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| {{#Wiki_filter:Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251 Attachment 2 ATTACHMENT 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION LICENSE AMENDMENT REQUEST NRC REQUEST FOR ADDITIONAL INFORMATION AND FPL RESPONSES DATABASE (1116 TOTAL PAGES, INCLUDING COVER SHEET) | | {{#Wiki_filter:}} |
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| 8/11/22, 10:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 32 NRC Question CCH001 Number Select Licensee Response Application Attachment Attachment 1 - CCH001 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response The previous response (L-2022-010 Attachment 1 Question 1) focused on the preclusion of operating in Statement Modes 1 and 2 without all reactor coolant pumps in operation. However, this analysis was removed from the licensing basis since operating with less than all 3 RCPs in Modes 1 and 2 is prohibited by TS. Moreover, Turkey Point does not have analysis for starting an inactive reactor coolant loop at an incorrect temperature (i.e. inadvertent) an incident of moderate frequencyin any mode. Starting inactive loops in lower modes, however, is permitted within the temperature limitations of the TSa normal operation event. Since the ITS bases discussion specifically refers to hot standby [Mode 3], this statement does apply to Turkey Point.
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| UFSAR Section 4.1.3 states that since no means are provided to isolate individual loops, and since natural circulation occurs it is not possible to preferentially cool a large volume of water that could be swept into the core. The system design permits reverse flow through the inactive loop(s) due to the pressure difference across the reactor vessel. The cold leg temperature in the inactive loop(s) is identical to the cold leg temperature of the active loop (the reactor coreinlet temperature). Therefore, the startup of an inactive RCP would not cause a discernable power excursion since water colder than the operating loop is not added to the reactor vessel. As such, starting an inactive RCP in MODES 3, 4, or 5 will not result in a "cold water" criticality.
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| FPL proposes to restore and revise the subject ITS 3.1.1 Bases paragraph to reflect PTN design and licensing bases (see attached).
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| | |
| ===Response===
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| 3/13/2022 8:15 AM Date/Time Closure Statement Question Closure 3/13/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 3/14/2022 7:15 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=32 1/1
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| SDM B 3.1.1 BASES
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| : c. Startup of an inactive reactor coolant pump (RCP)
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| APPLICABLE SAFETY ANALYSES (continued)
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| : c. Startup of an inactive reactor coolant pump (RCP), and 5 d.
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| : d. Rod ejection.
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| c Each of these events is discussed below.
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| In the boron dilution analysis, the required SDM defines the reactivity difference between an initial subcritical boron concentration and the corresponding critical boron concentration. These values, in conjunction with the configuration of the RCS and the assumed dilution flow rate, directly affect the results of the analysis. This event is most limiting at the beginning of core life, when critical boron concentrations are highest.
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| an overtemperature T Depending on the system initial conditions and reactivity insertion rate, high neutron flux trip the uncontrolled rod withdrawal transient is terminated by either a high power level trip or a high pressurizer pressure trip. In all cases, power 1 level, RCS pressure, linear heat rate, and the DNBR do not exceed The startup of an inactive allowable limits.
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| RCP will not result in a "cold water" criticality, because no The startup of an inactive RCP will not result in a "cold water" criticality, means are provided to even if the maximum difference in temperature exists between the SG isolate individual loops. 1 Natural circulation occurs and the core. The maximum positive reactivity addition that can occur when the RCS is hot and the due to an inadvertent RCP start is less than half the minimum required RCPs are not running. SDM. Startup of an idle RCP cannot, therefore, produce a return to Therefore, it is not possible power from the hot standby condition.
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| to preferentially cool a large volume of water that could be The ejection of a control rod rapidly adds reactivity to the reactor core, swept into the core. The maximum positive reactivity causing both the core power level and heat flux to increase with addition that can occur due corresponding increases in reactor coolant temperatures and pressure.
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| to an inactive RCP start is The ejection of a rod also produces a time dependent redistribution of less than the minimum core power.
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| required SDM. Startup of an inactive RCP cannot, SDM satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). Even though it is not therefore, produce a return to power from the hot standby directly observed from the control room, SDM is considered an initial condition. condition process variable because it is periodically monitored to ensure that the unit is operating within the bounds of accident analysis assumptions.
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| LCO SDM is a core design condition that can be ensured during operation through control rod positioning (control and shutdown banks) and through the soluble boron concentration.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.1-3 Rev. 5.0 1
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| 3/14/22, 12:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 36 NRC Question CCH001 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 3/14/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Added By Craig Harbuck Date Added 3/14/2022 11:15 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=36 1/1
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| 3/10/22, 9:21 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 48 NRC Question CCH002 Number Category Technical ITS 3.1 Section ITS 3.1.1 Number DOC M-1 Number JFD Number JFD Bases Number Page 248 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC DOC 3/4.10.5 - M01 states:
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| Question CTS 3.10.5 states The limitations of Specification 3.1.3.3 may be suspended during the performance of individual full-length shutdown and control rod drop time measurements provided;
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| : a. Only one shutdown or control bank is withdrawn from the fully inserted position at a time, and
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| : b. The rod position indicator is OPERABLE during the withdrawal of the rods.
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| The ITS does not contain this special test exception. This changes the CTS by eliminating a special test exception.
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| This change is acceptable because the performance of individual full-length shutdown and control rod drop time measurements is no longer performed. As a result this CTS Special test exception is not needed. This change is designated as more restrictive because an exception to the CTS is being deleted.
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| The licensee is requested to explain in DOC M01 why performance of individual full-length shutdown and control rod drop time measurements is no longer performed. The DOC should also explain how individual full-length shutdown and control rod drop times are currently verified to be within limits and will be verified under ITS.
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| Attach File Staff Request ID 114.docx (13KB) 1 Attach File 2
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| https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=48 1/2
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| 3/10/22, 9:21 AM Turkey Point ITS Conversion Database Issue Date 3/9/2022 Added By Craig Harbuck Date Modified Modified By Date 3/9/2022 6:01 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=48 2/2
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| 8/14/22, 9:38 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 41 NRC Question CCH002 Number Select Licensee Response Application Attachment Attachment 1 - CCH002 LAR markup.pdf (2MB) 1 Attachment 2
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| Response The drop times of individual full-length shutdown and control rods are required and verified per the Statement requirements of CTS 3.1.3.4. and 4.1.3.4. The CTS requirement to verify the rod drop times of individual full-length shutdown and control rods is retained in ITS SR 3.1.4.3. PTN has the capability to use rod drop test equipment for automated testing of rod drop times for one rod, a group of rods, a bank of rods, multiple banks of rods, or all rods at one time. Currently, rod drop testing is performed by testing multiple rods at one time, whereby individual rod drop times can be ascertained and compared to the applicable Surveillance acceptance criteria.
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| Moreover, CTS 3.10.5 is an exception to CTS 3.1.3.3, "Position Indication System - Shutdown," which requires the group step counter demand position indicator to be OPERABLE and capable of determining within +/- 2 steps the demand position in MODES 3, 4, and 5 with the Reactor Trip System breakers in the closed position. CTS 3.10.5 allows the CTS 3.1.3.3 requirements to be suspended provided the limitations of CTS 3.10.5 are met. CTS 3.1.3.3 requirements are proposed for relocation to the Technical Requirements Manual as shown in CTS 3.1.3.3 DOC R01. Therefore, the requirement to maintain the group step counter demand position indicator OPERABLE and capable of determining within +/- 2 steps the demand position in MODES 3, 4, and 5 will no longer be required by Technical Specifications. As a result, the CTS 3.10.5 special test exception is no longer needed.
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| For clarity, FPL proposes to replace CTS 3/4.10.5 DOC M01 with an administrative change (DOC A01) describing that the special test exception is no longer needed because CTS 3.1.3.3 requirements, which are suspended by CTS 3.10.5, are not retained in the ITS. The revised CTS page and DOC page are attached.
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| | |
| ===Response===
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| 3/22/2022 2:55 PM Date/Time Closure Statement Question Closure 3/22/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 3/22/2022 1:57 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=41 1/1
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| SPECIAL TEST EXCEPTIONS 3/4.10.5 POSITION INDICATION SYSTEM - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.10.5 The limitations of Specification 3.1.3.3 may be suspended during the performance of individual full-length shutdown and control rod drop time measurements provided;
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| : a. Only one shutdown or control bank is withdrawn from the fully inserted position at a time, and
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| : b. The rod position indicator is OPERABLE during the withdrawal of the rods.
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| APPLICABILITY: MODES 3, 4, and 5 during performance of rod drop time measurements.
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| A01 ACTION:
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| M01 With the Position Indication Systems inoperable or with more than one bank of rods withdrawn, immediately open the Reactor trip breakers.
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| SURVEILLANCE REQUIREMENTS 4.10.5 The above required Position Indication Systems shall be determined to be OPERABLE within 24 hours prior to the start of and in accordance with the Surveillance Frequency Control Program thereafter during rod drop time measurements by verifying the Demand Position Indication System and the Analog Rod Position Indication System agree:
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| : a. Within 12 steps when the rods are stationary, and
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| : b. Within 24 steps during rod motion.
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| TURKEY POINT - UNITS 3 & 4 3/4 10-4 AMENDMENT NOS. 263 AND 258 Page 1 of 1
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| | |
| DISCUSSION OF CHANGES CTS 3/4.10.5, POSITION INDICATION SYSTEM - SHUTDOWN ADMINISTRATIVE CHANGES None MORE RESTRICTIVE CHANGES M01 CTS 3.10.5 states The limitations of Specification 3.1.3.3 may be suspended during the performance of individual full-length shutdown and control rod drop time measurements provided;
| |
| : a. Only one shutdown or control bank is withdrawn from the fully inserted position at a time, and
| |
| : b. The rod position indicator is OPERABLE during the withdrawal of the rods.
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| The ITS does not contain this special test exception. This changes the CTS by eliminating a special test exception.
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| This change is acceptable because the performance of individual full-length shutdown and control rod drop time measurements is no longer performed. As a result this CTS Special test exception is not needed. This change is designated as more restrictive because an exception to the CTS is being deleted.
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| RELOCATED SPECIFICATIONS A01 CTS 3.10.5 allows the CTS 3.1.3.3, "Position Indication System
| |
| - Shutdown," to be suspended during the performance of individual None full-length shutdown and control rod drop time measurements provided two criteria are met. The ITS does not contain this special test exception (STE) because the CTS Specification being suspended REMOVED DETAIL CHANGES by the STE is proposed for relocation as shown in CTS 3.1.3.3 DOC R01. This changes the CTS by eliminating an STE.
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| None CTS 3.10.5 provides an STE to CTS 3.1.3.3, which requires the group step counter demand position indicator to be OPERABLE and capable of determining within +/- 2 steps the demand position in LESS RESTRICTIVE CHANGES MODES 3, 4, and 5 with the Reactor Trip System breakers in the closed position. CTS 3.1.3.3 is proposed for relocation to the None Technical Requirements Manual and will not be retained in the ITS.
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| Thus, this STE is no longer needed.
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| This change is considered administrative because it does not result in technical changes to the CTS because the CTS 3.1.3.3 requirements, which are suspended by CTS 3.10.5, are not retained in the ITS.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 4/21/22, 2:16 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 323 NRC Question CCH002 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 4/21/2022 Date Notification Craig Harbuck Christina Long William Maher Caroline Tilton Added By Craig Harbuck Date Added 4/21/2022 12:08 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=323 1/1
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| 3/24/22, 2:10 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 45 NRC Question CCH002 Number Select NRC Response Application Attachment 1
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| Attachment 2
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| Response The licensees response proposed to change the deletion of CTS 3.10.5 from a more restrictive change to an administrative change because of the relocation of the associated LCO 3.1.3.3 to the TRM. Why are the current STE limitations on rod position indication and shutdown bank withdrawal Statement during rod testing no longer needed if rod testing would involve not meeting relocated LCO 3.1.3.3? That is, why not also relocate CTS 3.10.5 to the TRM?
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| | |
| ===Response===
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| 3/24/2022 1:30 PM Date/Time Closure Statement Question Closure 3/24/2022 Date Notification Gregg Ellis Christina Long Caroline Tilton Added By Craig Harbuck Date 3/24/2022 12:29 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=45 1/1
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| 8/12/22, 10:04 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 250 NRC Question CCH002 Number Select Licensee Response Application Attachment Attachment 1 - CCH002-1 LAR markup.pdf (2MB) 1 Attachment 2
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| Response The special test exception (STE) requirements of CTS 3.10.5 were designed to waive the CTS 3.1.3.3 Statement requirements of the group step counter demand position indication requirements in MODES 3, 4, and 5 with the Reactor Trip System breakers closed to allow the performance of individual full-length shutdown and control rod drop time measurements. However, the need to waive the CTS 3.1.3.3 OPERABILITY requirements of the group step counter demand position indication is not necessary when rods are tested in multiple banks, or all at one time. As stated in the FPL response to CCH002, rod drop testing is performed at PTN by testing multiple rods at one time. Therefore, there is no need to utilize the STE requirements provided in CTS 3.10.5. As such, relocating the CTS 3.10.5 STE requirements along with the CTS 3.1.3.3 requirements to the TRM is unnecessary.
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| The proposed administrative A01 DOC will be revised to add the clarification that the STE requirements provided in CTS 3.10.5 are not included in the relocation to the TRM because the STE requirements are no longer use at PTN since rod drop testing is performed by testing multiple rods at one time, whereby individual rod drop times can be ascertained. This obviates the need for an STE to bypass the group step counter demand position indicator when performing individual full-length shutdown and control rod drop time measurements.
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| The revised CTS page and DOC page are attached. This attachment replaces and supersedes the attachment provided in the initial FPL Response to CCH002.
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| | |
| ==Attachment:==
| |
| : 1. CCH002-1 LAR Markup
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| | |
| ===Response===
| |
| 4/16/2022 9:50 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/16/2022 8:50 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=250 1/1
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| | |
| SPECIAL TEST EXCEPTIONS 3/4.10.5 POSITION INDICATION SYSTEM - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.10.5 The limitations of Specification 3.1.3.3 may be suspended during the performance of individual full-length shutdown and control rod drop time measurements provided;
| |
| : a. Only one shutdown or control bank is withdrawn from the fully inserted position at a time, and
| |
| : b. The rod position indicator is OPERABLE during the withdrawal of the rods.
| |
| APPLICABILITY: MODES 3, 4, and 5 during performance of rod drop time measurements.
| |
| A01 ACTION:
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| M01 With the Position Indication Systems inoperable or with more than one bank of rods withdrawn, immediately open the Reactor trip breakers.
| |
| SURVEILLANCE REQUIREMENTS 4.10.5 The above required Position Indication Systems shall be determined to be OPERABLE within 24 hours prior to the start of and in accordance with the Surveillance Frequency Control Program thereafter during rod drop time measurements by verifying the Demand Position Indication System and the Analog Rod Position Indication System agree:
| |
| : a. Within 12 steps when the rods are stationary, and
| |
| : b. Within 24 steps during rod motion.
| |
| TURKEY POINT - UNITS 3 & 4 3/4 10-4 AMENDMENT NOS. 263 AND 258 Page 1 of 1
| |
| | |
| DISCUSSION OF CHANGES CTS 3/4.10.5, POSITION INDICATION SYSTEM - SHUTDOWN ADMINISTRATIVE CHANGES None None MORE RESTRICTIVE CHANGES M01 CTS 3.10.5 states The limitations of Specification 3.1.3.3 may be suspended during the performance of individual full-length shutdown and control rod drop time measurements provided;
| |
| : a. Only one shutdown or control bank is withdrawn from the fully inserted position at a time, and
| |
| : b. The rod position indicator is OPERABLE during the withdrawal of the rods.
| |
| The ITS does not contain this special test exception. This changes the CTS by eliminating a special test exception.
| |
| This change is acceptable because the performance of individual full-length shutdown and control rod drop time measurements is no longer performed. As a result this CTS Special test exception is not needed. This change is designated as more restrictive because an exception to the CTS is being deleted.
| |
| RELOCATED SPECIFICATIONS A01 CTS 3.10.5 allows the CTS 3.1.3.3, "Position Indication System -
| |
| Shutdown," to be suspended during the performance of individual full-None length shutdown and control rod drop time measurements provided two criteria are met. The ITS does not contain this special test exception (STE) because the STE is no longer needed. This changes the CTS by REMOVED DETAIL CHANGES eliminating an STE.
| |
| CTS 3.10.5 provides an STE to CTS 3.1.3.3, which requires the group None step counter demand position indicator to be OPERABLE and capable of determining within +/- 2 steps the demand position in MODES 3, 4, and 5 with the Reactor Trip System breakers in the closed position. CTS LESS RESTRICTIVE CHANGES 3.1.3.3 is proposed for relocation to the Technical Requirements Manual (TRM) and will not be retained in the ITS. This STE is not included in None the relocation to the TRM because the STE requirements are no longer use at PTN because rod drop testing is performed by testing multiple rods at one time, whereby individual rod drop times can be ascertained.
| |
| This obviates the need for an STE to bypass the group step counter demand position indicator when performing individual full-length shutdown and control rod drop time measurements.
| |
| This change is considered administrative because it does not result in technical changes to the CTS because the CTS 3.1.3.3 requirements, which are suspended by CTS 3.10.5, are not retained in the ITS.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 4/21/22, 2:16 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 323 NRC Question CCH002 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 4/21/2022 Date Notification Craig Harbuck Christina Long William Maher Caroline Tilton Added By Craig Harbuck Date Added 4/21/2022 12:08 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=323 1/1
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| 3/27/22, 5:10 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 265 NRC Question CCH003 Number Category Technical ITS Section 3.1l3.2 ITS Number 3.1.4 DOC Number A-1 JFD Number 5 JFD Bases 1
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| Number Page 74, 90, 93 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC ITS 3.1.4 - pages 74, 90, 93 of 251 - ITS 3.1.4, Rod Group Alignment Limits Question CTS 3.1.3.1, ACTION d.3.c) states (with unrelated proposed markup addressed by DOC 3.1.4-L02):
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| : d. With one full length rod ... misaligned from its group step counter demand position by more than the Allowed Rod Misalignment of Specification 3.1.3.1, POWER OPERATION may continue provided that within one hour either:
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| : 3. The rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:
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| c) A power distribution map is obtained from the movable incore detectors and FQ (Z) and FNH are verified to be within their limits within 72 hours, and ITS 3.1.4, Required Action B.4 states (STS markup shown and explained by JFD 3.1.4-5):
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| B. One rod not within alignment limits. l B.1.1 Verify SDM to be within the limits specified in the COLR. l 1 hour OR B.1.2 Initiate boration to restore SDM to within limit. l 1 hour AND B.2 Reduce THERMAL POWER to 75% RTP. l 2 hours AND B.3 Verify SDM is within the limits specified in the COLR. l Once per 12 hours AND B.4 Perform SR 3.2.1.1 or, SR 3.2.1.2, and SR 3.2.2.1. l 72 hours AND . . .
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| https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=265 1/2
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| | |
| 3/27/22, 5:10 PM Turkey Point ITS Conversion Database The ITS 3.1.4 Bases for Required Action B.4 states (with STS markup addressed by JFD B 3.1.4-1):
| |
| Verifying that FQ(Z), as approximated by FCQ (Z) and FWQ (Z), and FNH are within the required limits ensures that current operation at 75% RTP with a rod misaligned is not resulting in power distributions that may invalidate safety analysis assumptions at full power. The Completion Time of 72 hours allows sufficient time to obtain flux maps of the core power distribution using the incore flux mapping system and to calculate FQ (Z) and FNH.
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| The licensee is requested to clarify ITS 3.1.4 Required Action B.4 and its Bases regarding which of SR 3.2.1.1 and SR 3.2.1.2 may be performed to determine FQ(Z).
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| Attach File 1 Attach File 2 Issue Date 3/25/2022 Added By Craig Harbuck Date Modified Modified By Date Added 3/25/2022 9:26 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=265 2/2
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| 8/12/22, 10:07 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 275 NRC Question CCH003 Number Select Licensee Response Application Attachment Attachment 1 - CCH003 LAR Markups.pdf (2MB) 1 Attachment 2
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| Response ITS 3.1.4 Required Action B.4 will be revised to clarify which of SR 3.2.1.1 and SR 3.2.1.2 is required to be Statement performed. The revised ISTS Required Action B.4 will be broken down into Required Actions B.4.1, B.4.2, and B.5 (see the ITS markup page in Attachment 1), each with a Completion Time of 72 hours. In addition, ITS 3.1.4 Required Action B.5 is renumbered as Required Action B.6 as a conforming change. Revision 1 of the PTN ITS Conversion license amendment request (LAR) modified ITS SR 3.2.1.1 and SR 3.2.1.2. These changes are reflected in ITS 3.1.4 Required Actions B.4.1 and B.4.2, which specify the requirements (via Required Actions Notes) for calculating FQZ using the methods specified in SR 3.2.1.1 and SR 3.2.1.2. In addition, the ITS 3.1.4 CTS markup, ISTS justification for deviations, and ITS Bases markup will be revised accordingly to coincide with the changes made to the ITS markup as shown in Attachment 1.
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| | |
| ==Attachment:==
| |
| : 1. CCH003 LAR Markup
| |
| | |
| ===Response===
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| 4/19/2022 8:45 AM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/19/2022 7:45 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=275 1/1
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| | |
| ITS 0 A01 ITS 3.1.4 REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)
| |
| : d. With one full length rod inoperable due to causes other than addressed by ACTION a, above, or misaligned from its group step counter demand position by more than the Allowed Rod Misalignment of Specification 3.1.3.1, POWER OPERATION may continue provided that within 0 A01 one hour either:
| |
| ~~=~~~~~~~~~~~~~==~~~o
| |
| : 1. The rod is restored to OPERABLE status within the Allowed Rod Misalignment of A05 ACTION B Specification 3.1.3.1, or
| |
| : 2. The remainder of the rods in the bank with the inoperable rod are aligned to within the Allowed Rod Misalignment of Specification 3.1.3.1 of the inoperable rod while maintaining A03 the rod sequence and insertion limits of Specification 3.1.3.6; the THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.6 during subsequent operation, or L02 L01
| |
| : 3. The rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:
| |
| Add proposed Required Action B.1.2 two L03 a) The THERMAL POWER level is reduced to less than or equal to 75% of RATED THERMAL POWER within one hour and within the next 4 hours the power range L04 neutron flux high trip setpoint is reduced to less than or equal to 85% of RATED THERMAL POWER. THERMAL POWER shall be maintained less than or equal to 75% of RATED THERMAL POWER until compliance with ACTIONS A01 3.1.3.1.d.3.c and 3.1.3.1.d.3.d below are demonstrated, and ACTION B b) The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours, and ACTIONS B.4.1, c) A power distribution map is obtained from the movable incore detectors and A01 B.4.2, B.5 FQ (Z) and FNH are verified to be within their limits within 72 hours, and Perform SR 3.2.1.1 OR SR 3.2.1.2; d) A reevaluation of each accident analysis of Table 3.1-1 is performed within 5 LA01 AND SR 3.2.2.1 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions.
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| Add proposed ACTION C M02 SURVEILLANCE REQUIREMENTS SR 3.1.4.1 4.1.3.1.1 The position of each full length rod shall be determined to be within the Allowed Rod Misalignment of SR 3.1.4.1 the group step counter demand position in accordance with the Surveillance Frequency Control Program Note 2 (allowing for one hour thermal soak after rod motion) [except during time intervals when the Rod Position SR 3.1.4.1 Deviation Monitor is inoperable, then verify the group positions]- at least once
| |
| - per 4- hours. L05 Note 1 SR 3.1.4.2 4.1.3.1.2 Each full length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 10 steps in any one direction in accordance with the Surveillance Frequency Control Program. A01 TURKEY POINT - UNITS 3 & 4 3/4 1-17 AMENDMENT NOS. 263 AND 258 Page 2 of 6
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| | |
| CTS Rod Group Alignment Limits 3.1.4 ACTIONS (continued)
| |
| CONDITION REQUIRED ACTION COMPLETION TIME 3.1.3.1 ACTION d B.1.2 Initiate boration to restore 1 hour SDM to within limit.
| |
| AND B.2 Reduce THERMAL 2 hours POWER to 75% RTP.
| |
| B.4.1 -----------------NOTE------------------- AND Not required to be performed when FQP exceeds FQL and THERMAL POWER is > PT. B.3 Verify SDM is within the Once per
| |
| --------------------------------------------- limits specified in the 12 hours Perform SR 3.2.1.1 COLR.
| |
| OR AND or B.4.2 -----------------NOTE-------------------
| |
| Only required to be performed when FQP exceeds FQL and THERMAL POWER is > PT.
| |
| B.4 °J Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.
| |
| 72 hours 72 hours 05
| |
| --------------------------------------------- 72 hours AND Perform SR 3.2.1.2 AND B.5 Perform SR 3.2.2.1 B.5 Re-evaluate safety 5 days analyses and confirm results remain valid for 6 duration of operation under these conditions.
| |
| DOC M02 C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition B not met.
| |
| 3.1.3.1 ACTION b,D. More than one rod not D.1.1 Verify SDM is within the 1 hour 3.1.3.1 ACTION c within alignment limit. limits specified in the COLR.
| |
| OR Turkey Point Unit 3 and Unit 4 Westinghouse STS 3.1.4-2 Amendment Nos. XXX and YYY Rev. 5.0 0 1
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| | |
| JUSTIFICATION FOR DEVIATIONS ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS
| |
| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
| |
| : 2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
| |
| : 3. Changes were made to reflect inclusion of specific CTS not included in ISTS.
| |
| : 4. Changes have been made to reflect changes made to the Specification.
| |
| : 5. CTS 3.1.3.1 Action d.3.c) requires that a power distribution map is obtained from the movable incore detectors and FQo(Z) and FNH are verified to be within their limits within 72 hours. ITS 3.1.4 Required Action B.4 provides similar requirements allowing FQo(Z) to be obtained by either SR 3.2.1.1 or SR 3.2.1.2 and FNH to be obtained by SR 3.2.2.1.
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| Actions B.4.1 and B.4.2 Required Action B.5 provides requirements allowing Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| Rod Group Alignment Limits B 3.1.4 BASES ACTIONS (continued)
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| A.2 If the inoperable rod(s) cannot be restored to OPERABLE status, the plant must be brought to a MODE or condition in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours.
| |
| The allowed Completion Time is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.
| |
| B.1.1 and B.1.2 When a rod becomes misaligned, it can usually be moved and is still trippable.
| |
| 0 7 An alternative to realigning a single misaligned RCCA to the group average position is to align the remainder of the group to the position of the misaligned RCCA. However, this must be done without violating the bank sequence, overlap, and insertion limits specified in LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6, "Control Bank Insertion Limits."
| |
| In many cases, realigning the remainder of the group to the misaligned rod may not be desirable. For example, realigning control bank B to a rod that is misaligned 15 steps from the top of the core would require a significant power reduction, since control bank D must be moved fully in and control bank C must be moved in to approximately 100 to 115 steps.
| |
| 01 misaligned but
| |
| ~
| |
| Power operation may continue with one RCCA trippable but misaligned, (OPERABLE)
| |
| ~._______JI O07 4 provided that SDM is verified within 1 hour. The Completion Time of 1 hour represents the time necessary for determining the actual unit SDM and, if necessary, aligning and starting the necessary systems and B.4.1., B.4.2, B.5 components to initiate boration.
| |
| 6 B.2, B.3, B.4, and B.5 For continued operation with a misaligned rod, RTP must be reduced, SDM must periodically be verified within limits, hot channel factors (FQ(Z) and F N H ) must be verified within limits, and the safety analyses must be 0 1 re-evaluated to confirm continued operation is permissible.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.4-5 ' - - - - - ~--
| |
| Rev. 5.0 01
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| | |
| Rod Group Alignment Limits B 3.1.4 BASES ACTIONS (continued) resulting from 1
| |
| Reduction of power to 75% RTP ensures that local LHR increases due to 4 a misaligned RCCA will not cause the core design criteria to be exceeded 1
| |
| (Ref. 7). The Completion Time of 2 hours gives the operator sufficient time to accomplish an orderly power reduction without challenging the Reactor Protection System.
| |
| When a rod is known to be misaligned, there is a potential to impact the SDM. Since the core conditions can change with time, periodic verification of SDM is required. A Frequency of 12 hours is sufficient to The calculation of FQ(Z) is ensure this requirement continues to be met.
| |
| required by performing SR 3.2.1.1 or SR 3.2.1.2 depending if FQP exceeds FQL and THERMAL POWER is > PT as specified in the Verifying that FQ(Z), as approximated by F QC ( Z) and F WQ ( Z) , and F N H are within the required limits ensures that current operation at 75% RTP with 0 1 a rod misaligned is not resulting in power distributions that may invalidate ACTIONS B.4.1.1 and B.4.1.2 Notes. safety analysis assumptions at full power. The Completion Time of 72 hours allows sufficient time to obtain flux maps of the core power distribution using the incore flux mapping system and to calculate FQ(Z)
| |
| Add JFD 1 and F N H .
| |
| Once current conditions have been verified acceptable, time is available to perform evaluations of accident analysis to determine that core limits 4
| |
| will not be exceeded during a Design Basis Event for the duration of U operation under these conditions. The accident analyses presented in 0--FSAR_ Chapter __,....15- (Ref. -5) that may be adversely affected will be 4 evaluated to ensure that the analysis results remain valid for the duration of continued operation under these conditions. A Completion Time of 0 1 5 days is sufficient time to obtain the required input data and to perform the analysis.
| |
| C.1 When Required Actions cannot be completed within their Completion 4
| |
| Time, the unit must be brought to a MODE or Condition in which the LCO requirements are not applicable. To achieve this status, the unit 3 4 must be brought to at least MODE 2 with Keff < 1.0 within 6 hours, which obviates concerns about the development of undesirable xenon or power distributions. The allowed Completion Time of 6 hours is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging the plant systems.
| |
| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.4-6 Rev. 5.0
| |
| ' - - - - - ~: . . . . _ _ _
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| 0 1
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| | |
| 5/31/22, 12:04 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 387 NRC Question CCH003 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
| |
| Question Closure 5/9/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 5/8/2022 2:40 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=387 1/1
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| | |
| 4/26/22, 8:48 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 339 NRC Question CCH003 Number Select NRC Response Application Attachment 1
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| Attachment 2
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| | |
| ===Response===
| |
| Statement Staff request editorial clarification changes to proposed addition to fourth paragraph of Bases for ITS 3.2.1 ACTION B. Replace "if" with "whether or not";
| |
| exceeds with is <;
| |
| "and" with "when";
| |
| ACTIONS with Notes for Required Actions; and delete Notes at the end so that the sentence states:
| |
| The calculation of FQ(Z) is required by performing SR 3.2.1.1 or SR 3.2.1.2 depending if upon whether or not FQP exceeds is < FQL and when THERMAL POWER is > PT as specified in the ACTIONS Notes for Required Actions B.4.1.1 and B.4.1.2 Notes.
| |
| or The calculation of FQ(Z) is required by performing SR 3.2.1.1 or SR 3.2.1.2 depending upon whether or not FQP is < FQL when THERMAL POWER is > PT as specified in the Notes for Required Actions B.4.1.1 and B.4.1.2.
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| | |
| ===Response===
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| 4/25/2022 5:55 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Added By Craig Harbuck Date 4/25/2022 4:56 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=339 1/2
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| 4/26/22, 8:48 AM Turkey Point ITS Conversion Database https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=339 2/2
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| | |
| 8/12/22, 10:10 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 367 NRC Question CCH003 Number Select Licensee Response Application Attachment Attachment 1 - CCH003-1 LAR Markup.pdf (792KB) 1 Attachment 2
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| Response During the FPL review of the cited Bases paragraph, it was determined the cited Bases paragraph is Statement associated with ITS 3.1.4 ACTION B instead of ITS 3.2.1 ACTION B. The proposed addition to the fourth paragraph of Bases for ITS 3.1.4 ACTION B will be revised as follows:
| |
| The calculation of FQ(Z) is required by performing SR 3.2.1.1 or SR 3.2.1.2 depending upon whether FQP exceeds FQL when THERMAL POWER is > PT as specified in the Notes for Required Actions B.4.1 and B.4.2.
| |
| The word exceeds is maintained consistent with the word usage in the referenced Notes and a clerical error associated with the Required Action numbering is corrected by changing B.4.1.1 and B.4.1.2 to B.4.1 and B.4.2, respectively, to match the ITS 3.1.4 Required Action designations.
| |
| Attachment 1 - CCH003 LAR Markups provided in the initial FPL response to RAI CCH003 is superseded and replaced with Attachment 1 - CCH003-1 LAR Markup.
| |
| Attachment
| |
| : 1. CCH003-1 LAR Markup
| |
| | |
| ===Response===
| |
| 5/3/2022 4:00 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 5/3/2022 2:59 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=367 1/1
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| | |
| ITS 0 A01 ITS 3.1.4 REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)
| |
| : d. With one full length rod inoperable due to causes other than addressed by ACTION a, above, or misaligned from its group step counter demand position by more than the Allowed Rod Misalignment of Specification 3.1.3.1, POWER OPERATION may continue provided that within 0 A01 one hour either:
| |
| ~~=~~~~~~~~~~~~~==~~~o
| |
| : 1. The rod is restored to OPERABLE status within the Allowed Rod Misalignment of A05 ACTION B Specification 3.1.3.1, or
| |
| : 2. The remainder of the rods in the bank with the inoperable rod are aligned to within the Allowed Rod Misalignment of Specification 3.1.3.1 of the inoperable rod while maintaining A03 the rod sequence and insertion limits of Specification 3.1.3.6; the THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.6 during subsequent operation, or L02 L01
| |
| : 3. The rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:
| |
| Add proposed Required Action B.1.2 two L03 a) The THERMAL POWER level is reduced to less than or equal to 75% of RATED THERMAL POWER within one hour and within the next 4 hours the power range L04 neutron flux high trip setpoint is reduced to less than or equal to 85% of RATED THERMAL POWER. THERMAL POWER shall be maintained less than or equal to 75% of RATED THERMAL POWER until compliance with ACTIONS A01 3.1.3.1.d.3.c and 3.1.3.1.d.3.d below are demonstrated, and ACTION B b) The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours, and Required Actions c) A power distribution map is obtained from the movable incore detectors and A01 B.4.1, B.4.2, B.5 FQ (Z) and FNH are verified to be within their limits within 72 hours, and Perform SR 3.2.1.1 OR SR 3.2.1.2; d) A reevaluation of each accident analysis of Table 3.1-1 is performed within 5 LA01 AND SR 3.2.2.1 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions.
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| Add proposed ACTION C M02 SURVEILLANCE REQUIREMENTS SR 3.1.4.1 4.1.3.1.1 The position of each full length rod shall be determined to be within the Allowed Rod Misalignment of SR 3.1.4.1 the group step counter demand position in accordance with the Surveillance Frequency Control Program Note 2 (allowing for one hour thermal soak after rod motion) [except during time intervals when the Rod Position SR 3.1.4.1 Deviation Monitor is inoperable, then verify the group positions]- at least once
| |
| - per 4- hours. L05 Note 1 SR 3.1.4.2 4.1.3.1.2 Each full length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 10 steps in any one direction in accordance with the Surveillance Frequency Control Program. A01 TURKEY POINT - UNITS 3 & 4 3/4 1-17 AMENDMENT NOS. 263 AND 258 Page 2 of 6
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| | |
| CTS Rod Group Alignment Limits 3.1.4 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME 3.1.3.1 ACTION d B.1.2 Initiate boration to restore 1 hour SDM to within limit.
| |
| AND B.2 Reduce THERMAL 2 hours POWER to 75% RTP.
| |
| B.4.1 -----------------NOTE------------------- AND Not required to be performed when FQP exceeds FQL and THERMAL POWER is > PT. B.3 Verify SDM is within the Once per
| |
| --------------------------------------------- limits specified in the 12 hours Perform SR 3.2.1.1 COLR.
| |
| OR AND or B.4.2 -----------------NOTE-------------------
| |
| Only required to be performed when FQP exceeds FQL and THERMAL POWER is > PT.
| |
| B.4 °J Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.
| |
| 72 hours 72 hours 05
| |
| --------------------------------------------- 72 hours AND Perform SR 3.2.1.2 AND B.5 Perform SR 3.2.2.1 B.5 Re-evaluate safety 5 days analyses and confirm results remain valid for 6 duration of operation under these conditions.
| |
| DOC M02 C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition B not met.
| |
| 3.1.3.1 ACTION b,D. More than one rod not D.1.1 Verify SDM is within the 1 hour 3.1.3.1 ACTION c within alignment limit. limits specified in the COLR.
| |
| OR Turkey Point Unit 3 and Unit 4 Westinghouse STS 3.1.4-2 Amendment Nos. XXX and YYY Rev. 5.0 0 1
| |
| | |
| JUSTIFICATION FOR DEVIATIONS ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS
| |
| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
| |
| : 2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
| |
| : 3. Changes were made to reflect inclusion of specific CTS not included in ISTS.
| |
| : 4. Changes have been made to reflect changes made to the Specification.
| |
| : 5. CTS 3.1.3.1 Action d.3.c) requires that a power distribution map is obtained from the movable incore detectors and FQo(Z) and FNH are verified to be within their limits within 72 hours. ITS 3.1.4 Required Action B.4 provides similar requirements allowing FQo(Z) to be obtained by either SR 3.2.1.1 or SR 3.2.1.2 and FNH to be obtained by SR 3.2.2.1.
| |
| Actions B.4.1 and B.4.2 Required Action B.5 provides requirements allowing Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| | |
| Rod Group Alignment Limits B 3.1.4 BASES ACTIONS (continued)
| |
| A.2 If the inoperable rod(s) cannot be restored to OPERABLE status, the plant must be brought to a MODE or condition in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours.
| |
| The allowed Completion Time is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.
| |
| B.1.1 and B.1.2 When a rod becomes misaligned, it can usually be moved and is still trippable.
| |
| 0 7 An alternative to realigning a single misaligned RCCA to the group average position is to align the remainder of the group to the position of the misaligned RCCA. However, this must be done without violating the bank sequence, overlap, and insertion limits specified in LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6, "Control Bank Insertion Limits."
| |
| In many cases, realigning the remainder of the group to the misaligned rod may not be desirable. For example, realigning control bank B to a rod that is misaligned 15 steps from the top of the core would require a significant power reduction, since control bank D must be moved fully in and control bank C must be moved in to approximately 100 to 115 steps.
| |
| 01 misaligned but
| |
| ~
| |
| Power operation may continue with one RCCA trippable but misaligned, (OPERABLE)
| |
| ~._______JI O07 4 provided that SDM is verified within 1 hour. The Completion Time of 1 hour represents the time necessary for determining the actual unit SDM and, if necessary, aligning and starting the necessary systems and B.4.1, B.4.2, B.5 components to initiate boration.
| |
| 6 B.2, B.3, B.4, and B.5 For continued operation with a misaligned rod, RTP must be reduced, SDM must periodically be verified within limits, hot channel factors (FQ(Z) and F N H ) must be verified within limits, and the safety analyses must be 0 1 re-evaluated to confirm continued operation is permissible.
| |
| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.4-5 ' - - - - - ~--
| |
| Rev. 5.0 01
| |
| | |
| Rod Group Alignment Limits B 3.1.4 BASES ACTIONS (continued) resulting from 1
| |
| Reduction of power to 75% RTP ensures that local LHR increases due to 4 a misaligned RCCA will not cause the core design criteria to be exceeded 1
| |
| (Ref. 7). The Completion Time of 2 hours gives the operator sufficient time to accomplish an orderly power reduction without challenging the Reactor Protection System.
| |
| When a rod is known to be misaligned, there is a potential to impact the SDM. Since the core conditions can change with time, periodic verification of SDM is required. A Frequency of 12 hours is sufficient to The calculation of FQ(Z) is ensure this requirement continues to be met.
| |
| required by performing SR 3.2.1.1 or SR 3.2.1.2 depending upon whether FQP exceeds FQL when THERMAL POWER is > PT Verifying that FQ(Z), as approximated by F QC ( Z) and F WQ ( Z) , and F N H are within the required limits ensures that current operation at 75% RTP with 0 1 a rod misaligned is not resulting in power distributions that may invalidate as specified in the Notes for Required Actions B.4.1 and safety analysis assumptions at full power. The Completion Time of B.4.2. 72 hours allows sufficient time to obtain flux maps of the core power distribution using the incore flux mapping system and to calculate FQ(Z)
| |
| Add JFD 1 and F N H .
| |
| Once current conditions have been verified acceptable, time is available to perform evaluations of accident analysis to determine that core limits 4
| |
| will not be exceeded during a Design Basis Event for the duration of U operation under these conditions. The accident analyses presented in 0--FSAR_ Chapter __,....15- (Ref. -5) that may be adversely affected will be 4 evaluated to ensure that the analysis results remain valid for the duration of continued operation under these conditions. A Completion Time of 0 1 5 days is sufficient time to obtain the required input data and to perform the analysis.
| |
| C.1 When Required Actions cannot be completed within their Completion 4
| |
| Time, the unit must be brought to a MODE or Condition in which the LCO requirements are not applicable. To achieve this status, the unit 3 4 must be brought to at least MODE 2 with Keff < 1.0 within 6 hours, which obviates concerns about the development of undesirable xenon or power distributions. The allowed Completion Time of 6 hours is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging the plant systems.
| |
| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.4-6 Rev. 5.0
| |
| ' - - - - - ~: . . . . _ _ _
| |
| 0 1
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| 5/9/22, 7:52 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 387 NRC Question CCH003 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/9/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 5/8/2022 2:40 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=387 1/1
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| | |
| 3/28/22, 2:12 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 293 NRC Question CCH004 Number Category Technical ITS 3.1 Section ITS 3.1.4 Number DOC A-1 Number JFD Number JFD Bases 6
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| Number Page 74, 91, 103 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.1.4 - pages 74, 91, and 103 of 251 - ITS 3.1.4, Rod Group Alignment Limits Question CTS SR 4.1.3.1.1, The position of each full length rod shall be determined to be within the Allowed Rod Misalignment of the group step counter demand position in accordance with the Surveillance Frequency Control Program ..., corresponds to ITS SR 3.1.4.1, Verify position of individual rods within alignment limit. l In accordance with the Surveillance Frequency Control Program The markup of STS SR 3.1.4.1 Bases indicates that the ITS SR 3.1.4.1 Frequency is in accordance with the SFCP. However, the STS Bases for STS SR 3.1.4.1 brackets the entire description of the Surveillance instead of bracketing just the rationale for the 12-hour Frequency, which is contained in the description of the Surveillance. The STS Bases markup shows that the Surveillance description in addition to the Frequency rationale is being omitted in the ITS Bases, which is not the intent of the brackets.
| |
| : 1. The licensee is requested to provide a description of the Surveillance and its rationale in the Bases for ITS SR 3.1.4.1, in accordance with JFD B 3.1.4-6, which states, The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
| |
| : 2. Staff observes that the descriptive details of this Surveillance in CTS SR 4.1.3.1.1 could be characterized as being relocated to the ITS SR 3.1.4.1 Bases as an LA-type change. The licensee is requested to address this apparent change in an LA-type DOC.
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| Attach File 1
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| Attach File 2
| |
| Issue Date 3/28/2022 Added By Craig Harbuck Date Modified Modified By Date 3/28/2022 11:12 AM Added https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=293 1/2
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| | |
| 3/28/22, 2:12 PM Turkey Point ITS Conversion Database Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=293 2/2
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| 8/12/22, 10:10 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 319 NRC Question CCH004 Number Select Licensee Response Application Attachment Attachment 1 - CCH004 LAR Markup.pdf (820KB) 1 Attachment 2
| |
| Response With respect to Item 1 of the CCH004 request, the current markup of the ITS SR 3.1.4.1 Bases is consistent Statement with the STS and Technical Specification Task Force (TSTF) traveler TSTF-425-A, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," Revision 3. As indicated in the Reviewers Note in the ISTS Bases associated with SR 3.1.4.1, plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program (SFCP) should utilize the appropriate Frequency description. The Frequency of CTS 4.3.1.1 (ITS SR 3.1.4.1) is controlled under the SFCP. Therefore, the optional text associated with the SFCP was selected consistent with the current licensing basis as indicated in JFD B 3.1.4-6. Further modifying the ISTS Bases markup as requested would represent a deviation from the STS Bases and TSTF-425 as indicated in the STS Reviewers Note. Therefore, FPL does not propose a change to the ITS 3.1.4 Bases markup that would result in a deviation from the STS.
| |
| With respect to Item 2 of the CCH004 request and in support of consistency with ITS SR 3.1.4.1, wording will be removed from CTS 4.1.3.1.1 per DOC A01 ("full length" and "of the group step counter demand position" deleted). ITS SR 3.1.4.1 requires verification of the position of individual rods within the alignment limit, since the rod misalignment limits (Allowed Rod Misalignment) are described in the ITS 3.1.4 Limiting Condition for Operation (LCO). In addition, at PTN all control and shutdown rods are full length rods. Subsequently, the deleted wording is not required to meet the intent of ITS SR 3.1.4.1. These changes represent wording preference, editorial change, and reformatting to obtain consistency with the ISTS as specified in DOC A01 with no further discussion of change required. The reference to "thermal soak" in CTS 4.1.3.1.1 is proposed for relocation to the ITS 3.1.4 Bases. Therefore, a new DOC LA02 has been developed in support of this relocation. A markup of the affected ITS 3.4.1 CTS markup, DOC, and ITS Bases markup pages from the ITS Conversion Revision 1 license amendment request is attached, including new DOC LA02.
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| | |
| ==Attachment:==
| |
| : 1. CCH004 LAR Markup
| |
| | |
| ===Response===
| |
| 4/21/2022 9:40 AM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/21/2022 8:40 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=319 1/1
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| | |
| A01 ITS ITS 3.1.4 REACTIVITY CONTROL SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)
| |
| : d. With one full length rod inoperable due to causes other than addressed by ACTION a, above, A01 or misaligned from its group step counter demand position by more than the Allowed Rod Misalignment of Specification 3.1.3.1, POWER OPERATION may continue provided that within one hour either:
| |
| : 1. The rod is restored to OPERABLE status within the Allowed Rod Misalignment of A05 ACTION B Specification 3.1.3.1, or
| |
| : 2. The remainder of the rods in the bank with the inoperable rod are aligned to within the Allowed Rod Misalignment of Specification 3.1.3.1 of the inoperable rod while maintaining A03 the rod sequence and insertion limits of Specification 3.1.3.6; the THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.6 during subsequent operation, or L02 L01
| |
| : 3. The rod is declared inoperable and the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:
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| Add proposed Required Action B.1.2 two L03 a) The THERMAL POWER level is reduced to less than or equal to 75% of RATED THERMAL POWER within one hour and within the next 4 hours the power range L04 neutron flux high trip setpoint is reduced to less than or equal to 85% of RATED THERMAL POWER. THERMAL POWER shall be maintained less than or equal to 75% of RATED THERMAL POWER until compliance with ACTIONS A01 3.1.3.1.d.3.c and 3.1.3.1.d.3.d below are demonstrated, and ACTION B b) The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours, and c) A power distribution map is obtained from the movable incore detectors and FQ (Z) and FNH are verified to be within their limits within 72 hours, and d) A reevaluation of each accident analysis of Table 3.1-1 is performed within 5 LA01 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions.
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| Add proposed ACTION C M02 SURVEILLANCE REQUIREMENTS alignment limit SR 3.1.4.1 4.1.3.1.1 The position of each full length rod shall be determined to be within the Allowed Rod Misalignment of A01 SR 3.1.4.1 the group step counter demand position in accordance with the Surveillance Frequency Control Program Note 2 (allowing for one hour thermal soak after rod motion) except during time intervals when the Rod Position LA02 SR 3.1.4.1 Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours. L05 Note 1 SR 3.1.4.2 4.1.3.1.2 Each full length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 10 steps in any one direction in accordance with the Surveillance Frequency Control Program. A01 TURKEY POINT - UNITS 3 & 4 3/4 1-17 AMENDMENT NOS. 263 AND 258 Page 2 of 6
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| DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS designated as more restrictive because it adds explicit actions to verify SDM or to restore SDM within limits and reduces the time required to be in MODE 3.
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| RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.1.3.1 ACTION d.3.d) states when a rod is misaligned, POWER OPERATION may continue if a reevaluation of each accident analysis in Table 3.1-1 is performed within 5 days. This reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions. ITS 3.1.4 Required Action B.5 requires that when one rod is misaligned, re-evaluation of the safety analyses is performed along with confirmation that the results remain valid for the duration of operation under these conditions. This changes the CTS by moving the accidents listed in Table 3.1-1 to the Updated Final Safety Analysis Report (UFSAR).
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| The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to re-evaluate the safety analyses and confirm that the results remain valid for the duration of operation under these conditions.
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| Additionally, this change is acceptable because the removed information will be adequately controlled in the UFSAR. The UFSAR is controlled under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because information Add LA02 relating to procedural detail is being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.1.3.1 ACTION a states, in part, with one or more full length rods inoperable due to being immovable as a result of excessive friction, determine that the SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is satisfied within 1 hour. CTS 3.1.3.1 ACTION d.3 states, in part, with one full length rod misaligned from its group step counter demand height, the rod is declared inoperable and the SDM requirement of Specification 3.1.1.1 is satisfied within 1 hour. ITS 3.1.4 ACTION A and B requires, within 1 hour, to verify SDM is within the limits specified in the COLR or to initiate boration to restore SDM to within limits. This changes the CTS by allowing boration to restore SDM.
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| The purpose of CTS 3.1.3.1 ACTION a and d.3 is to verify adequate SDM exists.
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| This change is acceptable because the ITS 3.1.4 Required Actions are used to establish remedial measures that must be taken in response to the degraded Turkey Point Unit 3 and Unit 4 Page 4 of 8
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| Rod Group Alignment Limits B 3.1.4 BASES SURVEILLANCE REQUIREMENTS (continued)
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5
| |
| description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ] 6 The SR is modified by a Note that permits it to not be performed for rods associated with an inoperable demand position indicator or an inoperable rod position indicator. The alignment limit is based on the demand position indicator which is not available if the indicator is inoperable.
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| LCO 3.1.7, "Rod Position Indication," provides Actions to verify the rods are in alignment when one or more rod position indicators are inoperable.
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| ---------------------------------- Reviewer's Note ----------------------------------------
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| The bracketed SR Note is only applicable to plants with an analog rod 5 position indication system.
| |
| [The Surveillance is modified by a Note which states that the SR is not 6 required to be performed until 1 hour after associated rod motion. Control JFD 1 rod temperature affects the accuracy of the rod position indication system. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows control rod temperature to stabilize following rod movement in 6
| |
| order to ensure the indicated rod position is accurate.]
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| to allow for thermal soak SR 3.1.4.2 Verifying each control rod is OPERABLE would require that each rod be tripped. However, in MODES 1 and 2 with Keff 1.0, tripping each control 4 rod would result in radial or axial power tilts, or oscillations. Exercising each individual control rod provides increased confidence that all rods in either greater than or equal to continue to be OPERABLE without exceeding the alignment limit, even if direction 1
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| they are not regularly tripped. Moving each control rod by 10 steps will not cause radial or axial power tilts, or oscillations, to occur. [ The 92 day Frequency takes into consideration other information available to the 6
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| operator in the control room and SR 3.1.4.1, which is performed more frequently and adds to the determination of OPERABILITY of the rods.
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| OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.4-8 Rev. 5.0 1
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| Add new LA02 LA02 (Type 1 - Removing Details of System Design and System Description, including Design Limits) CTS 4.1.3.1.1 requires, in part, the position of each rod to be determined, allowing for one hour thermal soak after rod motion. ITS SR 3.1.4.1 requires the verification of individual rod position within alignment limits and is modified by a Note that states the SR is not required to be performed until one hour after associated rod motion. This changes the CTS by not explicitly specifying the one hour is for thermal soak after rod motion.
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| The purpose of the SR is to verify the position of each rod periodically to detect a rod that has deviated from its expected position beyond the required alignment limits. The modification of the SR to not be performed for one hour, is to account for temperature affects after rod motion that could affect the accuracy of the rod position indication.
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| Moving the reason why one hour is allowed after rod motion will not affect the performance of the SR. The SR will still be performed in accordance with the Surveillance Frequency Control Program. Additionally, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.
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| Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| 5/31/22, 12:05 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 335 NRC Question CCH004 Number Select NRC Question Closure Application Attachment 1
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| Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Statement Closure of item 1 is based on the below remarks by the STSB reviewer and a conscious choice by STSB to not forward fit the correction of an error in an industry markup of a Bases discussion in Rev. 3.0 of NUREG-1431, Standard Technical Specifications Westinghouse Plants, for SR 3.1.4.1, that was provided with TSTF-425 Rev. 3, in 2009, and which was incorporated in Rev. 4.0 of NJREG-1431 in 2012.
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| Regarding your response to item 1, to make no change to your proposed Bases for ITS SR 3.1.4.1, as suggested by staff.
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| The licensee is requested to insert a passage equivalent to part or all of the following passage at the beginning of the Bases discussion for ITS SR 3.1.4.1:
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| "This SR periodically verifies that the position of each individual rod is within alignment limits. Recording rod position data at regular intervals provides a history that allows the operator to detect a rod that is beginning to deviate from its expected position."
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| This technical addition is requested in order to comply with the purpose of the Bases as described in 10 CFR 50.36to provide the reason for the specification. The staff does not agree that the bracketed paragraph in the STS SR 3.1.4.1 Bases only justifies the 12-hour value of the surveillance frequency; it also describes the surveillance and the reason for performing it on a regular interval.
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| This compliance deficiency stems from an apparent ambiguity in the markup of this passage in NUREG-1431, Rev. 3.0 (issued 03/31/2004), the Westinghouse STS Bases, by TSTF-425, Revision 3 (proposed March 18, 2009, approved June 23, 2009; ADAMS Package Accession No. ML090850642), which was incorporated in STS Revision 4. The licensee will agree that the markups of the Bases for the equivalent surveillance requirements (also labeled SR 3.1.4.1) in the BWOG-STS (NUREG-1430) and the CE-STS (NUREG-1432) retain language in the affected paragraph that conforms to the regulatory requirement to provide the reason for the specification. Therefore, including the above suggested passage or its equivalent would not be inconsistent with the intent of TSTF-425 and the STS.
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| Staff recognizes the low safety significance of this compliance deficiency in the proposed Bases for SR 3.1.4.1 in ITS Subsection B 3.1.4, and does not need it to be resolved to approve the ITS Bases. The licensee may disposition it after ITS implementation in accordance with the TS Bases Control Program.
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| Closure of item 2 is based on the adequacy of new Bases DOC LA2 for Subsection B 3.1.4 which moved detail from CTS 4.1.3.1.1 to Bases for ITS SR 3.1.4.1 Note 1. CTS 4.1.3.1.1 requires, in part, the position of each rod to be determined, allowing for one hour thermal soak after rod motion.
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| Question 4/25/2022 Closure https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=335 1/2
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| 5/31/22, 12:05 PM Turkey Point ITS Conversion Database Date Notification Christina Long William Maher Added By Craig Harbuck Date 4/25/2022 3:15 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=335 2/2
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| 4/13/22, 4:54 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 294 NRC Question CCH005 Number Category Editorial ITS 3.2 Section ITS 3.2.1 Number DOC A-1 Number JFD Number JFD Bases Number Page 17, 18 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.2.1 - pages 17 and 18 of 130 - ITS 3.2.1, Heat Flux Hot Channel Factor, FQ(Z)
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| Question
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| : 1. In Insert 2 of the markup of STS 3.2.1, the licensee is requested to insert "setpoints" after "trip" in ITS 3.2.1 Required Action B.2, for consistent phrasing.
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| : 2. In Insert 2 of the markup of STS 3.2.1, the licensee is requested to insert "setpoints" after "trip" in ITS 3.2.1 Required Action C.3, for consistent phrasing.
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| : 3. Global issue: The placement of nested logical connectors in ACTIONS tables in STS markup inserts are not always consistent with the guidance in the ITS writer's guide. The licensee is requested to adjust the smooth version of the ITS so that placement of logical connectors conforms to ITS writer's guide. An example is Actions B and C of ITS 3.2.1 in Insert 2 of the markup of STS 3.2.1.
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| Attach File 1
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| Attach File 2
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| Issue Date 4/13/2022 Added By Craig Harbuck Date Modified Modified By Date 4/13/2022 2:18 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=294 1/1
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| 8/12/22, 10:11 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 259 NRC Question CCH005 Number Select Licensee Response Application Attachment Attachment 1 - CCH005 LAR Markup.pdf (671KB) 1 Attachment 2
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| Response The term "setpoints" will be inserted after "trip" in ITS 3.2.1, Required Action B.2, consistent with ITS Statement 3.2.1, Required Actions A.2, A.3, and B.3 (see attached).
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| ITS 3.2.1 ACTION C, including Required Action C.3, as proposed in Revision 0 of the FPL ITS Conversion license amendment request (LAR), has been eliminated in Revision 1 of the ITS Conversion LAR. Therefore, Item 2 is no longer applicable. Revision 1 of the FPL ITS Conversion LAR corrected the alignment of the logical connectors in Insert 2 of the markup of STS 3.2.1 to be consistent with the ITS Writers Guide and the examples of nesting shown in ITS Section 1.2, Logical Connectors. Please refer to Enclosure 2, Volume 7, ITS 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))," Revision 1, of the ITS Conversion LAR (ADAMS Accession No. ML22089A205).
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| In conjunction with updating the ITS markup file, reference to CTS Discussion of Changes (DOCs) were added in the left column of ITS Insert page 3.2.1-1a in accordance with the guidance provided by the NRC entitled, "Expectations for Licensees Responses to Improved Technical Specification (ITS) Conversion License Amendment Request (LAR) and Requests for Additional Information (RAIs)" (NRC ADAMS Accession No. ML22054A166). In this respect, reference to DOCs A06 and LA02 were added to Insert 1.
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| | |
| ==Attachment:==
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| : 1. CCH005 LAR Markups
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| | |
| ===Response===
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| 4/18/2022 10:20 AM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/18/2022 9:19 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=259 1/1
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| ITS 3.2.1 CTS INSERT 1 3 AND 4.2.2.1 With predicted FQ (FQP) > FQ limit (FQL) and THERMAL POWER > predicted DOC LA02 threshold power (PT) calculated as specified in the COLR, THERMAL POWER shall be less than the following limit calculated as specified in the COLR:
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| 4.2.2.3.b.1 a. Base load power limit (PBL) during base load operation, and 4.2.2.4.a b. Radial burndown power limit (PRB) during radial burndown conditions.
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| 4.2.2.4.d DOC A06 INSERT 2 (page 1 of 2) 3 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME 4.2.2.2.a.1)
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| B. ------------NOTE------------ B.1 Reduce THERMAL 15 minutes Required Action B.4 POWER 1% RTP for shall be completed each 1% Fj(Z) exceeds whenever this Condition limit.
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| is entered.
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| --------------------------------- AND 4.2.2.2.a.1) FQ(Z) not within limit B.2 Reduce Power Range 72 hours DOC M02 when determined per Neutron Flux - High trip setpoints SR 3.2.1.2 and Fj(Z) 1% RTP for each exceeds limit by 4%. 1% Fj(Z) exceeds limit.
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| AND DOC M02 B.3 Reduce Overpower T trip 72 hours setpoints 1% RTP for each 1% Fj(Z) exceeds limit.
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| AND DOC M02 B.4 Perform SR 3.2.1.2. Prior to increasing THERMAL POWER above the limit of Required Action B.1 Insert Page 3.2.11a
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| 6/1/22, 10:43 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 619 NRC Question CCH005 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/1/2022 Date Notification Gregg Ellis Christina Long William Maher Caroline Tilton Added By Craig Harbuck Date Added 6/1/2022 9:42 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=619 1/1
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| 4/13/22, 4:54 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 298 NRC Question CCH006 Number Category Technical ITS 3.2 Section ITS 3.2.1 Number DOC Number JFD Number JFD Bases 1
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| Number Page 5, 28 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.2.1 - pages 5 and 28 of 130 - ITS 3.2.1, Heat Flux Hot Channel Factor, FQ(Z)
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| Question ITS SR 3.2.1.1 states:
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| Verify FQC (Z) is within limit. l Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND In accordance with the Surveillance Frequency Control Program [31 EFPD?]
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| The part of CTS SR 4.2.2.1 corresponding to ITS SR 3.2.1.1 states:
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| If [FQ]P, is less than [FQ]L or P is less than PT, FQ(Z) shall be evaluated to determine if FQ(Z) is within its limit as follows:
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| : 1. Prior to exceeding 75% of RATED THERMAL POWER,** after refueling,
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| : 2. In accordance with the Surveillance Frequency Control Program.
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| ** During power escalation at the beginning of each cycle, power level may be increased until a power level or extended operation has been achieved and power distribution map obtained.
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| The CTS Footnote ** and the conditional applicability clause (mistakenly shown as being deleted in the CTS 4.2.2.1 markup) is replaced by Surveillance Requirements table Notes 2 and 1, respectively, (STS 3.2.1B markup Insert 3, which is addressed by JFD 3.2.1-2, and which states:
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| -----------------------------------------------------NOTES-----------------------------------------------------------
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| : 1. If [FQ]P [FQ]L or THERMAL POWER PT, FQ(Z) shall be evaluated by SR 3.2.1.1.
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| If [FQ]P > [FQ]L and THERMAL POWER > PT, FQ(Z) shall be evaluated by SR 3.2.1.2.
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| : 2. During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.
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| ITS SR 3.2.1.2 states (STS 3.2.1 markup insert 4, JFD 3.2.1-2):
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| Verify FQ(Z) is within limits using MIDS, Base Load, or Radial Burndown in accordance with the COLR. l In accordance with the Surveillance Frequency Control Program The part of CTS SR 4.2.2.1 corresponding to ITS SR 3.2.1.2 states:
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| 4.2.2.1 If [FQ]P as predicted by approved physics calculations is greater than [FQ]L and P is greater than PT* as defined in 4.2.2.2, FQ(Z) shall be evaluated by [movable incore detector system] MIDS (Specification 4.2.2.2), BASE LOAD (Specification 4.2.2.3) or RADIAL BURNDOWN (Specification 4.2.2.4) to determine if FQ is within its limit [FQ]P = Predicted FQ).
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| https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=298 1/2
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| 4/13/22, 4:54 PM Turkey Point ITS Conversion Database (Issue 1) The CTS conditional applicability clause is replaced by Surveillance Requirements table Note 1, as shown above. The licensee is requested to mark the omission of the CTS 4.2.2.1 phrase as predicted by approved physics calculations as an LA-type of change.
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| (Issue 2) In the markup at the end of the first paragraph of the SRs section of the Bases for STS 3.2.1, the licensee is requested to clarify that SR 3.2.1.1 also has a periodic Frequency of in accordance with the SFCP.
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| (Issue 3) In the markup of the second sentence of the first paragraph of the Bases for STS SR 3.2.1.1, the licensee is requested to correct the sentence so its meaning is clear. As shown in the markup, with the changes incorporated the sentence would state:
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| Specifically, FQM(Z) is the measured value of FQ(Z) obtained from incore flux map results is then compared to its specified limits.
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| In addition, the markup of this sentence removes a phrase with an equation defining how FQC(Z) is calculated from FQM(Z).
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| Apparently, FQC(Z) is not defined for PTN 3&4, because in the STS 3.2.1 Bases markup, it is always replaced by FQ(Z). The licensee is requested to explain the relationship between FQ(Z) and FQM(Z).
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| (Issue 4) In the markup of the LCO section of the Bases for STS 3.2.1, Insert 1 (PDF page 28) replaces the STS description of the Heat Flux Hot Channel Factor, FQ(Z), limits. STS 3.2.1 Bases markup Insert 1 appears to replicate existing information in CTS LCO 3.2.2 (PDF page 5). These descriptive details in CTS LCO 3.2.2 are moved to the ITS 3.2.1 Bases verbatim as addressed by DOC 3.2.1-LA01.
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| The staff observes that the symbol / presentation of each parameter used in Bases discussions and Specifications related to FQ(Z) are inconsistent. In the ITS, each parameter related to Core Operating Limits should be stated using a standard symbol with standard formatting of superscripts and subscripts and use of brackets and parenthesis; also, the same symbol for multiplication, e.g., x should always be used. The CTS are not consistent. The licensee is requested to explain which symbols are used for each parameter, and consider using the same symbol for each parameter in the LCO section of the Bases for ITS 3.2.1, as well as throughout the ITS Specifications and Bases, and also in the COLR.
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| Attach File 1
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| Attach File 2
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| Issue Date 4/13/2022 Added By Craig Harbuck Date Modified Modified By Date 4/13/2022 2:49 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=298 2/2
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| 8/12/22, 10:11 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 343 NRC Question CCH006 Number Select Licensee Response Application Attachment Attachment 1 - CCH006 LAR Markup.pdf (3MB) 1 Attachment 2
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| Response Issue 1 -
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| Statement This was identified by FPL during development of Revision 1 to the LAR. Revision 1 of the ITS Conversion license amendment request (LAR) has removed the phrase "as predicted by approved physics calculations,"
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| from the CTS and justification has been provided in ITS 3.2.1 DOC LA01. DOC LA01 proposes to change the CTS by relocating this detail to the ITS Bases.
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| Specifically, the phrase regarding FQ P predicted by approved physics calculations is shown in Insert 2 of ITS 3.2.1 Bases markup. The changes provided in Revision 1 of the ITS Conversion LAR address this RAI.
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| Please refer to Enclosure 2, Volume 7, ITS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z))," Revision 1, of the ITS Conversion LAR.
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| Issue 2 -
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| FPL will add "periodic" to the Bases of SR 3.2.1.1 in the statement that the surveillance frequency is controlled under the Surveillance Frequency Control Program as follows (change shown in italics).
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| "The periodic Surveillance Frequency is controlled under the Surveillance Frequency Control Program."
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| See the attachment markup.
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| Issue 3 -
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| To clarify the statement in the second sentence of the first paragraph of the ITS 3.2.1 Bases markup for SR 3.2.1.1, FPL proposes to consolidate and revise the first and second sentences to state as follows:
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| Verification that FQ(Z) is within its specified limits involves increasing the value of FQ M(Z) obtained from incore flux maps to allow for manufacturing tolerance and measurement uncertainties, which is then compared to its specified limits.
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| In addition, FPL proposes to revise Insert 1 to the ITS 3.2.1 Bases markup to explain the relationship between FQ(Z) and FQ M(Z). The relationship between FQ(Z) and FQ M(Z) is as follows:
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| FQ(Z) = FQM(Z) x (UNC) where: FQM(Z) is obtained from incore flux map UNC is the combined allowance for manufacturing tolerances (1.03) and measurement uncertainties (1.05).
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| UNC = 1.03 x 1.05 = 1.0815 FQ(Z) is the resulting value, which is compared to the limit to confirm that FQ(Z) <FQL(Z).
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| See the attachment markup.
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| Issue 4 -
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| The symbols used for each parameter is explained in the ITS 3.2.1 Bases to the extent practical consistent with CTS 3.2.2 and the associated CTS Bases. Additionally, FPL will consider consistent usage of the same symbol for each parameter in the LCO section of the Bases for ITS 3.2.1, as well as throughout the ITS Specifications and Bases, and also in the COLR, to the extent practical.
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| | |
| ==Attachment:==
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| : 1. CCH006 LAR Markups
| |
| | |
| ===Response===
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| 4/30/2022 1:35 PM Date/Time https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=343 1/2
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| 8/12/22, 10:11 AM Turkey Point ITS Conversion Database Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long William Maher Caroline Tilton Added By Christina Long Date 4/30/2022 12:36 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=343 2/2
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| ITS 3.2.1 CTS 1
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| INSERT 1 LCO 3.2.2 F LQ (Z) shall be limited by the following relationships:
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| LX
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| [FQ ]
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| FM Q (Z) [K(Z)] for P > 0.5 P
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| L
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| [FQ ] X FM Q (Z) [K(Z)] for P 0.5
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| | |
| ===0.5 where===
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| [FQ]L = FQ limit at RTP as specified in the COLR THERMAL POWER P=
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| RTP
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| [FQ]M = measured value, and K(Z) for a given core height, is specified in the K(Z) curve, defined in the COLR.
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| The relationship between FQ(Z) and FQM(Z) is as follows:
| |
| FQ(Z) = FQM(Z) x (UNC) where: FQM(Z) is obtained from incore flux map UNC is the combined allowance for manufacturing tolerances (1.03) and measurement uncertainties (1.05).
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| UNC = 1.03 x 1.05 = 1.0815 FQ(Z) is the resulting value which is compared to the limit to confirm that FQ(Z) <
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| L FQ (Z).
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| Insert B 3.2.1-2
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| FQ(Z) (RAOC-W(Z) Methodology ) 1 B 3.2.1B BASES SURV EILLANCE REQUIREMENTS (continued)
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| SR 3.2.1.1 the value of obtained from Verification that FQC ( Z) is within its specif ied limits involv es increasing incore flux maps FQM ( Z) to allow for manufacturing tolerance and measurement uncertainties in order to ob tain FQ ( Z) . Specifically , FQM ( Z) is the measured C
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| , which value of FQ(Z) ob tained from incore flux map results and FQ ( Z) = FQ ( Z)
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| C M
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| [1.0815 ] (Ref . 4) . FQ ( Z) is then compared to its specified limits.
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| C The limit with which FQC ( Z) is compared varies inv ersely with pow er ab ov e 50% RTP and directly with a function called K(Z) prov ided in the COLR.
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| 2 This SR, which uses the Performing this Surveillance in MODE 1 prior to exceeding 75% RTP normal method, is modified by a Note stating that the ensures that the FQC ( Z) limit is met when RTP is achiev ed, because SR is not required to be peak ing factors generally decrease as pow er lev el is increased.
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| performed if FQP exceeds FQL and THERMAL POWER is > PT. When FQP ex ceeds If THERMAL POWER has been increased by 10 % RTP since the last determination of FQ ( Z) , another ev aluation of this factor is required FQL and THERMAL POWER C is > PT, FQ(Z) is calculated per SR 3.2.1.2 using an [12] hours af ter achiev ing equilibrium conditions at this higher pow er lev el augmented calculational (to ensure that FQ ( Z) values are being reduced sufficiently with pow er C
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| method or calculational methods for base load or increase to stay within the LCO limits).
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| radial burndow n, as applicab le, in accordance with the COLR. [ The Frequency of 31 EFPD is adequate to monitor the change of pow er distribution with core burnup because such changes are slow and well 4 controlled when the plant is operated in accordance with the Technical Specifications (TS).
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| periodic OR The Surveillance Frequency is controlled under the Surveillance 1 Frequency Control Program.
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| -----------------------------------REV IEW ER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given ab ov e, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| Westinghouse STS B 3.2.1B-8 Rev. 5.0 Rev ision XXX 1 Turkey Point Unit 3 and Unit 4
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| 6/1/22, 3:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 647 NRC Question CCH006 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/1/2022 Date Notification Gregg Ellis Christina Long William Maher Caroline Tilton Added By Craig Harbuck Date Added 6/1/2022 1:25 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=647 1/1
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| 5/6/22, 3:12 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 319 NRC Question CCH007 Number Category Technical ITS 3.4 Section ITS 3.4.12 Number DOC LA-3 Number JFD Number JFD Bases Number Page 247,250,260 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.4.12 - page 250 of 456 - ITS 3.4.12, Overpressure Mitigating Systems, SR 3.4.12.4 Question (Perform a COT on each required PORV, excluding actuation. l In accordance with the SFCP) retains CTS SR 4.4.9.3.1.a (Each PORV shall be demonstrated OPERABLE by:
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| : a. Performance of a CHANNEL OPERATIONAL TEST* on the PORV actuation channel, but excluding valve operation, in accordance with the Surveillance Frequency Control Program thereafter when the PORV is required OPERABLE.
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| * Not required to be met until 12 hours after decreasing RCS cold leg temperature to 275°F.), but the ITS conversion LAR proposes to move the indicated Frequency to the SFCP, as described in DOC 3.4.12 - LA03:
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| (Type 4 - - Removal of TS requirement to the Surveillance Frequency Control Program) CTS 4.4.9.3.1.a states "within 31 days prior to entering a condition in which the PORV is required OPERABLE." ITS SR 3.4.12.4 does not state this.
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| This changes the CTS by not including "within 31 days prior to entering a condition in which the PORV is required OPERABLE" and placing it in the Surveillance Frequency Control Program (SFCP).
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| This event-based Frequency is not allowed by TSTF-425 to be in the SFCP because it is not a periodic Frequency. Corresponding STS SR 3.4.12.8 (Perform a COT on each required PORV, excluding actuation. l [31 days OR In accordance with the SFCP]) includes an equivalent Frequency even if the 31 day Frequency is moved to the SFCP, provided it is not relaxed. (A SR must be met within its specified Frequency before entering the associated LCOs Applicability; the proposed Applicability of ITS 3.4.12 includes MODE 4 when any RCS cold leg temperature is 275°F.) If the intent of moving this Frequency to the SFCP is to retain the within 31 days prior to requirement, even if the regular interval is relaxed, the licensee is requested to retain this Frequency in the Surveillance Requirement. Otherwise, revise the DOC 3.4.12 - LA03 to justify also relaxing this Frequency so it remains consistent with the regular Frequency should the regular Frequency be changed under the SFCP in the future.
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| https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=319 1/2
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| 5/6/22, 3:12 PM Turkey Point ITS Conversion Database Attach File 1
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| Attach File 2
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| Issue Date 5/6/2022 Added By Ravinder Grover Date Modified Modified By Date 5/6/2022 2:10 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=319 2/2
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| 8/12/22, 10:12 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 403 NRC Question CCH007 Number Select Licensee Response Application Attachment Attachment 1 - CCH007 LAR Markups (002).pdf (852KB) 1 Attachment 2
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| Response The CTS 4.4.9.3.1.a wording, within 31 days prior to entering a condition in which the PORV is required Statement OPERABLE, is not considered an event based frequency excluded from relocation to the Surveillance Frequency Control Program (SFCP); rather, this frequency establishes the periodic performance interval prior to entering the condition in which the PORV is required to be OPERABLE and is duplicative of CTS 4.0.4 (ITS SR 3.0.4). ITS SR 3.0.4 states, in part, that entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency. The frequency specified in the SFCP for CTS 4.4.9.3.1.a (ITS SR 3.4.12.4) is 31 days.
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| ITS SR 3.0.4 will continue to require the Surveillance to be performed within its frequency (i.e., 31 days) prior to entering a condition in which the PORV is required OPERABLE, and deletion of the text is not a relaxation of the current requirement. Any future change to the frequency of 31 days, which includes the frequency of 31 days prior to entering a condition in which the PORV is required OPERABLE, will be evaluated using the risk-informed methodology of NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies per the guidance of the SFCP specified in ITS Section 5.5 (CTS 6.8.4).
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| PTN adopted a SFCP on July 16, 2015, in License Amendments 263 and 258, for Unit 3 and Unit 4 respectively (NRC ADAMS Accession No. ML15166A320). Therefore, the process for any future relaxation of the Surveillance Frequency specified in the SFCP for ITS SR 3.4.12.4, which includes the initial Surveillance interval prior to entering the condition a PORV is required to be OPERABLE, has been previously approved by the NRC and no further justification is necessary.
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| ITS 3.4.12 DOC LA03 will be removed and replaced with DOC A05, as follows.
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| A05 CTS 4.4.9.3.1.a states, in part, that each PORV shall be demonstrated OPERABLE by performance of an ANALOG CHANNEL OPERATIONAL TEST on the PORV actuation channel but excluding valve operation, within 31 days prior to entering a condition in which the PORV is required OPERABLE and in accordance with the Surveillance Frequency Control Program thereafter when the PORV is required OPERABLE. The statement within 31 days prior to entering a condition in which the PORV is required OPERABLE, is not included in ITS SR 3.4.12.4. This changes the CTS by removing a Frequency which is duplicative of CTS 4.0.4 (ITS SR 3.0.4). ITS SR 3.0.4 states, in part, that entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCOs Surveillances have been met within their specified Frequency. The Frequency specified in the Surveillance Frequency Control Program for CTS 4.4.9.3.1.a (ITS SR 3.4.12.4) is 31 days. Therefore, ITS SR 3.0.4 will continue to require the Surveillance to be performed within the specified frequency (i.e., 31 days) prior to entering a condition in which the PORV is required OPERABLE.
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| This change is designated as an administrative change and is acceptable because it does not result in technical changes to the CTS.
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| Additionally, FPL identified an error in the ISTS markup of ITS SR 3.4.14.1 Frequency in LAR Enclosure 2, Volume 9, Attachment 14, ITS 3.4.14 - RCS Pressure Isolation Valve (PIV) Leakage. The logical connector OR will be removed between the first and second Frequency such that the Frequency of ITS SR 3.4.14.1 will read as follows:
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| In accordance with the INSERVICE TESTING PROGRAM AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND Within 24 hours following valve actuation due to automatic or manual action or flow through the valve See attached LAR markups for applicable changes.
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| ==Attachment:==
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| https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=403 1/2
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| 8/12/22, 10:12 AM Turkey Point ITS Conversion Database
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| : 1. CCH007 LAR Markups
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| ===Response===
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| 5/16/2022 3:55 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Ravinder Grover Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 5/16/2022 2:55 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=403 2/2
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| A01 ITS ITS 3.4.12 REACTOR COOLANT SYSTEM OVERPRESSURE MITIGATING SYSTEMS SURVEILLANCE REQUIREMENTS 4.4.9.3.1 Each PORV shall be demonstrated OPERABLE by:
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| SR 3.4.12.4 a. Performance of an ANALOG CHANNEL OPERATIONAL TEST* on the PORV actuation channel, M01 SR 3.4.12.4 but excluding valve operation, within 31 days prior to entering a condition in which the PORV is Note required OPERABLE and in accordance with the Surveillance Frequency Control Program LA03 thereafter when the PORV is required OPERABLE. A05 SR 3.4.12.5 b. Performance of a CHANNEL CALIBRATION on the PORV actuation channel in accordance with the Surveillance Frequency Control Program; and SR 3.4.12.3 c. Verifying the PORV block valve is open in accordance with the Surveillance Frequency Control Program when the PORV is being used for overpressure protection.
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| : d. While the PORVs are required to be OPERABLE, the backup nitrogen supply shall be verified LA01 OPERABLE in accordance with the Surveillance Frequency Control Program.*
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| SR 3.4.12.2 4.4.9.3.2 The 2.20 square inch vent shall be verified to be open in accordance with the Surveillance Frequency Control Program** when the vent(s) is being used for overpressure protection.
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| SR 3.4.12.1 4.4.9.3.3 Verify the high pressure injection flow path to the RCS is isolated in accordance with the Surveillance LA02 Frequency Control Program by closed valves with power removed or by locked closed manual valves.
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| pumps are not capable of injecting into the RCS A03 SR 3.4.12.4 Note
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| * Not required to be met until 12 hours after decreasing RCS cold leg temperature to 275 F.
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| A04
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| ** Except when the vent pathway is provided with a valve which is locked, sealed, or otherwise secured in the open position, then verify these valves open in accordance with the Surveillance Frequency Control Program.
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| 3/4.4.10 DELETED TURKEY POINT - UNITS 3 & 4 3/4 4-28 AMENDMENT NOS. 263 AND 258
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| DISCUSSION OF CHANGES ITS 3.4.12, OVERPRESSURE MITIGATING SYSTEMS only stating once that the surveillance is performed at a Frequency "In accordance with the Surveillance Frequency Control Program."
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| The change is acceptable because the frequency that the surveillance will be perform at has not changed, duplication has been eliminated. This change is designated as administrative because it does not result in technical changes to the CTS.
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| Add DOC A05 (See response to CCH007)
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| MORE RESTRICTIVE CHANGES M01 CTS 4.4.9.3.1.a requires, in part, each PORV be demonstrated OPERABLE by the performance of an ANALOG CHANNEL OPERATIONAL TEST. ITS SR 3.4.12.6 requires performance of a CHANNEL OPERATIONAL TEST (COT) to demonstrate Power Operated Relief Valve (PORV) OPERABILITY. This changes the CTS by changing the ANALOG CHANNEL OPERATIONAL TEST requirements to a COT.
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| CTS defines an ANALOG CHANNEL OPERATIONAL TEST as the injection of a simulated signal into the sensor as close to the sensor as practicable to verify OPERABILITY. ITS defines a COT as the injection of an actual or simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY.
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| The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. This changes the CTS by requiring adjustments of the setpoints so that each PORV Channel is within the necessary range and accuracy. This change is designated as more restrictive because it imposes additional requirements on testing.
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| M02 CTS 3.4.9.3, ACTION a. states that with the high pressure safety injection flow paths to the RCS unisolated, restore isolation of these flow paths within 4 hours.
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| ITS 3.4.12 ACTION A. states that with one or more high pressure safety injection flow paths to the RCS not isolated to isolate all high pressure safety injection flow paths to the RCS within 4 hours. In addition, ITS 3.4.12 ACTION D states, in part, that if the Required Action and associated Completion Time of Condition A is not met to depressurize the RCS and establish RCS vent of 2.20 square inches within 24 hours. This changes the CTS by providing a Required Action to establish an RCS vent instead of entering ITS 3.0.3 and proceeding to shut down the unit until in MODE 5 without requiring an RCS vent.
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| The purpose of CTS 3.4.9.3, ACTION a. is to provide remedial measures at low RCS temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits caused by a mass input transient. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or Turkey Point Unit 3 and Unit 4 Page 2 of 4
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| DISCUSSION OF CHANGES ITS 3.4.12, OVERPRESSURE MITIGATING SYSTEMS LA03 (Type 4 - - Removal of TS requirement to the Surveillance Frequency Control Program) CTS 4.4.9.3.1.a states "within 31 days prior to entering a condition in which the PORV is required OPERABLE." ITS SR 3.4.12.4 does not state this. This changes the CTS by not including "within 31 days prior to entering a condition in which the PORV is required OPERABLE" and placing it in the Surveillance Frequency Control Program (SFCP).
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| The removal of this PORV time from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health and safety.
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| The ITS retains the requirement to "within 31 days prior to entering a condition in which the PORV is required OPERABLE" in the SFCP. Also, this change is acceptable because these types of procedural details will be adequately controlled in the SFCP. This change is designated as a less restrictive removal of detail change because a "within 31 days prior to entering a condition in which the PORV is required OPERABLE" is being removed from the Technical Specifications.
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| REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) Actions b and c of CTS 3.4.9.3 provide Completion Times to restore an inoperable PORV and, if not restored with the stated Completion Time, the RCS must be depressurized and vented through at least a 2.20 square inch vent within the next 8 hours. Action c, however, permits 24 hours to depressurize the RCS and vent through at least a 2.20 square inch vent when both PORVs are inoperable. The CTS is changed to permit 24 hours to depressurize the RCS and vent through at least a 2.20 square inch vent in any of the aforementioned cases. This changes the CTS by increasing the Completion Time to depressurize and vent the RCS from 8 hours to 24 hours when a PORV is not restored to OPERABLE status within its stated Completion Time.
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| The purpose of CTS 3.4.9.3 is to control RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering that 24 hours is currently permitted to establish an adequate vent path when both PORVs are inoperable and the low probability of an overpressurization event occurring during this period. This includes a reasonable time for a controlled depressurization (which may also require a controlled cooldown) of the RCS prior to establish the necessary vent path. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 4 of 5
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| RCS PIV Leakage CTS 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.4.6.2.2 SR 3.4.14.1 ------------------------------NOTES-----------------------------
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| : 1. Not required to be performed in MODES 3 and 4.
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| : 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
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| : 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
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| Verify leakage from each RCS PIV is equivalent to In accordance 0.5 gpm per nominal inch of valve size up to a with the 3 5.0 maximum of 5 gpm at an RCS pressure INSERVICE
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| [2215] psig and [2255] psig. TESTING PROGRAM, and 2
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| [ [18] months OR INSERT 2 3 In accordance with the Surveillance Frequency Control Program ]
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| AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.4.14-3 Rev. 5.0 1
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| 5/16/22, 5:34 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 407 NRC Question CCH007 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/16/2022 Date Notification Gregg Ellis Ravinder Grover Craig Harbuck Christina Long William Maher Caroline Tilton Added By Craig Harbuck Date Added 5/16/2022 4:34 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=407 1/1
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| 5/25/22, 1:52 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 699 NRC Question CCH008 Number Category Technical ITS 3.1 Section ITS 3.1.7 Number DOC A-1 Number JFD 1
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| Number JFD Bases Number Page 163 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC There is one demand position indicator (group step counter) per rod group, with two rod groups for each of Question four control banks and each of two shutdown banks. ITS 3.1.7 Condition A says one RPI per bank instead of one RPI per group as does STS 3.1.7 Condition A; The licensee is requested to explain in JFD 3.1.7-1 why this difference is retained, since it makes ITS less flexible than STS.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/25/2022 Added By Craig Harbuck Date Modified Modified By Date 5/25/2022 12:44 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=699 1/1
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| 8/3/22, 5:50 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1463 NRC Question CCH008 Number Select Licensee Response Application Attachment Attachment 1 - CCH008 LAR Markups(3) EA.pdf (1MB) 1 Attachment 2
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| Response FPL will adopt the flexibility by changing "bank" to "group" consistent with ISTS. The ITS 3.7.1 CTS Statement markup will be revised and Discussion of Change (DOC) L06 will be added to justify the change. ITS 3.7.1 markup will be changed to be consistent with the ISTS, thus no Justification for Deviation (JFD) is required. Additionally, the ITS 3.7.1 CTS DOCs and Bases will be changed accordingly to change "bank" to "group". See Attachment 1 - CCH008 LAR Markups.
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| Attachment
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| : 1. CCH008 LAR Markups
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| ===Response===
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| 7/6/2022 1:05 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/6/2022 12:06 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1463 1/1
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| A01 ITS ITS 3.1.7 REACTIVITY CONTROL SYSTEMS ROD POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION FOR OPERATION (Continued)
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| (RPI)
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| LCO 3.1.7 3.1.3.2 The Analog Rod Position Indication System and the Demand Position Indication System shall be OPERABLE and capable of determining the respective actual and demanded shutdown and control rod positions as follows: .
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| : a. Analog rod position indicators, within one hour after rod motion (allowance for thermal soak);
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| All Shutdown Banks: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.
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| LA01 Control Bank A and B: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.
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| Control Banks C and D: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal range of 0-All Rods Out as defined in the Core Operating Limits Report.
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| : b. Group demand counters; +/- 2 steps.
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| Add proposed LCO 3.1.7 NOTE L03 Applicability APPLICABILITY: MODES 1 and 2.
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| ACTION:
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| Add proposed ACTIONS Note L01
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| : a. With a maximum of one analog rod position indicator per bank inoperable either:
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| group A02 in one or more banks
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| : 1. Determine the position of the non-indicating rod(s) indirectly by the movable incore detectors at least once per 8 hours and within one hour after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last determination of the rods position, or group L06 2** a). Determine the position of the non-indicating rod indirectly by the movable incore detectors within 8 hours and once every 31 Effective Full Power Days thereafter, and within 1 hour if rod control system parameters indicate unintended movement, or if L04 ACTION A the rod with an inoperable position indicator is moved greater than 12 steps, and 8 s b). Review the parameters of the rod control system for indications of unintended rod movement for the rod with an inoperable indicator within 8 hours and once per 8 hours thereafter, and c). Determine the position of the non-indicating rod indirectly by the movable incore detectors prior to increasing THERMAL POWER above 50% RATED THERMAL POWER and within 8 hours of reaching 100% RATED THERMAL POWER, or
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| : 3. Reduce THERMAL POWER to less than 75% of RATED THERMAL POWER within 8 hours.
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| Add proposed ACTION B L02 Add proposed ACTION C L05 TURKEY POINT - UNITS 3 & 4 3/4 1-19 AMENDMENT NOS. 260 AND 255 Page 1 of 4
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| DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS).
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 CTS 3.1.3.2 ACTION a states "With a maximum of one analog rod position indicator per bank inoperable either". ITS Limiting Condition for Operation (LCO) 3.1.7 CONDITION A states "One RPI per bank inoperable in one or more banks." This changes the CTS by including more banks.
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| The purpose of CTS 3.1.3.2 ACTION a and ITS LCO 3.1.7 CONDITION A is to state the inoperability of the Rod Position Indication (RPI) System. Rod cluster control assemblies (RCCAs), or rods, are moved out of the core (up or group withdrawn) or into the core (down or inserted) by their control rod drive mechanisms. The RCCAs are divided among control banks and shutdown banks. Each bank may be further subdivided into two banks to provide for precise reactivity control. The axial position of shutdown rods and control rods are determined by two separate and independent systems: the Demand Position Indication System (commonly called group step counters) and the RPI System.
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| With one RPI per bank inoperable, different types of banks may have one inoperable RPI per type of bank.
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| MORE RESTRICTIVE CHANGES M01 CTS 3.1.3.2 ACTION a does not contain an ACTION to follow if the provided ACTIONS cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour to initiate a shutdown and 7 hours to be in HOT STANDBY.
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| ITS 3.1.7 ACTION E requires the unit to be placed in MODE 3 with 6 hours if the Required Actions and associated Completion Time of ACTION A or D are not met. This changes the CTS by eliminating the one hour to initiate a shutdown and consequently allows one hour less for the unit to be in MODE 3.
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| This change is acceptable because it provides an appropriate compensatory measure for the described conditions. If any Required Action and associated Completion Time cannot be met, the unit must be placed in a MODE in which the LCO does not apply. The LCO is applicable in MODES 1 and 2. Requiring a shutdown to MODE 3 is appropriate in this condition. The one hour allowed by CTS 3.0.3 to prepare for a shutdown is not needed because the operators have had time to prepare for the shutdown while attempting to follow the Required Turkey Point Unit 3 and Unit 4 Page 1 of 6
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| DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.1.3.2 ACTION a covers the inoperability for a maximum of one analog rod position indicator per bank.
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| CTS 3.1.3.2 does not have an ACTION to cover the inoperability for more than one rod position indicator per bank. CTS 3.1.3.2 ACTION b covers the inoperability for a maximum of one demand position indicator per bank. CTS 3.1.3.2 Note ** states "Rod position monitoring by Actions a.2.a), a.2.b), and a.2.c) may only be applied to one inoperable rod position indicator per unit and group shall only be allowed until an entry into MODE 3." ITS 3.1.7 ACTIONS are modified by a Note that states "Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator." ITS 3.1.7 ACTION A covers inoperability for one rod position indicator per bank. ITS 3.1.7 ACTION B covers inoperability for more than one rod position indicator per bank.
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| ITS 3.1.7 ACTION D covers inoperability for one demand position indicator bank for one or more banks. This changes the CTS by allowing separate Condition entry for each inoperable rod position indicator and each demand position indicator.
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| The purpose of CTS 3.1.3.2 ACTION a is to provide compensatory actions for a maximum of one rod position indicator per bank. The purpose of CTS 3.1.3.2 ACTION b is to provide compensatory actions for one demand position indicator per bank. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. This change will allow separate Condition entry for each inoperable rod position indicator and each inoperable demand position indicator while the CTS does not. The ITS will allow each inoperable rod position indicator or each inoperable demand position indicator to be tracked separately. This change is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for inoperable position indication. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L02 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.7 ACTION requires that with a maximum of one analog rod position indicator per bank inoperable, groups restore the inoperable indicator or reduce THERMAL POWER within 8 hours.
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| CTS 3.1.3.7 has no ACTION for more than one analog rod position indicator per bank inoperable. ITS 3.1.7 ACTION B requires more than one rod position indicator in one or more banks inoperable to be restored to OPERABLE status such that a maximum of one rod position indicator per group is inoperable within 24 hours. This changes the CTS by allowing 24 hours to restore inoperable rod position indicators to OPERABLE status such that a maximum of one rod position indicator per group is inoperable.
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| Turkey Point Unit 3 and Unit 4 Page 4 of 6
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| DISCUSSION OF CHANGES group ITS 3.1.7, ROD POSITION INDICATION The purpose of ITS 3.1.7 is to keep the rod position indication system and demand position indication system OPERABLE. 24 hours is allowed to restore inoperable rod position indicators to OPERABLE status such that a maximum of one rod position indicator per bank is inoperable. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant system or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. The change is the addition of ITS 3.1.7 ACTION B. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| L03 (Category 7 - Relaxation Of Surveillance Frequency Change - NON-24 MONTH TYPE CHANGE) CTS LCO 3.1.3.2 a states "within one hour after rod motion."
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| ITS LCO 3.1.7 Note states "Individual RPIs are not required to be OPERABLE for 1 hour following movement of the associated rods." This changes the CTS by allowing OPERABILITY after 1 hour.
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| The purpose of CTS 3.1.3.2 is to require OPERABILITY within one hour after rod motion. ITS LCO 3.1.7 Note states RPIs are not required to be OPERABLE for 1 hour following rod movement. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Allowing OPERABILITY after 1 hour is additional time. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
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| L04 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.2 a states in part that within 1 hour is allowed if rod control system parameters indicate unintended movement. ITS LCO 3.1.7 ACTION A states in part that 8 hours is allowed for unintended movement or inoperable RPI. This changes the CTS by allowing 8 hours for Completion Time.
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| The purpose of ITS LCO 3.1.7 ACTION A is verification of rod position of the RPI System. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Allowing a completion time of 8 hours verses 1 hour is additional time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| L05 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.2 a states, in part, that with a maximum of one analog rod position indicator per bank inoperable, determining FIX FONT that the position of the non-indicating rod within 1 hour is allowed if rod control system parameters indicate unintended movement. CTS 3.1.3.2 does not have an ACTION C. ITS LCO 3.1.7 ACTION C states that 4 hours is allowed for "One or more RPI inoperable in one or more banks and associated rod has been groups Turkey Point Unit 3 and Unit 4 Page 5 of 6
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| DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION moved > 24 steps in one direction since the last determination of the rod's position." This changes the CTS by allowing 4 hours for Completion Time and one or more inoperable RPI. groups The purpose of ITS LCO 3.1.7 ACTION C is verification of rod position of one or more RPIs inoperable in one or more banks and the associated rod has been moved > 24 steps in one direction since the last determination of the rod's position. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Allowing a Completion Time of 4 hours is additional time for one or more inoperable RPI. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| L06 (Category 4 . Relaxation of Required Action) CTS 3.1.3.2 Action a states, "With a maximum of one analog rod position indicator per bank inoperable.." ITS 3.1.7 ACTION A states with a maximum of one analog rod position indicator per group inoperable in one or more groups The CTS is revised to incorporate the Improved Standard Technical Specifications (ISTS) allowance for one rod per group to be inoperable versus one rod per bank. This changes the CTS by allowing more inoperable rod position indicators at any given time. The change to add, in one or more groups, is discussed in Discussion of Change (DOC) A02.
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| The purpose of CTS 3.1.3.2 Action a is to provide an alternate means of determining rod positions when the individual rod position indicators are not operable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. In this case, the Required Actions ensure the position of the affected rods are verified on a more frequent basis by using moveable incore instrumentation. Considering the limited rod motion that typically occurs during normal operation, the more frequent interval for determining rod position has also been shown by operating experience to be adequate to track and maintain positive control of rod position. The actual rod position, not the indicating system, is the parameter of concern in the safety analyses and the Actions provide adequate compensatory measures for one inoperable rod position indicator per group. The proposed Required Action allows for more inoperable indicators than the CTS Action but remains consistent with safe plant operation, considering the successful operating experience with determining rod positions by the use of the alternate means specified.
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| The methods of determining rod position specified in the Actions have been shown to be accurate and reliable alternatives that may be safely used for additional rods with inoperable indicators. The proposed change results in Required Actions that continue to assure the position of the affected rods is verified at a frequency which ensures the safe operation of the plant. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 6 of 6
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| Rod Position Indication 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication 1
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| 3.1.3.2 LCO 3.1.7 The [Digital] Rod Position Indication [D]RPI System and the Demand Position Indication System shall be OPERABLE.
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| ------------------------------------- NOTE ---------------------------------------------------
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| DOC L03
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| [Individual RPIs are not required to be OPERABLE for 1 hour following 1 movement of the associated rods.]
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| Applicability APPLICABILITY: MODES 1 and 2.
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| ACTIONS
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| ------------------------------------------------------------NOTE-----------------------------------------------------------
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| DOC L01 Separate Condition entry is allowed for each inoperable [D]RPI and each demand position 1 indicator.
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| CONDITION REQUIRED ACTION COMPLETION TIME bank 1 3 ACTION a A. One [D]RPI per group A.1 Verify the position of the Once per 8 hours inoperable in one or rods with inoperable [D]RPI AND ACTION a.1 more groups. indirectly by using movable Within one hour after any motion banks incore detectors. of the inoperable rod which 3
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| exceeds 24 steps in one direction OR since the last determination of group the rods position A.2 Verify the position of the 8 hours 1 ACTION a.2.a) rods with inoperable [D]RPI indirectly by using the AND moveable incore detectors.
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| Once per 31 EFPD thereafter AND DOC L04 8 hours after discovery of each ACTION a.2.b) unintended rod movement AND Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-1 Rev. 5.0 3
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| Rod Position Indication 3.1.7 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME 8 hours after each ACTION a.2.a) movement of rod with inoperable [D]RPI 1
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| > 12 steps AND Prior to THERMAL POWER exceeding 50% RTP ACTION a.2.c)
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| AND 8 hours after reaching RTP OR ACTION a.3. A.3 Reduce THERMAL 8 hours 3
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| POWER to 50% RTP.
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| < 75 1
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| DOC L02 B. More than one [D]RPI B.1 Place the control rods Immediately per group inoperable in group under manual control.
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| 3 one or more groups. bank banks AND B.2 Restore inoperable [D]RPIs 24 hours 1 to OPERABLE status such that a maximum of one 1
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| [D]RPI per group is inoperable.
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| Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-2 Rev. 5.0 3
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| Rod Position Indication 3.1.7 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME DOC L05 C. One or more [D]RPI C.1 Verify the position of the [4] hours 1 inoperable in one or rods with inoperable more groups and [D]RPIs indirectly by using 3 1 bank associated rod has been movable incore detectors.
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| moved > 24 steps in one groups direction since the last OR determination of the rod's position. C.2 Reduce THERMAL 8 hours POWER to 50% RTP.
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| DOC L01 D. One or more demand D.1.1 Verify by administrative Once per 8 hours ACTION C position indicators per means all [D]RPIs for the 1 bank inoperable in one affected banks are or more banks. OPERABLE.
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| AND D.1.2 Verify the most withdrawn Once per 8 hours 2 3 rod and the least withdrawn rod of the affected banks are 12 steps apart.
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| OR D.2 Reduce THERMAL 8 hours 3
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| POWER to 50% RTP.
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| < 75 2
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| DOC M02 E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time not met.
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| Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-3 Rev. 5.0 3
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| Rod Position Indication B 3.1.7 BASES LCO LCO 3.1.7 specifies that one [D]RPI System and one Bank Demand 2 Position Indication System be OPERABLE for each control rod. For the 1 control rod position indicators to be OPERABLE requires meeting the SR 5 of the LCO and the following:
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| 2
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| : a. The [D]RPI System indicates within 12 steps of the group step counter demand position as required by LCO 3.1.4, "Rod Group Alignment Limits,"
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| 2
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| : b. For the [D]RPI System there are no failed coils, and Position 1 4
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| : c. The Bank Demand Indication System has been calibrated either in 2
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| the fully inserted position or to the [D]RPI System.
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| The 12 step agreement limit between the Bank Demand Position 1 Indication System and the [D]RPI System indicates that the Bank 2 Demand Position Indication System is adequately calibrated, and can be used for indication of the measurement of control rod bank position.
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| A deviation of less than the allowable limit, given in LCO 3.1.4, in position indication for a single control rod, ensures high confidence that the position uncertainty of the corresponding control rod group is within the assumed values used in the analysis (that specified control rod group insertion limits).
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| These requirements ensure that control rod position indication during power operation and PHYSICS TESTS is accurate, and that design assumptions are not challenged.
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| OPERABILITY of the position indicator channels ensures that inoperable, misaligned, or mispositioned control rods can be detected. Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.
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| ---------------------------------- Reviewer's Note ----------------------------------------
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| The bracketed LCO Note is only applicable to plants with an analog rod 6 position indication system.
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| [The LCO is modified by a Note stating that the RPI system is not 2
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| required to be met OPERABLE for 1 hour following movement of the associated rods. Control and shutdown rod temperature affects the accuracy of the RPI System. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows temperature to stabilize following rod movement in order to ensure the indicated position is accurate.]
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7-3 Rev. 5.0 1
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| Rod Position Indication B 3.1.7 BASES of APPLICABILITY The requirements on the [D]RPI and step counters are only applicable in 5 2 MODES 1 and 2 (consistent with LCO 3.1.4, LCO 3.1.5, and LCO 3.1.6),
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| because these are the only MODES in which power is generated, and the OPERABILITY and alignment of rods have the potential to affect the safety of the plant. In the shutdown MODES, the OPERABILITY of the shutdown and control banks has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the Reactor Coolant System.
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| ACTIONS The ACTIONS Table is modified by a Note indicating that a separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator. This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable position indicator.
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| group A.1 and A.2 bank When one [D]RPI channel per group in one or more groups fails, the 2 1 position of the rod may still be determined indirectly by use of the 5 movable incore detectors. The Required Action may also be satisfied by ensuring at least once per 8 hours that FQ satisfies LCO 3.2.1, F N H 3 satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Based on experience, normal power operation does not require excessive movement of banks. If a bank has been significantly moved, the Required Action of C.1 or C.2 below is required. Therefore, verification of RCCA position within the Completion Time of 8 hours is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small.
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| Required Action A.1 requires verification of the position of a rod with an inoperable [D]RPI once per 8 hours which may put excessive wear and 2 tear on the moveable incore detector system, Required Action A.2 provides an alternative. Required Action A.2 requires verification of rod position using the moveable incore detectors every 31 EFPD, which coincides with the normal use of the system to verify core power distribution.
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| INSERT 1 3 Required Action A.2 includes six distinct requirements for verification of the position of rods associated with an inoperable [D]RPI using the movable incore detectors:
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| 2
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| : a. Initial verification within 8 hours of the inoperability of the [D]RPI; Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7-4 Rev. 5.0 1
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| 3 INSERT 1 Required Action A.1 requires that if one or more rods have been significantly moved (more than 24 steps in one direction, since the position was last determined), Required Action A.1 is still appropriate, but actions must be initiated immediately to begin verifying that the rod is still properly positioned, relative to their group positions. In this Required Action, the Completion Time only begins on discovery that both:
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| group
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| : a. One rod position indication per bank is inoperable, and
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| : b. A rod with an inoperable position indicator has been moved more than 24 steps in one direction since the last determination of the rod's position.
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| If at any time during the existence of Condition A (one RPI per bank inoperable), a rod with an inoperable position indicator has been moved more than 24 steps in one direction since the last determination of the rod's position, this Completion Time begins to be tracked.
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| Insert Page B 3.1.7-4
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| Rod Position Indication B 3.1.7 BASES ACTIONS (continued)
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| : b. Re-verification once every 31 Effective Full Power Days (EFPD) thereafter;
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| : c. Verification within 8 hours if rod control system parameters indicate unintended rod movement. An unintended rod movement is defined as the release of the rod's stationary gripper when no action was demanded either manually or automatically from the rod control system, or a rod motion in a direction other than the direction demanded by the rod control system. Verifying that no unintended rod movement has occurred is performed by monitoring the rod control system stationary gripper coil current for indications of rod movement;
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| : d. Verification within 8 hours if the rod with an inoperable [D]RPI is 2 intentionally moved greater than 12 steps;
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| : e. Verification prior to exceeding 50% RTP if power is reduced below 50% RTP; and
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| : f. Verification within 8 hours of reaching 100% RTP if power is reduced to less than 100% RTP.
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| Should the rod with the inoperable [D]RPI be moved more than 12 steps, or if reactor power is changed, the position of the rod with the inoperable 2
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| [D]RPI must be verified.
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| A.3
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| < 75 Reduction of THERMAL POWER to 50% RTP puts the core into a 4 condition where rod position is not significantly affecting core peaking factors (Ref. 3).
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| < 75 The allowed Completion Time of 8 hours is reasonable, based on 4 operating experience, for reducing power to 50% RTP from full power conditions without challenging plant systems and allowing for rod position determination by Required Action A.1 above.
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| groups 2 group 1 B.1 and B.4 bank banks 2 1 When more than one [D]RPI per group in one or more groups fail, additional actions are necessary. Placing the Rod Control System in manual assures unplanned rod motion will not occur.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7-5 Rev. 5.0 1
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| 7/7/22, 2:01 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1487 NRC Question CCH008 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/7/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/7/2022 12:21 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1487 1/1
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| 5/25/22, 5:17 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 703 NRC Question CCH009 Number Category Technical ITS 3.1 Section ITS 3.1.7 Number DOC L-2 Number JFD Number JFD Bases 2
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| Number Page 164 175 175 178 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On pages 176 and 178 of 258 Question JFD 3.1.7-2 states: [STS] 3.1.7 ACTION A provides compensatory actions when one rod position indicator is inoperable. [ITS] 3.1.7 provides an additional Required Action that can be taken when one rod position indicator is inoperable. The new Required Action allows the use of an alternate means other than the movable incore detectors to monitor the position of a control or shutdown rod when the analog rod position indication system is inoperable.
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| Judging by the placement of the references to JFD 3.1.7-2 on the STS markup, the new Required Action is contained in STS 3.1.7 ACTION D (markup shown) and ACTION E:
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| D. One or more demand position indicators per bank inoperable in one or more banks. l D.1.1 Verify by administrative means all [ D] RPIs for the affected banks are OPERABLE. l Once per 8 hours AND D.1.2 Verify the most withdrawn rod and the least withdrawn rod of the affected banks are 12 steps apart. l Once per 8 hours OR D.2 Reduce THERMAL POWER to 50% 75% RTP.
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| E. Required Action and associated Completion time not met. l E.1 Be in MODE 3. l 6 hours According to the STS markup, ITS 3.1.7 ACTION D corresponds to CTS ACTION C, which is incorrect; it corresponds to CTS 3.1.3.2 ACTION b. as addressed by DOC 3.1.7A01 and as shown on the CTS 3.1.3.2 markup on page 164. The licensee is https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=703 1/2
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| 5/25/22, 5:17 PM Turkey Point ITS Conversion Database requested to clarify which DOC addresses the new allowance in ACTION D for the use of an alternate means other than the movable incore detectors to monitor the position of a control or shutdown rod when the analog rod position indication system is inoperable. Also, explain what the alternate means consist of. Also, explain how JFD 3.1.7-2 applies to ACTION D, which only applies to inoperable demand position indication, not to inoperable analog RPI.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/25/2022 Added By Craig Harbuck Date Modified Modified By Date 5/25/2022 4:05 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=703 2/2
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| 8/3/22, 5:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1622 NRC Question CCH009 Number Select Licensee Response Application Attachment Attachment 1 - CCH009 LAR Markups (4) EA.pdf (2MB) 1 Attachment 2
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| Response FPL will change the reference in the left-hand margin of Improved Technical Specification (ITS) 3.1.7 Statement ACTION D to reference Current Technical Specification (CTS) 3.1.3.2 Action b instead of ACTION C.
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| There is no alternate method of monitoring an inoperable Rod Position Indication (RPI) System in ITS 3.1.7 ACTION D as stated in Justification for Deviation (JFD) 2. ITS 3.1.7 ACTION D is for the condition when demand position indication is inoperable and not for an inoperable RPI System. FPL will delete JFD 2 because it is not applicable to any deviation from the Improved Standard Technical Specification (ISTS).
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| Reference to JFD 3 for ITS 3.1.7, Required Action D.1.2 is also deleted since there is no deviation from the ISTS.
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| In addition, the added Completion Time for Required Action A.1 will be deleted because it is not needed since it is covered by ISTS 3.1.7 ACTION C. CTS and ITS markups will be revised, as applicable, to reflect ITS 3.1.7 ACTION C (tied to CTS 3.1.3.2 Actions a.1 and a.3). The statement, Add proposed ACTION C, will be deleted. Discussion of Change DOC L04 will be revised to address the change to the CTS 3.1.3.2 Action a.1 Completion Time of within one hour to 4 hours in the ITS. ITS 3.1.7 Required Action C.2 will be revised to reduce THERMAL POWER to < 75% RTP consistent with CTS 3.1.3.2 Action a.3. Also, the JFDs in the ITS 3.1.7 markup will be revised, as necessary, to reflect the deletion of JFD 2 and subsequent renumbering. ITS 3.1.7 JFDs 4 and 5 will be eliminated since they are not used.
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| Also, ISTS 3.1.7 Required Action D.1.2, when one or more demand position indicators per bank are inoperable in one or more banks, will be revised to replace 12 steps apart with within required rod misalignment limits. This change is consistent with CTS 3.1.3.2 Action b.1 which references the misalignment limits of CTS 3.1.3.1 (ITS 3.1.4). PTN ITS 3.1.7 will reference rod misalignment limits and the ITS 3.1.7 Bases for ACTION D.1.2 will specify the limits are specified in LCO 3.1.4, Rod Group Alignment Limits. JFD 3 will be added to justify the changes from the ISTS.
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| See Attachment 1 - CCH009 LAR Markups for all the changes described herein. The LAR Markups for CCH009 also include the changes prescribed in CCH010, and CCH011. This was done to ensure continuity between the responses to the three RAIs whose changes are closely tied. The response to CCH008 and the LAR Markups support the changes from bank to group; therefore, these changes do not appear in the attached CCH009 LAR Markups.
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| Attachment
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| : 1. CCH009 LAR Markups
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| ===Response===
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| 7/21/2022 1:40 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/21/2022 12:40 PM Added https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1622 1/2
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| 8/3/22, 5:27 PM Turkey Point ITS Conversion Database Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1622 2/2
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| A01 ITS ITS 3.1.7 REACTIVITY CONTROL SYSTEMS ROD POSITION INDICATION SYSTEMS - OPERATING STET LIMITING CONDITION FOR OPERATION (Continued)
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| (RPI)
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| LCO 3.1.7 3.1.3.2 The Analog Rod Position Indication System and the Demand Position Indication System shall be OPERABLE and capable of determining the respective actual and demanded shutdown and control rod positions as follows: .
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| ACTIONS Note
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| : a. Analog rod position indicators, within one hour after rod motion (allowance for thermal soak); A02 All Shutdown Banks: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.
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| LA01 Control Bank A and B: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the are not required to be group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in OPERABLE for the Core Operating Limits Report.
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| Control Banks C and D: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal range of 0-All Rods Out as defined in the Core Operating Limits Report.
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| : b. Group demand counters; +/- 2 steps.
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| Add proposed LCO 3.1.7 NOTE L03 Applicability APPLICABILITY: MODES 1 and 2.
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| ACTION:
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| Add proposed ACTIONS Note L01
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| : a. With a maximum of one analog rod position indicator per bank inoperable either:
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| in one or more banks A02
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| : 1. Determine the position of the non-indicating rod(s) indirectly by the movable incore detectors at least once per 8 hours and within one hour after any motion of the non- L06 ACTION C indicating rod which exceeds 24 steps in one direction since the last determination of the rods position, or 4 hours L04 2** a). Determine the position of the non-indicating rod indirectly by the movable incore detectors within 8 hours and once every 31 Effective Full Power Days thereafter, and within 1 hour if rod control system parameters indicate unintended movement, or if L04 ACTION A the rod with an inoperable position indicator is moved greater than 12 steps, and 8 s b). Review the parameters of the rod control system for indications of unintended rod movement for the rod with an inoperable indicator within 8 hours and once per 8 hours thereafter, and c). Determine the position of the non-indicating rod indirectly by the movable incore detectors prior to increasing THERMAL POWER above 50% RATED THERMAL POWER and within 8 hours of reaching 100% RATED THERMAL POWER, or Required Actions A.3 and C.2 3. Reduce THERMAL POWER to less than 75% of RATED THERMAL POWER within 8 hours.
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| Add proposed ACTION B L02 Add proposed ACTION C L05 TURKEY POINT - UNITS 3 & 4 3/4 1-19 AMENDMENT NOS. 260 AND 255 Page 1 of 4
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| A01 ITS ITS 3.1.7 REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION FOR OPERATION (Continued) or more in one or more banks L06 ACTION (Continued):
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| : b. With a maximum of one demand position indicator per bank inoperable either:
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| : 1. Verify that all analog rod position indicators for the affected bank are OPERABLE and ACTION D that the most withdrawn rod and the least withdrawn rod of the bank are within the Allowed Rod Misalignment of Specification 3.1.3.1 at least once per 8 hours, or A01 required 2. Reduce THERMAL POWER to less than 75% of RATED THERMAL POWER within 8 hours.
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| Add proposed ACTION E limits M01
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| **Rod position monitoring by Actions a.2.a), a.2.b), and a.2.c) may only be applied to one inoperable rod position L01 indicator per unit and shall only be allowed until an entry into MODE 3.
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| L03 TURKEY POINT - UNITS 3 & 4 3/4 1-20 AMENDMENT NOS. 260 AND 255 Page 2 of 4
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| A01 ITS ITS 3.1.7 REACTIVITY CONTROL SYSTEMS A03 SURVEILLANCE REQUIREMENTS 4.1.3.2.1 Each analog rod position indicator shall be determined to be OPERABLE by verifying that the Demand Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of Specification 3.1.3.1 (allowing for one hour thermal soak after rod motion) in accordance with the M02 Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the Demand Position Indication System and the Analog Rod Position Indication System at least once per 4 hours.
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| 4.1.3.2.2 Each of the above required analog rod position indicator(s) shall be determined to be OPERABLE by LA02 performance of a CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST performed in accordance with the Table 4.1-1.
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| Add proposed SR 3.1.7.1 M02 L05 TURKEY POINT - UNITS 3 & 4 3/4 1-21 AMENDMENT NOS. 260 AND 255 Page 3 of 4
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| A01 ITS ITS 3.1.7 TABLE 4.1-1 ROD POSITION INDICATOR SURVEILLANCE REQUIREMENTS L05 Functional Unit Check Calibration Operational Test M02 Individual Rod Position SFCP SFCP SFCP Demand Position SFCP N/A SFCP TURKEY POINT - UNITS 3 & 4 3/4 1-22 AMENDMENT NOS. 263 AND 258 Page 4 of 4
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| DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS).
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 CTS 3.1.3.2 ACTION a states "With a maximum of one analog rod position CTS LCO 3.1.3.2.a in part indicator per bank inoperable either". ITS Limiting Condition for Operation states, "within one hour after (LCO) 3.1.7 CONDITION A states "One RPI per bank inoperable in one or more rod motion (allowance for thermal soak)," when referring banks." This changes the CTS by including more banks.
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| to rod position. ITS LCO Note states, "Individual RPIs are not The purpose of CTS 3.1.3.2 ACTION a and ITS LCO 3.1.7 CONDITION A is to required to be OPERABLE for 1 hour following movement of state the inoperability of the Rod Position Indication (RPI) System. Rod cluster the associated rods." This control assemblies (RCCAs), or rods, are moved out of the core (up or changes the CTS by changing withdrawn) or into the core (down or inserted) by their control rod drive the wording of the the requirement and making it an mechanisms. The RCCAs are divided among control banks and shutdown LCO Note. banks. Each bank may be further subdivided into two banks to provide for precise reactivity control. The axial position of shutdown rods and control rods The purpose of the CTS are determined by two separate and independent systems: the Demand Position allowance is to ensure enough time is allowed for the RPI Indication System (commonly called group step counters) and the RPI System.
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| system to accurately indicate With one RPI per bank inoperable, different types of banks may have one the rod position following inoperable RPI per type of bank. it does thermal heatup of the system components due to rod movement. Administratively These changes are designated as administrative changes and are acceptable changing the wording to be because they do not result in technical changes to the CTS.
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| more precise and making it an LCO Note does not change the allowance. This change is INSERT DOC A03 MORE RESTRICTIVE CHANGES M01 CTS 3.1.3.2 ACTION a does not contain an ACTION to follow if the provided ACTIONS cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour to initiate a shutdown and 7 hours to be in HOT STANDBY.
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| ITS 3.1.7 ACTION E requires the unit to be placed in MODE 3 with 6 hours if the Required Actions and associated Completion Time of ACTION A or D are not met. This changes the CTS by eliminating the one hour to initiate a shutdown and consequently allows one hour less for the unit to be in MODE 3.
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| This change is acceptable because it provides an appropriate compensatory measure for the described conditions. If any Required Action and associated Completion Time cannot be met, the unit must be placed in a MODE in which the LCO does not apply. The LCO is applicable in MODES 1 and 2. Requiring a shutdown to MODE 3 is appropriate in this condition. The one hour allowed by CTS 3.0.3 to prepare for a shutdown is not needed because the operators have had time to prepare for the shutdown while attempting to follow the Required Turkey Point Unit 3 and Unit 4 Page 1 of 6
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| DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION Actions and associated Completion Times. This change is designated as more restrictive because it allows less time to shutdown than is allowed in the CTS.
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| M02 CTS 4.1.3.2.1 requires that each "analog rod position indicator shall be determined to be OPERABLE by verifying that the Demand Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of Specification 3.1.3.1 (allowing for one hour thermal soak after rod motion) in accordance with the Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the Demand Position Indication System and the Analog Rod Position Indication System at least once per 4 hours." ITS 3.1.7 does not contain these requirements because they are duplicative of CTS 4.1.3.1.1 (ITS Surveillance Requirement (SR) 3.1.4.1). A new Surveillance has been added (ITS SR 3.1.7.1) to verify each RPI agrees within 12 steps of the group demand position for the full indicated range of rod travel, once prior to criticality after each removal of the reactor head. This changes the CTS deleting an SR that is duplicated in CTS 4.1.3.1.1 and by adding a new Surveillance Requirement.
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| The purpose of ITS SR 3.1.7.1 is to provide additional assurance that the rod position indication system is operating correctly. This change is acceptable because it provides additional assurance that the rod position indication channels are OPERABLE. This change is designated as more restrictive overall because new requirements are being added to CTS.
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| RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.1.3.2 requires the shutdown and control rod position indication system and the demand position indication system to be OPERABLE and capable of determining the respective actual and demanded shutdown and control rod positions as follows:
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| : a. Analog rod position indicators, within one hour after rod motion (allowance for thermal soak);
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| All Shutdown Banks: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.
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| Control Bank A and B: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.
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| Turkey Point Unit 3 and Unit 4 Page 2 of 6
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| DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION Control Banks C and D: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal range of 0-All Rods Out as defined in the Core Operating Limits Report.
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| : b. Group demand counters; +/- 2 steps.
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| ITS LCO 3.1.7 requires the analog RPI System and the Demand Position Indication System to be OPERABLE but the details of what constitutes an OPERABLE system are moved to the Bases. This changes the CTS by removing the details of what constitutes an OPERABLE system to the Bases.
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| The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement that the RPI System and Demand Position Indication System be OPERABLE. The details on the capability requirements of the systems do not need to appear in the specification in order for the requirement to apply. Additionally, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA02 (Type 4 - - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 4.1.3.2.2 requires a CHANNEL CHECK, CHANNEL CALIBRATION, AND ANALOG CHANNEL CALIBRATION TEST for each analog rod position indicators. ITS 3.1.7 does not contain these SRs for the analog rod position indicators. This changes the CTS by moving the CHANNEL CHECK, CHANNEL CALIBRATION, AND ANALOG CHANNEL CALIBRATION TEST for the analog rod position indicators to the Technical Requirements Manual (TRM).
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| The removal of these surveillance requirements from the Technical Specifications is acceptable because this requirement is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health and safety. The ITS retains the requirement to verify position of individual rods within the alignment limit and verify rod freedom of movement (trippability) by moving each rod not fully inserted in the core 10 steps in either direction (SR 3.1.4.1 and SR 3.1.4.2, respectively). In addition to ensuring the rods are within their alignment limits, these SRs also provide indication if the analog rod position indication is not operating properly. Also, this change is acceptable because these surveillance requirements will be adequately controlled in the TRM. TRM changes are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because TS requirements are being removed from the Technical Specifications.
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| Turkey Point Unit 3 and Unit 4 Page 3 of 6
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| ITS 3.1.7 ACTIONS provide requirements for the inoperability of RPI on a per DISCUSSION OF CHANGES group basis and demand ITS 3.1.7, ROD POSITION INDICATION position indicators on a per bank basis. The change from RPI per bank to RPI per group in one or more groups LESS RESTRICTIVE CHANGES (RPI) is discussed in DOC L06.
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| L01 (Category 4 - Relaxation of Required Action) CTS 3.1.3.2 ACTION a covers the inoperability for a maximum of one analog rod position indicator per bank.
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| CTS 3.1.3.2 does not have an ACTION to cover the inoperability for more than one rod position indicator per bank. CTS 3.1.3.2 ACTION b covers the inoperability for a maximum of one demand position indicator per bank. CTS 3.1.3.2 Note ** states "Rod position monitoring by Actions a.2.a), a.2.b), and RPI per group in RPI a.2.c) may only be applied to one inoperable rod position indicator per unit and one or more groups shall only be allowed until an entry into MODE 3." ITS 3.1.7 ACTIONS are modified by a Note that states "Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator." ITS 3.1.7 ACTION A covers inoperability for one rod position indicator per bank. ITS 3.1.7 ACTION B covers inoperability for more than one rod position indicator per bank.
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| ITS 3.1.7 ACTION D covers inoperability for one demand position indicator bank for one or more banks. This changes the CTS by allowing separate Condition entry for each inoperable rod position indicator and each demand position indicator. RPI inoperable The purpose of CTS 3.1.3.2 ACTION a is to provide compensatory actions for a maximum of one rod position indicator per bank. The purpose of CTS 3.1.3.2 ACTION b is to provide compensatory actions for one demand position indicator per bank. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. This change will allow separate Condition entry for each inoperable rod position indicator and each inoperable demand RPI position indicator while the CTS does not. The ITS will allow each inoperable rod position indicator or each inoperable demand position indicator to be tracked separately. This change is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for inoperable position indication. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| 2 L02 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.7 ACTION requires that with a maximum of one analog rod position indicator per bank inoperable, restore the inoperable indicator or reduce THERMAL POWER within 8 hours.
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| CTS 3.1.3.7 has no ACTION for more than one analog rod position indicator per bank inoperable. ITS 3.1.7 ACTION B requires more than one rod position indicator in one or more banks inoperable to be restored to OPERABLE status such that a maximum of one rod position indicator per group is inoperable within 24 hours. This changes the CTS by allowing 24 hours to restore inoperable rod position indicators to OPERABLE status such that a maximum of one rod position indicator per group is inoperable.
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| Turkey Point Unit 3 and Unit 4 Page 4 of 6
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| DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION The purpose of ITS 3.1.7 is to keep the rod position indication system and demand position indication system OPERABLE. 24 hours is allowed to restore inoperable rod position indicators to OPERABLE status such that a maximum of one rod position indicator per bank is inoperable. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant system or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. The change is the addition of ITS 3.1.7 ACTION B. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| L03 (Category 7 - Relaxation Of Surveillance Frequency Change - NON-24 MONTH TYPE CHANGE) CTS LCO 3.1.3.2 a states "within one hour after rod motion."
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| ITS LCO 3.1.7 Note states "Individual RPIs are not required to be OPERABLE for Insert DOC L03 1 hour following movement of the associated rods." This changes the CTS by allowing OPERABILITY after 1 hour.
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| The purpose of CTS 3.1.3.2 is to require OPERABILITY within one hour after rod motion. ITS LCO 3.1.7 Note states RPIs are not required to be OPERABLE for 1 hour following rod movement. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Allowing OPERABILITY after 1 hour is additional time. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
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| L04 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.2 a states in part that within 1 hour is allowed if rod control system parameters indicate unintended movement. ITS LCO 3.1.7 ACTION A states in part that 8 hours is allowed for unintended movement or inoperable RPI. This changes the CTS by allowing 8 hours for Completion Time.
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| The purpose of ITS LCO 3.1.7 ACTION A is verification of rod position of the RPI System. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Allowing a completion time of 8 hours verses 1 hour is additional time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| L05 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.2 a states, in part, that with a maximum of one analog rod position indicator per bank inoperable, determining that the position of the non-indicating rod within 1 hour is allowed if rod control system parameters indicate unintended movement. CTS 3.1.3.2 does not have an ACTION C. ITS LCO 3.1.7 ACTION C states that 4 hours is allowed for "One INSERT DOC L05 or more RPI inoperable in one or more banks and associated rod has been Turkey Point Unit 3 and Unit 4 Page 5 of 6
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| DISCUSSION OF CHANGES ITS 3.1.7, ROD POSITION INDICATION moved > 24 steps in one direction since the last determination of the rod's position." This changes the CTS by allowing 4 hours for Completion Time and one or more inoperable RPI.
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| The purpose of ITS LCO 3.1.7 ACTION C is verification of rod position of one or more RPIs inoperable in one or more banks and the associated rod has been moved > 24 steps in one direction since the last determination of the rod's position. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Allowing a Completion Time of 4 hours is additional time for one or more inoperable RPI. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| INSERT DOC L06 Turkey Point Unit 3 and Unit 4 Page 6 of 6
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| ITS 3.1.7 DOC INSERTS INSERT DOC A03 A03 CTS 4.1.3.2.1 requires each analog rod position indicator (RPI) to be determined to be OPERABLE by verifying that the Demand Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of Specification 3.1.3.1 (allowing for one hour thermal soak after rod motion) in accordance with the Surveillance Frequency Control Program (SFCP) except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the Demand Position Indication System and the Analog Rod Position Indication System at least once per 4 hours. ITS 3.1.7 does not contain this SR. However, this Surveillance is redundant to CTS 4.1.3.1.1 which is retained as ITS SR 3.1.4.1. This changes the CTS by removing a duplicate SR.
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| The purpose of CTS 4.1.3.2.1 is to verify the OPERABILITY of the RPI by verifying that the demand position indicator and the RPI agree within the allowed rod misalignment limits. The removal of the SR is acceptable because CTS 4.1.3.2.1 is a duplicate of CTS 4.1.3.1.1, which is being retained in the ITS as SR 3.1.4.1, as modified in ITS 3.1.4.
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| CTS 4.1.3.1.1 requires the position of each full length rod to be determined to be within the Allowed Rod Misalignment of the group step counter demand position in accordance with the SFCP (allowing for one hour thermal soak after rod motion) except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours. The Frequencies of both CTS 4.1.3.1.1 and 4.1.3.2.1 in the SFCP are equivalent. Therefore, performance of CTS 4.1.3.1.1 accomplishes the same purpose at the same periodicity as CTS 4.1.3.2.1 (i.e.,
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| periodically verifies OPERABILITY of the RPI). ITS SR 3.1.4.1 requires verifying the position of individual rods within alignment limit at a frequency in accordance with the SFCP. Changes to CTS 4.1.3.1.1, which would also apply to CTS 4.1.3.2.1, are described in the Discussion of Changes associated with ITS 3.1.4. This change represents a presentation difference and is classified as administrative since it does not result in technical changes to the CTS.
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| Page 1 of 6
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| ITS 3.1.7 DOC INSERTS INSERT DOC L03 (Category 4 - Relaxation of Required Action) CTS 3.1.3.2 Action a.2, which allows use of movable incore detectors as an alternative method of verifying rod position, is modified by Footnote ** that states, Rod position monitoring by Actions A.2.a), a.2.b), and a.2.c) may only be applied to one inoperable rod position indicator per unit and shall only be allowed until an entry into MODE 3. ITS 3.1.7 ACTIONS do not contain this limitation on the use of movable incore detectors as an alternative method of verifying rod position. This changes the CTS by eliminating the requirement limiting the alternate method of verifying rod position to only one inoperable RPI per unit and only until an entry into MODE 3.
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| The purpose of CTS 3.1.3.2 Action a.2 Footnote** limiting the alternate method of verifying rod position to only one inoperable RPI per unit and only until an entry into MODE 3 is to ensure sufficient rod position monitoring is available to verify core conditions during normal operation and that the RPI is repaired as soon as reasonable conditions exist to safely perform the activities and prevent repeated use of this provision in lieu of the necessary repair. The proposed change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the other RPI within the rod group. This includes the capacity and capability of the remaining RPI, a reasonable time to determine the position of the rod using the movable incore detectors, and the low probability of a Design Basis Accident (DBA) occurring during the time period to verify the rod position using movable incore detectors. The PTN movable incore detector system for each unit is capable of providing rod position monitoring when required, to verify core conditions during normal operations and accident conditions.
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| Therefore, there is no need to limit the use of movable incore detectors as an alternative method of verifying rod position to the condition of one inoperable RPI per unit. In addition, the plant quality assurance program will ensure that the degraded condition of an inoperable RPI, which is a condition considered adverse to quality, is promptly corrected pursuant to Section XVI, "Corrective Action," of 10 CFR 50, Appendix B. Therefore, the inoperable RPI will be repaired as soon as reasonable conditions exist to safely perform the activities and there is no need to limit the use of the alternative method of verifying rod position only until an entry into MODE 3. The CTS limitation specified in Footnote ** was not included in TSTF-547-A; Clarification of Rod Position Requirements, which incorporated the alternate method of verifying rod position into the ISTS.
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| The subject ITS 3.1.7 ACTIONS are consistent with the ISTS and have been determined to provide sufficient rod position monitoring to verify core conditions during normal operation when one RPI is inoperable in one or more groups. Therefore, the ITS 3.1.7 ACTIONS continue to provide acceptable remedial actions pursuant to 10 CFR 50.36(c)(2)(i) when one RPI per group is inoperable in one or more groups. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| Page 2 of 6
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| ITS 3.1.7 DOC INSERTS INSERT DOC L04 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.2 Action a.1 requires, in part, determining the position of the non-indicating rod(s) indirectly by movable incore detectors within one hour after any motion of the non-indicating rod which exceeds 24 steps in one direction since the last determination of rods position. CTS 3.1.3.2 Action a.2.a requires, in part, determining the position of the non-indicating rod indirectly by movable incore detectors within 1 hour if rod control system parameters indicate unintended movement. ITS 3.1.7 Required Action A.1 requires, in part, verification of the position of the rods with inoperable RPI indirectly by using movable incore detectors within 8 hours after discovery of each unintended rod movement. ITS 3.1.7 Required Action C.1 requires verification of the position of the rods with inoperable RPI indirectly by using movable incore detectors within 4 hours. This changes the CTS by extending the Completion Time to verify the position of the rods with inoperable RPI indirectly by using movable incore detectors.
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| The purpose of CTS 3.1.3.2 Action a.1 and a.2.a is periodic verification of rod position using the movable incore detector system after the rods have been moved significantly or intended rod movement has occurred. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the other RPI within the rod group. This includes the capacity and capability of the remaining RPI, a reasonable time to determine the position of the rod using the movable incore detectors, and the low probability of a DBA occurring during the allowed Completion Time. One hour does not allow adequate time to use the movable incore detector system to measure the core flux around the rod and analyze the data to determine the rod position in a controlled manner, thereby increasing the potential for human performance error when performing this task. The proposed Completion Times of 8 hours and 4 hours have been determined reasonable to determine the position of the rod using the movable incore detectors. This extended period of time to determine the rod position will not result in significant perturbation of the core power distribution if the rod is misaligned, and since the probability of a DBA or transient that would be affected by the potentially misaligned rod is very low for the period of time allowed to determine the rod position. The subject ITS 3.1.7 ACTIONS are consistent with the ISTS and have been determined to provide sufficient time to verify the position of each rod with inoperable RPI indirectly by using movable incore detectors. Therefore, the ITS 3.1.7 ACTIONS continue to provide acceptable remedial actions pursuant to 10 CFR 50.36(c)(2)(i) when one RPI per group is inoperable in one or more groups. This change is designated as less restrictive because additional time is allowed to perform remedial actions when the LCO is not met than was allowed in the CTS.
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| Page 3 of 6
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| ITS 3.1.7 DOC INSERTS INSERT DOC L05 (Category 5 - Deletion of Surveillance Requirement) CTS 4.1.3.2.2 requires a CHANNEL CHECK, CHANNEL CALIBRATION, and ANALOG CHANNEL OPERATIONAL TEST for each required analog rod position indicator as specified in Table 4.1-1. ITS 3.1.7 does not contain this Surveillance Requirement (SR) or Table 4.1-1 for the analog rod position indicators.
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| Additionally, ITS SR 3.1.7.1 is added and will require a verification that each rod position indicator (RPI) agrees within 12 steps of the group demand position for the full indicated range of rod travel. This verification will be performed once prior to criticality after each removal of the reactor head. ITS SR 3.1.7.1 includes a note that the SR is not required to be met for RPI associated with a rod that is not within the alignment limits of limiting condition for operation (LCO) 3.1.4. The CTS is revised to conform to the ISTS. This changes the CTS by deleting surveillances.
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| The purpose of CTS 4.1.3.2.2 and testing specified in CTS Table 4.1-1 is to ensure that the individual rod position indicators (RPIs) and demand position indicators are capable of assessing OPERABILITY and misalignment of the shutdown and control rods. The Rod Position Indication System is an indication-only system and the RPI and demand position indicators do not function or actuate to mitigate a design basis accident or transient. The acceptance criteria for rod position indication are that rod positions must be known with sufficient accuracy in order to verify the core is operating within the group sequence, overlap, design peaking limits, ejected rod worth, and with minimum SHUTDOWN MARGIN. The rod positions must also be known in order to verify the alignment limits are preserved. This change is acceptable because the deleted SR is not necessary to verify that the equipment used to meet the LCO can perform their required functions. Other SRs retained in Technical Specifications and proposed ITS SR 3.1.7.1 continue to ensure the necessary quality of the RPIs and demand position indicators is maintained with sufficient accuracy to monitor rod positions. The Channel Check requirement specified in CTS Table 4.1-1 is redundant to CTS 4.1.3.1.1 (ITS SR 3.1.4.1). ITS SR 3.1.4.1 requires that the alignment limits (rod alignment is maintained between analog RPI and group step counter demand position) be verified at a frequency in accordance with the Surveillance Frequency Control Program (SFCP), which is currently every 12 hours. This rod alignment limit surveillance accomplishes the same verification as required by the Channel Check specified in CTS 4.1.3.2.2. In addition, CTS 4.1.3.1.2 (ITS SR 3.1.4.2) verifies rod freedom of movement (trippability) by moving each rod not fully inserted in the core 10 steps in either direction at a frequency in accordance with the SFCP, which is currently every 184 days. Performance of ITS SR 3.1.4.2 confirms the OPERABILITY of each RPI and demand position indicator by periodically actuating the associated RPI channel and demand position indicator channel eliminating the need for a periodic Channel Operational Test. ISTS SR 3.1.7.1 is being adopted, which verifies that each RPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. This SR ensures each RPI is operating correctly. This SR is performed prior to reactor criticality after each removal of the reactor head, as there is the potential for unnecessary plant transients if the SR were performed with the reactor at power. Calibration errors that could impact the capability of an RPI to determine the rod position with sufficient accuracy would be identified during the performance of ITS SR 3.1.7.1 prior to criticality. Therefore, an explicit requirement to perform a Channel Calibration at a frequency in accordance with the SFCP, which is currently 18 months, is unnecessary.
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| Page 4 of 6
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| ITS 3.1.7 DOC INSERTS INSERT DOC L05 (continued)
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| The combination of the retained SRs, the addition of ITS SR 3.1.7.1, and considering that the RPIs are prominent in the control room and routinely observed by the operators, provides assurance the OPERABILITY of the analog rod position indicators are adequately monitored and maintained. Therefore, the analog rod position indicators (i.e., RPIs and group demand position indicators) continue to be tested in a manner and at a frequency necessary to give adequate confidence, pursuant to the requirements of 10 CFR 50.36(c)(3), that the necessary quality of systems and components is maintained, facility operation will be within safety limits, and that the Rod Position Indication LCO will be met. This change is designated as a less restrictive because Surveillances, which were required in the CTS, will not be required in the ITS.
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| Page 5 of 6
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| ITS 3.1.7 DOC INSERTS INSERT DOC L06 L06 (Category 4 - Relaxation of Required Action) CTS 3.1.3.2 Action a states, in part, "With a maximum of one analog rod position indicator per bank inoperable..." CTS 3.1.3.2 Action b states, in part, With a maximum of one demand position indicator per bank inoperable ITS 3.1.7 Condition A applies with, One RPI per group inoperable in one or more groups.
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| ITS 3.1.7 Condition D applies with, One or more demand position indicators per bank inoperable in one or more banks. The CTS is revised to incorporate the ISTS allowance for one rod position indicator (RPI) per group to be inoperable in one or more groups versus one rod per bank and the allowance of multiple demand position indicators to be inoperable in one or more banks. This changes the CTS by allowing more inoperable RPIs and demand position indicators at any given time.
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| The purpose of CTS 3.1.3.2 Actions a and b is to provide an alternate means of determining rod positions and alignment limits when individual RPI and demand position indicators are not operable. The Rod Position Indication System is an indication-only system and the RPI and demand position indicators do not function or actuate to mitigate a design basis accident or transient. The individual RPI and demand position indicators are used to verify the core is operating within the group sequence, overlap, design peaking limits, ejected rod worth, and with minimum SHUTDOWN MARGIN. The rod positions must also be known in order to verify the alignment limits are preserved. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. In this case, the Required Actions ensure the position of the affected rods are verified on a more frequent basis when the associated RPI is inoperable by using moveable incore instrumentation and verifying the maximum deviation of the individual rod positions are within alignment limits when a demand position indicator is inoperable. Considering the limited rod motion that typically occurs during normal operation, the more frequent interval for determining rod position has also been shown by operating experience to be adequate to track and maintain positive control of rod position. The actual rod position, not the indicating system, is the parameter of concern in the safety analyses and the ITS ACTIONS provide adequate compensatory measures for one inoperable RPI per group in one or more groups and multiple inoperable demand position indicators per bank in one or more banks. The proposed ITS 3.1.7 ACTIONS allow for more inoperable indicators than the CTS Actions but remains consistent with safe plant operation, considering the successful operating experience with determining rod positions and rod alignment by the use of the alternate means specified. The methods of determining rod position and rod alignment specified in the ACTIONS have been shown to be accurate and reliable alternatives that may be safely used for additional rods with inoperable indicators. The proposed change results in Required Actions that continue to assure the position and alignment of the affected rods are verified at a frequency which ensures the safe operation of the plant. The subject ITS 3.1.7 ACTIONS are consistent with the ISTS and have been determined to provide sufficient rod position monitoring to verify core conditions during normal operation when one RPI is inoperable in one or more groups or one or more demand position indicators per bank are inoperable in one or more banks. Therefore, the ITS 3.1.7 ACTIONS continue to provide acceptable remedial actions pursuant to 10 CFR 50.36(c)(2)(i) when one RPI per group is inoperable in one or more groups or one or more demand position indicators per bank are inoperable in one or more banks. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| Page 6 of 6
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| Rod Position Indication 3.1.7 CTS 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication 1
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| 3.1.3.2 LCO 3.1.7 The [Digital] Rod Position Indication [D]RPI System and the Demand Position Indication System shall be OPERABLE.
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| A02
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| ------------------------------------- NOTE ---------------------------------------------------
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| DOC L03
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| [Individual RPIs are not required to be OPERABLE for 1 hour following 1 movement of the associated rods.]
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| Applicability APPLICABILITY: MODES 1 and 2.
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| ACTIONS
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| ------------------------------------------------------------NOTE-----------------------------------------------------------
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| DOC L01 Separate Condition entry is allowed for each inoperable [D]RPI and each demand position 1 indicator.
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| 2 CONDITION REQUIRED ACTION COMPLETION TIME bank 1 3 ACTION a A. One [D]RPI per group A.1 Verify the position of the Once per 8 hours inoperable in one or rods with inoperable [D]RPI AND ACTION a.1 more groups. indirectly by using movable DOC L06 Within one hour after any motion banks incore detectors. of the inoperable rod which 3
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| exceeds 24 steps in one direction OR since the last determination of the rods position A.2 Verify the position of the 8 hours ACTION a.2.a) rods with inoperable [D]RPI indirectly by using the AND moveable incore detectors.
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| Once per 31 EFPD thereafter AND DOC L04 8 hours after discovery of each ACTION a.2.b) unintended rod movement 2
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| AND Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-1 Rev. 5.0 3
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| Rod Position Indication CTS 3.1.7 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME 8 hours after each ACTION a.2.a) movement of rod with inoperable [D]RPI 1
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| > 12 steps AND Prior to THERMAL POWER exceeding 50% RTP ACTION a.2.c)
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| AND 8 hours after reaching RTP OR ACTION a.3. A.3 Reduce THERMAL 8 hours 3
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| POWER to 50% RTP. 2
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| < 75 1
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| DOC L02 B. More than one [D]RPI B.1 Place the control rods Immediately per group inoperable in under manual control.
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| 3 DOC L06 one or more groups. bank banks AND B.2 Restore inoperable [D]RPIs 24 hours 1 to OPERABLE status such that a maximum of one 1
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| [D]RPI per group is inoperable.
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| Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-2 Rev. 5.0 3
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| Rod Position Indication 3.1.7 CTS ACTIONS (continued)
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| L04 CONDITION REQUIRED ACTION COMPLETION TIME DOC L05 C. One or more [D]RPI C.1 Verify the position of the [4] hours 1 ACTION a.1 inoperable in one or rods with inoperable more groups and [D]RPIs indirectly by using 3 1 bank associated rod has been movable incore detectors.
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| moved > 24 steps in one < 75 direction since the last OR determination of the rod's position. C.2 Reduce THERMAL 8 hours ACTION a.3 POWER to 50% RTP.
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| L06 DOC L01 D. One or more demand D.1.1 Verify by administrative Once per 8 hours ACTION C position indicators per means all [D]RPIs for the 1 bank inoperable in one affected banks are or more banks. OPERABLE.
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| b 2 AND D.1.2 Verify the most withdrawn Once per 8 hours 2 3 rod and the least withdrawn rod of the affected banks are 12 steps apart. 3 OR within required rod misalignment limits.
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| D.2 Reduce THERMAL 8 hours 3
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| M01 POWER to 50% RTP.
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| < 75 2
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| DOC M02 E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time not met.
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| Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-3 Rev. 5.0 3
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| Rod Position Indication 3.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC L05 SR 3.1.7.1 ----------------------------- NOTE ------------------------------
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| Not required to be met for [D]RPIs associated with rods that do not meet LCO 3.1.4.
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| 1 Verify each [D]RPI agrees within [12] steps of the Once prior to group demand position for the [full indicated range] criticality after of rod travel. each removal of the reactor head 2
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| Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-4 Rev. 5.0 3
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| JUSTIFICATION FOR DEVIATIONS ITS 3.1.7, ROD POSITION INDICATION
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| : 1. The Improved Standard Technical Specifications (ISTS) contain bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 2. ISTS 3.1.7 ACTION A provides compensatory actions when one rod position indicator is inoperable. Turkey Point Nuclear Generating Station (PTN) Improved Technical Specification (ITS) 3.1.7 provides an additional Required Action that can be taken when one rod position indicator is inoperable. The new Required Action 2 allows the use of an alternate means other than the movable incore detectors to monitor the position of a control or shutdown rod when the analog rod position indication system is inoperable.
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| : 3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 4. Editorial changes made for enhanced clarity/consistency.
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| : 5. Changes are made to be consistent with the Specification.
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| : 3. The ISTS Required Action D.1.2 alignment criteria has been revised to be consistent with the current licensing basis requirements. The CTS allows the alignment criteria to vary at THERMAL POWER levels > 90% and 90% as specified in ITS LCO 3.1.4.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| Rod Position Indication B 3.1.7 BASES of APPLICABILITY The requirements on the [D]RPI and step counters are only applicable in 5 2 MODES 1 and 2 (consistent with LCO 3.1.4, LCO 3.1.5, and LCO 3.1.6),
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| because these are the only MODES in which power is generated, and the OPERABILITY and alignment of rods have the potential to affect the safety of the plant. In the shutdown MODES, the OPERABILITY of the shutdown and control banks has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the Reactor Coolant System.
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| ACTIONS The ACTIONS Table is modified by a Note indicating that a separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator. This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable position indicator.
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| A.1 and A.2 bank When one [D]RPI channel per group in one or more groups fails, the 2 1 position of the rod may still be determined indirectly by use of the 5 movable incore detectors. The Required Action may also be satisfied by ensuring at least once per 8 hours that FQ satisfies LCO 3.2.1, F N H 3 satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Based on experience, normal power operation does not require excessive movement of banks. If a bank has been significantly moved, the Required Action of C.1 or C.2 below is required. Therefore, verification of RCCA position within the Completion Time of 8 hours is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small.
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| Required Action A.1 requires verification of the position of a rod with an inoperable [D]RPI once per 8 hours which may put excessive wear and 2 tear on the moveable incore detector system, Required Action A.2 provides an alternative. Required Action A.2 requires verification of rod position using the moveable incore detectors every 31 EFPD, which coincides with the normal use of the system to verify core power distribution.
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| INSERT 1 3 Required Action A.2 includes six distinct requirements for verification of the position of rods associated with an inoperable [D]RPI using the movable incore detectors:
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| 2
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| : a. Initial verification within 8 hours of the inoperability of the [D]RPI; Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7-4 Rev. 5.0 1
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| 3 INSERT 1 Required Action A.1 requires that if one or more rods have been significantly moved (more than 24 steps in one direction, since the position was last determined), Required Action A.1 is still appropriate, but actions must be initiated immediately to begin verifying that the rod is still properly positioned, relative to their group positions. In this Required Action, the Completion Time only begins on discovery that both:
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| : a. One rod position indication per bank is inoperable, and
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| : b. A rod with an inoperable position indicator has been moved more than 24 steps in one direction since the last determination of the rod's position.
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| If at any time during the existence of Condition A (one RPI per bank inoperable), a rod with an inoperable position indicator has been moved more than 24 steps in one direction since the last determination of the rod's position, this Completion Time begins to be tracked.
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| Insert Page B 3.1.7-4
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| Rod Position Indication B 3.1.7 BASES ACTIONS (continued)
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| The immediate Completion Time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in this Condition.
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| The 24 hour Completion Time provides sufficient time to troubleshoot and restore the [D]RPI system to operation while avoiding the plant 2 5 challenges associated with the shutdown without full rod position indication.
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| Based on operating experience, normal power operation does not require excessive rod movement. If one or more rods has been significantly moved, the Required Action of C.1 or C.2 below is required.
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| C.1 and C.2 With one [D]RPI inoperable in one or more groups and the affected groups have moved greater than 24 steps in one direction since the last determination of rod position, additional actions are needed to verify the position of rods within inoperable [D]RPI. Within 4 hours, the position of the rods with inoperable position indication must be determined using the moveable incore detectors to verify these rods are still properly positioned, relative to their group positions. < 75 If, within [4] hours, the rod positions have not been determined, 2 THERMAL POWER must be reduced to 50% RTP within 8 hours to 4 avoid undesirable power distributions that could result from continued operation at > 50% RTP, if one or more rods are misaligned by more than 4 24 steps. The allowed Completion Time of [4] hours provides an acceptable period of time to verify the rod positions.
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| 75 D.1.1 and D.1.2 With one or more demand position indicators per bank inoperable in one or more banks, the rod positions can be determined by the [D]RPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indicators are OPERABLE and the most withdrawn rod and the least withdrawn rod are 12 steps apart within the allowed Completion 4
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| Time of once every 8 hours is adequate.
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| Rod misalignment limits are within the required rod specified in LCO 3.1.4. "Rod misalignment limits Group Alignment Limits,"
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7-6 Rev. 5.0 1
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| 7/25/22, 1:33 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1646 NRC Question CCH009 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/25/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/25/2022 12:28 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1646 1/1
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| 5/25/22, 7:30 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 707 NRC Question CCH010 Number Category Technical ITS 3.1 Section ITS 3.1.7 Number DOC L-1 Number JFD Number JFD Bases Number Page 164 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC 1. DOC 3.1.7-L01 addresses the added allowance of separate Condition entry for each RPI (i.e., per rod)
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| Question and each demand position indication (i.e., per rod group). On page 164, the markup of CTS 3.1.2.1, the footnote ** for ACTION a.2. is shown as being deleted according to DOC 3.1.7-L01. The footnote **
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| provides a Mode-related restriction on the application of ACTION a.2; it states:
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| ** Rod position monitoring by Actions a.2.a), a.2.b), and a.2.c) may only be applied to one inoperable rod position indicator per unit and shall only be allowed until an entry into MODE 3.
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| The staff observes that although DOC 3.1.7- L01 quotes this footnote, it does not explicitly address the reasons for the restrictions specified by this footnote, and why removal of those restrictions is acceptable.
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| The licensee is requested to add justification for this change in an appropriate DOC.
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| : 2. DOC 3.1.7-A02 states: CTS 3.1.3.2 ACTION a states With a maximum of one analog rod position indicator per bank inoperable either. ITS [LCO] 3.1.7 Condition A states One RPI per bank inoperable in one or more banks. This changes the CTS by including more banks.
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| This is an administrative change only if the correct interpretation of CTS 3.1.3.2 ACTION a is that, because it says one RPI per bank inoperable, ACTION a also applies to the Condition of simultaneously having multiple affected banks, each affected bank with one analog RPI inoperable. (There are no provision in the CTS Action a for having a separate Completion Time for each affected bank, which is addressed by DOC 3.1.7-L02.) The licensee is requested to clarify why the change described in DOC 3.1.7-A02 is designated as administrative.
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| : 3. DOC 3.1.7-L03 addresses changing the exception to meeting the LCO requirement of CTS 3.1.3.2.a for RPI operability, from within one hour after rod motion (allowance for thermal soak) to Individual RPIs are not required to be OPERABLE for 1 hour following movement of the associated rods in the Note to corresponding ITS LCO 3.1.7.
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| The DOC 3.1.7-L03 is categorized as Category 7 - Relaxation of Surveillance Frequency Change - NON-24 MONTH TYPE CHANGE; this is incorrect because this is not a change to a Surveillance Frequency, but an apparent change to the allowed duration of an exception to meeting the LCO. This appears to rather be an https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=707 1/2
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| 5/25/22, 7:30 PM Turkey Point ITS Conversion Database administrative change because the phrasing in both versions of the exception require that the moved rods RPI be Operable 1 hour after completion of the rod movement. The licensee is requested to clarify why the change described in DOC 3.1.7-L03 is designated as less restrictive rather than administrative.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/25/2022 Added By Craig Harbuck Date Modified Modified By Date 5/25/2022 5:41 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=707 2/2
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| 8/3/22, 5:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1626 NRC Question CCH010 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response 1. Discussion of change (DOC) L03 will be added to provide justification for the deletion of the CTS Statement footnote that limits the alternate monitoring method to only one inoperable RPI per unit and shall only be allowed until an entry into MODE 3. DOC L01 will be revised to limit the discussion to the added note allowing separate Condition entry note for each inoperable rod position indicator and each demand position indicator. See the Attachment associated with response to RAI CCH009 (Attachment 1
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| - CCH009 LAR Markups) for the LAR markup pages.
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| : 2. The proposed change specified in DOC A02 did not result in a technical change, but rather is a presentation preference. After further review, FPL has determined to change the CTS Action requirement to include the Conditions on a per group basis instead of a per bank basis. As a result, FPL will designate the CTS Actions a and Action b change, from allowing one RPI and demand position indicator per bank to be inoperable to allowing one RPI or demand position indicator per group in one or more groups to be inoperable as a less restrictive change versus an administrative change. Therefore, FPL will replace DOC A02 with DOC L06. DOC L06 was revised in response to CCH008 to address one RPI per group instead of one RPI per bank. DOC L06 will be further revised to expand the discussion related to one RPI per group to one RPI per group in one or more groups and one or more demand position indicators per bank in one or more banks. This revised DOC L06 will include and supersede, where appropriate, the changes provided in FPL response to CCH008. See the Attachment associated with response to RAI CCH009 (Attachment 1 - CCH009 LAR Markups) for the LAR markup pages.
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| : 3. FPL will delete the current less restrictive DOC (L03) and designate the one-hour allowance for components to thermally stabilize following rod movement specified in CTS 3.1.3.2.a, as an administrative change consistent with the Note to LCO 3.1.7 and insert a discussion in DOC A02. See the Attachment associated with response to RAI CCH009 (Attachment 1 - CCH009 LAR Markups) for the LAR markup pages.
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| Attachment
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| : 1. None for CCH010. See the LAR Markup Attachment associated with RAI CCH009 (Attachment 1 - CCH009 LAR Markups) for the markups associated with the above changes. This was done for continuity and affects CCH009, CCH010, and CCH011.
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| ===Response===
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| 7/21/2022 1:40 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/21/2022 12:42 PM Added Date Modified Modified https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1626 1/2
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| 8/3/22, 5:26 PM Turkey Point ITS Conversion Database By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1626 2/2
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| 7/29/22, 10:20 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1674 NRC Question CCH010 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/28/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/28/2022 3:00 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1674 1/1
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| 5/25/22, 7:31 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 711 NRC Question CCH011 Number Category Technical ITS 3.1 Section ITS 3.1.7 Number DOC LA-2 Number JFD Number JFD Bases 3
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| Number Page 165, 166, 169, 175, 176, 178 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call Y
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| Requested NRC On page 169, DOC 3.1.7-LA02 states in part, (Type 4 - - Removal of LCO, SR, or other TS requirement to Question the TRM, ...). ... CTS SR 4.1.3.2.2 requires a CHANNEL CHECK, CHANNEL CALIBRATION, and [ANALOG]
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| CHANNEL [CALIBRATION] [OPERATIONAL] TEST for each analog rod position indicators[; and CHANNEL CHECK and CHANNEL OPERATIONAL TEST for each group demand position counter]. ITS 3.1.7 does not contain these SRs for the analog rod position indicators [and group demand position counters]. This changes the CTS by moving [these SRs] for the analog rod position indicators [and group demand position counters] to the Technical Requirements Manual (TRM). However, the discussion of change does not provide a clear justification for why these SRs are not required by 10 CFR 50.36(c)(3).
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| Please describe clearly why the removed/relocated surveillances are not required by 10 CFR 50.36(c)(3).
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| If your justification is because other ITS SRs (such as SR 3.1.4.1 and SR 3.1.4.2) will meet that need, please explain how they do so.
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| The justification in the DOC 3.1.7-LA02 states: The ITS retains the requirement to verify position of individual rods within the alignment limit and verify rod freedom of movement (trippability) by moving each rod not fully inserted in the core 10 steps in either direction (SR 3.1.4.1 and SR 3.1.4.2, respectively). In addition to ensuring the rods are within their alignment limits, these SRs also provide indication if the analog rod position indication is not operating properly. Also, this change is acceptable because these surveillance requirements will be adequately controlled in the TRM.
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| Further, the change appears to be a L-type change rather than a LA (removal of detail change). Please consider the characterization of this change in that light.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/25/2022 Added By Craig Harbuck Date Modified Modified https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=711 1/2
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| 5/25/22, 7:31 PM Turkey Point ITS Conversion Database By Date 5/25/2022 6:18 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=711 2/2
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| 8/3/22, 5:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1630 NRC Question CCH011 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response FPL will change the ITS 3.1.7 discussion of change (DOC) for the removal of the CTS SRs from a Less Statement Restrictive Removal of Detail Change (DOC LA02) to a Less Restrictive Change (DOC L05). ITS 3.1.7 DOC L05 is being added to describe the proposed deletion of CTS 4.1.3.2.2 and why the adoption of ISTS SR 3.1.7.1 along with SR 3.1.4.1 and SR 3.1.4.2 are adequate to ensure the requirements of 10CFR50.36(c)(3) are being met for the Rod Position Indicators (RPIs) and demand position indicators. As a result of this change, the CTS reference to DOC M02 in the ITS SR 3.1.7.1 markup will revised to DOC L05, DOCs LA02 and M02 will be deleted and the references in the CTS markup will be revised to reflect the change.
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| Additionally, CTS 4.1.3.2.1 is redundant to CTS 4.1.3.1.1 and retained as ITS SR 3.1.4.1. Therefore, the CTS markup will be revised to change DOC M02 to an administrative change DOC A03. See the Attachment associated with response to RAI CCH009 (Attachment 1 - CCH009 LAR Markups) for the LAR markup pages.
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| Attachment
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| : 1. None for CCH011. See the LAR Markup Attachment associated with RAI CCH009 (Attachment 1 - CCH009 LAR Markups) for the markups associated with the above changes. This was done for continuity and affects CCH009, CCH010, and CCH011.
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| ===Response===
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| 7/21/2022 1:45 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/21/2022 12:44 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1630 1/1
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| 7/29/22, 10:20 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1678 NRC Question CCH011 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/28/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/28/2022 3:01 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1678 1/1
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| 5/26/22, 2:21 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 715 NRC Question CCH012 Number Category Technical ITS 3.1 Section ITS 3.1.2 Number DOC LA-1 Number JFD Number JFD Bases 5
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| Number Page 28 31 35 42 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.1.2 - page 28 of 258 - ITS 3.1.2, Core Reactivity Question
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| : 1. DOC 3.1.2-LA01 should state a description of the details being removed; these details are:
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| This comparison shall consider at least those factors stated in Specification 4.1.1.1.1e, above.
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| It is suggested that the licensee include such a description in the DOC 3.1.2-LA01 to ensure the table describing LA-type changes, which will be provided as an attachment to the staff Safety Evaluation for this ITS LAR, does not require referring to the LAR, Enclosure 2, Volume 6, markup page 28.
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| : 2. This question has some subtleties in understanding when actions may or must be accomplished. Worth a discussion at a biweekly meeting.
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| DOC 3.1.2-L03 (Category 7 - Relaxation of Surveillance Frequency) does not accurately categorize the nature of the translation of the CTS 4.1.1.1.2 Surveillance to ITS SR 3.1.2.1. In ITS LAR Enclosure 2, Volume 6, page 31, DOC 3.1.2 L03 says, in part:
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| CTS 4.1.1.1.2 also requires the predicted reactivity values to be adjusted (normalized) to correspond to the actual core conditions prior to exceeding a fuel burnup of 60 EFPD after each fuel loading. ITS SR 3.1.2.1 requires verifying the measured core reactivity is within +/- 1 % k/k of the predicted core reactivity values once prior to entering MODE 1 after each refueling and in accordance with the Surveillance Frequency Control Program after 60 EFPD. This changes the CTS by allowing the initial verification to be performed in MODE 2.
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| The purpose of CTS 4.1.1.1.2 is to verify the agreement between the actual and predicted core reactivity.
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| The CTS and ITS require the predicted core reactivity values to be normalized to the actual values prior to exceeding 60 EFPD of core burnup. ... CTS 4.1.1.1.1.e Frequency has been changed to ensure core reactivity is within limits prior to entering MODE 1 after each refueling.
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| CTS 4.1.1.1.2 (page 28) states, in the first half:
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| When in Mode 1 or 2, the overall core reactivity balance shall be compared to predicted values to demonstrate agreement within +/- 1% k/k in accordance with the Surveillance Frequency Control Program [This is 31 EFPD.] . This comparison shall consider at least those factors stated in Specification 4.1.1.1.1e, above. The predicted reactivity values shall be adjusted (normalized) to https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=715 1/2
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| 5/26/22, 2:21 PM Turkey Point ITS Conversion Database correspond to the actual core conditions prior to exceeding a fuel burnup of 60 EFPD after each fuel loading.
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| (A) The staff observes that CTS 4.1.1.1.2 would allow but does not require performing the initial overall core reactivity balance comparison to predicted values prior to entering MODE 1. Therefore, this event based Frequency is a new more restrictive requirement, and should be addressed by an M-DOC. The licensee is requested to address this new requirement as a more restrictive change.
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| (B) The staff observes that the SDM determination Frequency of 4.1.1.1.1.e is not relevant to the change in Surveillance Frequency addressed by DOC 3.1.2-L03. The licensee is requested to remove reference to the Frequency of 4.1.1.1.1.e from DOC 3.1.2-L03.
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| (C) The last sentence of CTS 4.1.1.1.2, quoted above, is changed by the equivalent Surveillance column Note in ITS SR 3.1.2.1 (on page 35), by changing shall be adjusted to may be adjusted; DOC 3.1.2- L04 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) justifies this difference by stating that the expectation is to perform the adjustment of the predicted reactivity values to the core conditions only if needed.
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| On page 42, the markup of the STS 3.1.2 Bases for SR 3.1.2.1 changes the discussion of the STS Note as follows:
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| The Note indicates that the normalization of predicted core reactivity to the measured value must may take place within the first 60 effective full power days (EFPD) after each fuel loading. This allows sufficient time for core conditions to reach steady state, but prevents operation for a large fraction of the fuel cycle without establishing a benchmark for the design calculations.
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| While it is accurate to say an adjustment is only needed if the predicted reactivity values differ from the measured values (agreement within +/- 1% k/k), the proposed language changes (shall and must replaced by may) can be read as allowing normalization adjustment to occur at some time after 60 EFPD.
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| The licensee is requested to revise its proposed clarification to preclude this possible reading.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/26/2022 Added By Craig Harbuck Date Modified Modified By Date 5/26/2022 1:19 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=715 2/2
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| 8/3/22, 5:51 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1415 NRC Question CCH012 Number Select Licensee Response Application Attachment Attachment 1 - CCH012 LAR Markups.pdf (2MB) 1 Attachment 2
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| Response 1. FPL will revise ITS 3.2.1, Discussion of Change (DOC) LA01 to include a description of the change as Statement follows:
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| (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
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| CTS 3.1.1.1, Surveillance Requirement (SR) 4.1.1.1.2 requires verification that core reactivity is within +/- 1% k/k and states: "This comparison shall consider at least those factors stated in Specification 4.1.1.1.1e, above." ITS SR 3.1.2.1 requires verification that core reactivity is within
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| +/- 1% k/k, but does not describe the factors that must be considered in the calculation. This information is moved to the Bases. This changes the CTS by removing details on how the SDM calculation is performed from the Specification and placing the information in the Bases.
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| See attached CCH012 license amendment request (LAR) markups.
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| 2.A FPL will add a new DOC M01 to account for the change restricting performance of SR 4.1.1.2 to prior to entering MODE 1 after each refueling as follows:
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| M01 CTS SR 4.1.1.1.2 requires verification that core reactivity is within +/- 1% k/k in MODES 1 or 2, in accordance with the Surveillance Frequency Control Program (SFCP). ITS SR 3.1.2.1 requires this verification to be performed "prior to entering MODE 1 following each refueling". This changes the CTS by removing the option of performing the initial surveillance in MODE 1.
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| The purpose of CTS SR 4.1.1.1.2 is to verify that core reactivity is within limits as an initial check on core conditions and design calculations at the beginning of core life. Limiting performance of verification to prior to entry into MODE 1 following a refueling outage provides an additional margin of safety by ensuring reactivity limits are met prior to operation above 5% RATED THERMAL POWER. This change is acceptable because the ITS requires a specific verification that core reactivity is within limits prior to MODE 1 entry during initial startup following a refueling outage where changes in core configuration were implemented. This change is designated as more restrictive because it restricts the conditions under which a Surveillance must be performed.
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| See attached CCH012 license amendment request (LAR) markups.
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| 2.B In light of the addition of DOC M01 in response to part 2.A above, DOC L03 is deleted and DOC L04 renumbered as DOC L03; therefore, no changes related to DOC L03 are required. The ITS 3.1.2 CTS markup is revised accordingly.
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| 2.C FPL will revise the ITS SR 3.1.2.1 Bases to reinstate the term "must" with regard to normalizing the core reactivity values. However, a clarifying phrase is proposed to be added to this Bases statement indicating that adjustments may not be necessary if the predicted values remain conservative to the measured (or actual) core reactivity values. The predicted values are verified prior to startup from a refueling outage that safety analyses limits will be maintained. Therefore, maintaining application of the predicted values when conservative to the measured values maintains the safety analyses assumptions. This clarification is also acceptable as it supports the use of the term "may" in the actual ITS SR 3.1.2.1 Note and the ISTS. FPL will revise Justification for Deviation (JFD) 5 to more accurately support this change. See attached CCH012 license amendment request (LAR) markups.
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| Attachment
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| : 1. CCH012 LAR Markups
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| ===Response===
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| 7/1/2022 12:35 PM Date/Time Closure https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1415 1/2
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| 8/3/22, 5:51 PM Turkey Point ITS Conversion Database Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/1/2022 11:35 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1415 2/2
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| ITS 3.1.2 A01 ITS REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
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| : e. In accordance with the Surveillance Frequency Control Program, when in MODE 3 or 4 by consideration of the following factors:
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| : 1) Reactor Coolant System boron concentration,
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| : 2) Control rod position, See ITS 3.1.1
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| : 3) Reactor Coolant System average temperature, M01
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| : 4) Fuel burnup based on gross thermal energy generation, A01
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| : 5) Xenon concentration, and L03 Verify measured core reactivity is
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| : 6) Samarium concentration.
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| Once prior to entering MODE 1 after refueling AND LA01 SR 3.1.2.1 4.1.1.1.2 When in Mode 1 or 2, the overall core reactivity balance shall be compared to predicted values to demonstrate agreement within +/- 1% k/k in accordance with the Surveillance Frequency Control Program. This comparison shall consider at least those factors stated in Specification 4.1.1.1.1e, above. The predicted reactivity SR 3.1.2.1 values shall be adjusted (normalized) to correspond to the actual core conditions prior to exceeding a fuel burnup A03 Note of 60 EFPD after each fuel loading. Add proposed Frequency Note of predicted values may A01 L04 3
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| TURKEY POINT - UNITS 3 & 4 3/4 1-2 AMENDMENT NOS. 263 AND 258 Page 2 of 2
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| DISCUSSION OF CHANGES ITS 3.1.2, CORE REACTIVITY ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS).
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 CTS 4.1.1.1.2 requires the overall core reactivity balance to be compared to predicted values to demonstrate agreement within +/- 1% k/k. However, this Surveillance is currently part of the SHUTDOWN MARGIN (SDM) Specification.
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| Additionally, CTS 3.1.1.1 is titled SHUTDOWN MARGIN - Tavg Greater Than 200°F. A new Limiting Condition for Operation (LCO), ITS LCO 3.1.2, requires the measured core reactivity to be within +/- 1% k/k of predicted values.
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| Furthermore, ITS 3.1.2 is titled Core Reactivity. This changes the CTS by having a separate Specification for the Core Reactivity requirement and changing the title.
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| This change is acceptable because the requirements have not changed.
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| Converting the requirement from a Surveillance in the SDM specification to an LCO is consistent with the ITS format and content guidance. Any technical changes resulting from this change are discussed in other DOCs. This change is designated as administrative because it does not result in a technical change to the CTS.
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| A03 CTS 4.1.1.1.2 requires the overall core reactivity balance to be compared to predicted values to demonstrate agreement within +/- 1% k/k in accordance with the Surveillance Frequency Control Program (SFCP). ITS Surveillance Requirement (SR) 3.1.2.1 Completion Time includes a Note stating that this SR is "Only required after 60 EFPD." This changes the CTS by stating within the Specification the time in core life in which the SR must be performed.
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| This change is acceptable because performing the SR after 60 EFPD (effective full power days) is consistent with the Frequency contained within the SFCP; therefore, requirements have not changed. Subsequently, this change is designated as administrative because it does not result in a technical change to the CTS.
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| M01 CTS SR 4.1.1.1.2 requires verification that core reactivity is within +/- 1% k/k in MODES 1 or 2, in accordance with the Surveillance Frequency Control Program (SFCP). ITS SR 3.1.2.1 requires this verification to be performed "prior to entering MODE 1 following each MORE RESTRICTIVE CHANGES refueling". This changes the CTS by removing the option of performing the initial surveillance in MODE 1.
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| The purpose of CTS SR 4.1.1.1.2 is to verify that core reactivity is within limits as an initial None check on core conditions and design calculations at the beginning of core life. Limiting performance of verification to prior to entry into MODE 1 following a refueling outage provides an additional margin of safety by ensuring reactivity limits are met prior to operation above 5%
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| RATED THERMAL POWER. This change is acceptable because the ITS requires a specific RELOCATED SPECIFICATIONS verification that core reactivity is within limits prior to MODE 1 entry during initial startup following a refueling outage where changes in core configuration were implemented. This change is designated as more restrictive because it restricts the conditions under which a None Surveillance must be performed.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 4
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| DISCUSSION OF CHANGES ITS 3.1.2, CORE REACTIVITY (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
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| CTS 3.1.1.1, Surveillance Requirement (SR) 4.1.1.1.2 requires verification that core reactivity is within +/- 1% k/k and states: "This comparison shall consider at least those factors stated in Specification 4.1.1.1.1e, above." ITS SR 3.1.2.1 requires verification that core reactivity is within +/-
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| 1% k/k, but does not describe the factors that must be considered in the calculation. This REMOVED DETAIL CHANGES information is moved to the Bases. This changes the CTS by removing details on how the SDM calculation is performed from the Specification and placing the information in the Bases.
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| LA01 The removal of these details for performing SR from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This ITS still retains the requirement that the core reactivity balance comparison be within +/- 1% k/k. The details of how this comparison is calculated do not need to appear in the Specification in order for the requirement to apply. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.
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| This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the CTS.
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| LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 4.1.1.1.2 is applicable in MODES 1, 2, 3, and 4. ITS 3.1.2 is applicable in MODES 1 and 2. This changes the CTS by reducing the applicable MODES in which the core reactivity requirement must be met.
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| The purpose of CTS Surveillance 4.1.1.1.2 is to verify the core design by comparing the actual and predicted core reactivity. This change is acceptable because the requirements continue to ensure that the process variables are maintained in the MODES and other specified conditions assumed in the safety analysis and licensing basis. The core reactivity balance can only be determined when the reactor is critical (MODES 1 and 2). Reducing the applicable MODES from MODES 1, 2, 3, and 4 to MODES 1 and 2 does not result in a reduction of the verification of this measure of core design accuracy. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.
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| L02 (Category 4 - Relaxation of Required Action) CTS 3.1.1.1 does not contain ACTIONS to follow if the core reactivity balance Surveillance is not met. If the core reactivity balance Surveillance is not met, CTS LCO 3.0.3 would be entered.
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| CTS LCO 3.0.3 requires the plant to be in MODE 3 within 6 hours, MODE 4 within 12 hours, and MODE 5 within 24 hours. ITS 3.1.2 contains ACTIONS to follow if the core reactivity LCO is not met. If the LCO is not met, 7 days are provided to re-evaluate the core design and safety analysis, to determine that the reactor core is acceptable for continued operation, and to establish appropriate operating restrictions and SRs. If these actions are not completed within the 7 days, the plant must be placed in MODE 3 within 6 hours. This changes the CTS by providing 7 days to evaluate and provide compensatory measures for not meeting the core reactivity balance requirement and then requiring entry into MODE 3 instead of requiring an immediate shutdown and entry into MODE 5.
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| Turkey Point Unit 3 and Unit 4 Page 2 of 4
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| DISCUSSION OF CHANGES ITS 3.1.2, CORE REACTIVITY The purpose of CTS 4.1.1.1.2 is to verify the accuracy of the core design by comparing the predicted and actual core reactivity throughout core life. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to restore inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs, restore, or replacement of required features, and the low probability of a Design Basis Accident (DBA) occurring during the repair/restoration period. Should the core reactivity balance requirement not be met, time is required to determine the cause of the disagreement and what adjustments may be needed to the operating conditions of the core. The startup physics testing program is used to verify most of the critical core design parameters, such as control rods worth, boron worth, and moderator temperature coefficient. In addition, there is considerable conservatism in the application of these values in the accident analyses.
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| Therefore, allowing a time to evaluate the difference and make any adjustments to the operational controls is acceptable. The 7 day Completion time is reasonable considering the complexity of the evaluations and the time to meet administrative requirements, such as 10 CFR 50.59 safety evaluation preparation and approval. If it cannot be determined within 7 days that the core is acceptable for continued operation, the unit must be shutdown. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L03 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.1.1.1.2 requires comparison of the actual and predicted core reactivity balance and specifically requires consideration of at least those factors stated in Specification 4.1.1.1.1.e.
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| CTS 4.1.1.1.2 also requires the predicted reactivity values to be adjusted (normalized) to correspond to the actual core conditions prior to exceeding a fuel burnup of 60 EFPD after each fuel loading. ITS SR 3.1.2.1 requires verifying the measured core reactivity is within +/- 1 % k/k of the predicted core reactivity values once prior to entering MODE 1 after each refueling and in accordance with the Surveillance Frequency Control Program after 60 EFPD. This changes the CTS by allowing the initial verification to be performed in MODE 2.
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| The purpose of CTS 4.1.1.1.2 is to verify the agreement between the actual and predicted core reactivity. The CTS and ITS require the predicted core reactivity values to be normalized to the actual values prior to exceeding 60 EFPD of core burnup. This allows sufficient time for core conditions to reach steady state but prevents operation for a large fraction of the fuel cycle without establishing a benchmark for the design calculations. CTS 4.1.1.1.1.e Frequency has been changed to ensure core reactivity is within limits prior to entering MODE 1 after each refueling. This change has been designated as less restrictive because Surveillances will be performed in different MODES of operation under the ITS 3 than under the CTS.
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| L04 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
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| CTS 4.1.1.1.2 requires, in part, that the predicted reactivity values shall be adjusted (normalized) to correspond to the actual core conditions prior to Turkey Point Unit 3 and Unit 4 Page 3 of 4
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| Core Reactivity B 3.1.2 BASES SURVEILLANCE SR 3.1.2.1 REQUIREMENTS Core reactivity is verified by periodic comparisons of measured and predicted RCS boron concentrations. The comparison is made, considering that other core conditions are fixed or stable, including control rod position, moderator temperature, fuel temperature, fuel depletion, xenon concentration, and samarium concentration. The Surveillance is BOL performed prior to entering MODE 1 as an initial check on core conditions and design calculations at BOC. The SR is modified by a Note. The 1
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| , if required, Note indicates that the normalization of predicted core reactivity to the may DOC L03 must measured value must take place within the first 60 effective full power 5 days (EFPD) after each fuel loading. This allows sufficient time for core when measured values conditions to reach steady state, but prevents operation for a large are found to be less fraction of the fuel cycle without establishing a benchmark for the design conservative than the predicted values to the calculations. [ The required subsequent Frequency of 31 EFPD, following 3 specific time in core life the initial 60 EFPD after entering MODE 1, is acceptable, based on the slow rate of core changes due to fuel depletion and the presence of other indicators (QPTR, AFD, etc.) for prompt indication of an anomaly.
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| OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| 19 67 Atomic energy Commission Proposed General Design Criteria 27 , 28, 29 , 32, and 33 REFERENCES 1. 10 CFR 50, Appendix A, GDC 26, GDC 28, and GDC 29 . 1 U 14 1 3
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| : 2. FSAR, Chapter [15] .
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| : 3. UFSAR, Chapter 3.1.2 1 Turkey Point Unit 3 and Unit 4 Revision XXX WOG B 3.1.2-5 Rev. 5.0 1
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| JUSTIFICATION FOR DEVIATIONS ITS 3.1.2 BASES, CORE REACTIVITY
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| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 2. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
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| : 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 4. Editorial changes made for enhanced clarity/consistency.
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| : 5. Changes are made to be consistent with changes made to the Specification.
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| The ITS SR 3.1.2.1 Bases states core reactivity values "must" be adjusted prior to exceeding 60 EFPD while the actual ITS SR 3.1.2.1 Note states the values "may" be adjusted, since adjustments may not be necessary if the predicted values remain conservative to the actual values (thus maintaining the assumptions of the safety analyses). Therefore, a phrase is added to this Bases statement clarifying that adjustments are only required if measured values are found to be less conservative than the predicted values. This change coordinates the differences in the ITS SR 3.1.2.1 Note wording and the ITS SR 3.1.2.1 Bases wording, while ensure the safety analyses assumptions are maintained.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 7/7/22, 2:06 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1495 NRC Question CCH012 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/7/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/7/2022 12:34 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1495 1/1
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| 5/26/22, 2:40 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 719 NRC Question CCH013 Number Category Technical ITS 3.1 Section ITS 3.1.7 Number DOC L-2 Number JFD Number JFD Bases 3
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| Number Page 175 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC JFD 3.1.7-3 Question
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| : 1. On page 175 of 258 The markup of STS 3.1.7 Required Action B.2 is not consistent with the intent of Required Action B.2, which is to restore the unit to operation under Condition A. The last phrase of this Required Action should say one RPI per bank and not one RPI per group. Following is the suggested revised markup of the STS 3.1.7 ACTION B on page 175:
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| B. More than one [ D] RPI per group bank inoperable in one or more groups banks. l B.1 Place the control rods under manual control. l Immediately AND B.2 Restore inoperable [ D] RPIs to OPERABLE status such that a maximum of one [ D] RPI per group bank is inoperable. l 24 hours The associated DOC 3.1.7-L02 for adding the allowance of ITS 3.1.7 ACTION B, in the first paragraph, also says per group instead of per bank. The licensee is requested to correct this error.
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| : 2. On page 175 of 258 The markup of STS 3.1.7 Condition C replaces one or more groups with one or more bank; this should be one or more banks.
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| Attach File 1
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| Attach File 2
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| https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=719 1/2
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| 5/26/22, 2:40 PM Turkey Point ITS Conversion Database Issue Date 5/26/2022 Added By Craig Harbuck Date Modified Modified By Date 5/26/2022 1:38 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=719 2/2
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| 8/3/22, 5:51 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1291 NRC Question CCH013 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response 1. In response to NRC request for additional information (RAI) CCH008, the terms "bank" or "banks" in the Statement Conditions and Required Actions of ITS 3.1.7 ACTIONS A, B, and C were replaced with the terms "group" or "groups", respectively. Therefore, no further change is necessary with respect to Condition B and Required Action B.1. Please see response and associated license amendment request (LAR) markups of RAI CCH008.
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| : 2. "Bank" in ITS 3.1.7, Condition C, will be replaced with "groups" in response to RAI CCH008; therefore, no further change to ITS 3.1.7, Condition C, is necessary. Please see response and associated LAR markups of RAI CCH008.
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| ===Response===
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| 6/24/2022 3:20 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 6/24/2022 2:20 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1291 1/1
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| 7/7/22, 2:05 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1491 NRC Question CCH013 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/7/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/7/2022 12:24 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1491 1/1
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| 5/26/22, 3:00 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 723 NRC Question CCH014 Number Category Technical ITS 3.1 Section ITS 3.1.7 Number DOC A-1 Number JFD 3
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| Number JFD Bases 3
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| Number Page 163 174 183 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC JFD 3.1.7-3 page 174 of 258 Question Proposed second Completion Time of ITS LCO 3.1.7 Required Action A.1 is based on retaining CTS 3.1.3.2 Action a.1. This plant-specific departure from STS 3.1.7 is improperly phrased. The licensee is requested to change it as shown below, because an inoperable RPI does not render the associated rod inoperable:
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| A. One RPI per bank inoperable in one or more banks. l A.1 Verify the position of the rods with inoperable RPI indirectly by using movable incore detectors. l Once per 8 hours AND Wwithin one hour after any motion of the inoperable a rod with inoperable RPI that which exceeds 24 steps in one direction since the last determination of the rods position The licensee is also requested to correct the first sentence of the Bases for 3.1.7 Required Actions A.1 and A.2 by changing in one or more groups to in one or more banks on page 183.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/26/2022 Added By Craig Harbuck Date Modified Modified By Date 5/26/2022 1:57 PM https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=723 1/2
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| 5/26/22, 3:00 PM Turkey Point ITS Conversion Database Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=723 2/2
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| 8/3/22, 5:25 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1634 NRC Question CCH014 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response The second Completion Time of ITS 3.1.7, Required Action A.1, is being deleted in response to NRC request Statement for additional information (RAI) CCH009. Therefore, no further changes associated with this Completion Time are required. Please see response and associated LAR markups of RAI CCH009.
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| With respect to the ITS 3.1.7 Bases, the terms "bank" or "banks" in the Conditions and Required Actions (and associated Bases) of ITS 3.1.7 ACTIONS A, B, and C were replaced with the terms "group" or "groups", respectively, in response to RAI CCH008. Therefore, the phrase "in one or more groups" contained in the Bases of ITS 3.1.7, Required Actions A.1 and A.2, is not changed. Please see response and associated LAR markups of RAI CCH008.
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| ===Response===
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| 7/21/2022 1:45 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/21/2022 12:45 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1634 1/1
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| 7/29/22, 10:20 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1682 NRC Question CCH014 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/28/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/28/2022 3:04 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1682 1/1
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| 5/26/22, 3:26 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 727 NRC Question CCH015 Number Category Technical ITS 3.1 Section ITS 3.1.7 Number DOC LA-3 Number JFD Number JFD Bases Number Page 163, 168, 169, 171, 174 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.1.7 - pages 163, 168, 169, 171, and 174 of 258 - ITS 3.1.7, Rod Position Indication Question The markup of CTS 3.1.3.2.a, after first applying STS LCO statement formatting, states, in part:
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| LCO 3.1.7 3.1.3.2 The Analog Rod Position Indication (RPI) System and the Demand Position Indication System shall be OPERABLE.
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| and capable of determining the respective actual and demanded shutdown and control rod positions as follows:
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| : a. Analog rod position indicators, within one hour after rod motion (allowance for thermal soak); ....
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| All Shutdown Banks: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.
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| Control Bank A and B: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal ranges of 0-30 steps and 200-All Rods Out as defined in the Core Operating Limits Report.
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| Control Banks C and D: within the Allowed Rod Misalignment of Specification 3.1.3.1 of the group demand counters for withdrawal range of 0-All Rods Out as defined in the Core Operating Limits Report.
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| : b. Group demand counters; +/- 2 steps.
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| ------------------------------------------NOTE--------------------------------------------
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| Individual RPIs are not required to be OPERABLE for 1 hour following movement of the associated rods.
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| The CTS markup indicates that all deleted text is addressed by DOC 3.1.7-LA01 as system design details being relocated to the Bases; it says these are details of what constitutes an OPERABLE system. The licensee is requested to explain which Bases passages, presumably in ITS Bases for Subsections 3.1.4, 3.1.5, 3.1.6, and 3.1.7 contain the information being relocated, because it does not appear to be in those Bases subsections in the STS Bases markups for ITS Section 3.1.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/26/2022 Added By Craig Harbuck https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=727 1/2
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| 5/26/22, 3:26 PM Turkey Point ITS Conversion Database Date Modified Modified By Date 5/26/2022 2:12 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=727 2/2
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| 8/3/22, 5:48 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1403 NRC Question CCH015 Number Select Licensee Response Application Attachment Attachment 1 - CCH015 LAR Markups.pdf (630KB) 1 Attachment 2
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| Response FPL will revise the ITS 3.1.7 Limiting Condition for Operation (LCO) Bases to include the information Statement proposed for relocation from CTS LCO 3.1.3.2. See attached CCH015 license amendment request (LAR) markups.
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| Attachment
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| : 1. CCH015 LAR Markups
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| ===Response===
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| 7/1/2022 12:20 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/1/2022 11:21 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1403 1/1
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| Rod Position Indication B 3.1.7 BASES LCO LCO 3.1.7 specifies that one [D] RPI System and one Bank Demand 2 Position Indication System be OPERABLE for each control rod. For the 1 control rod position indicators to be OPERABLE requires meeting the SR 5 of the LCO and the following:
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| 2
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| : a. The [D] RPI System indicates within 12 steps of the group step counter demand position as required by LCO 3.1.4, "Rod Group Alignment Limits,"
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| : d. RPI capable of indicating rod position for shutdown banks and control banks A and B 2 between a Demand Position Indication b. For the [D] RPI System there are no failed coils, and System indicated position of 0 and 30 steps Position withdrawn inclusive and between 200 steps 1 4 withdrawn and all-rods-out (ARO) inclusive.
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| : c. The Bank Demand Indication System has been calibrated either in 2
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| This permits the operator to verify that the the fully inserted position or to the [D] RPI System.
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| control rods in these banks are either fully withdrawn or fully inserted, the normal operating modes for these banks.
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| The 12 step agreement limit between the Bank Demand Position 1 Indication System and the [D] RPI System indicates that the Bank 2
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| : e. RPI capable of indicating rod position for Demand Position Indication System is adequately calibrated, and can be control banks C and D, between a Demand used for indication of the measurement of control rod bank position.
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| Position Indication System indicated position of 0 steps withdrawn and All Rods Out (ARO) inclusive. A deviation of less than the allowable limit, given in LCO 3.1.4, in position indication for a single control rod, ensures high confidence that the
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| : f. Demand Position Indication System capable of indicating rod position within +/- 2 position uncertainty of the corresponding control rod group is within the steps. assumed values used in the analysis (that specified control rod group insertion limits).
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| These requirements ensure that control rod position indication during power operation and PHYSICS TESTS is accurate, and that design assumptions are not challenged.
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| OPERABILITY of the position indicator channels ensures that inoperable, misaligned, or mispositioned control rods can be detected. Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.
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| ---------------------------------- Reviewer's Note ----------------------------------------
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| The bracketed LCO Note is only applicable to plants with an analog rod 6 position indication system.
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| [The LCO is modified by a Note stating that the RPI system is not 2
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| required to be met OPERABLE for 1 hour following movement of the associated rods. Control and shutdown rod temperature affects the accuracy of the RPI System. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows temperature to stabilize following rod movement in order to ensure the indicated position is accurate.]
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7 -3 Rev. 5.0 1
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| 7/12/22, 8:26 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1546 NRC Question CCH015 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/11/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/11/2022 7:51 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1546 1/1
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| 6/2/22, 4:05 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 751 NRC Question CCH016 Number Category Technical ITS 3.2 Section ITS 3.2.2 Number DOC Number JFD Number JFD Bases 1
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| Number Page 76 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC JFD B 3.2.2-1. On PDF page 76 of 136, the markup of STS 3.2.2 Bases for Required Question Action A.1.1, last paragraph, discusses Required Action A.3. In the first sentence, the markup changes the following phrase, as shown: ...Required Action A.3 requires that another determination of FNH must be done verified prior to exceeding
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| ... The staff finds the proposed change is not clear in that it seems to say the action is to verify a determination of FNH, which is not the intent.
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| Since the licensee is proposing to depart from the STS Bases phrasing, apparently to improve clarity, the staff suggests that the licensee change this STS phrase to say: ...Required Action A.3 requires that another verification determination of that FNH is within limits must be done prior to exceeding ... This suggested edit more clearly conveys the intended meaning of the sentence, consistent with the statement of ITS SR 3.2.2.1.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/2/2022 Added By Craig Harbuck Date Modified Modified By Date 6/2/2022 2:05 PM Added Notification Gregg Ellis https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=751 1/2
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| 6/2/22, 4:05 PM Turkey Point ITS Conversion Database Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=751 2/2
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| 8/11/22, 10:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1295 NRC Question CCH016 Number Select Licensee Response Application Attachment 1 Attachment 1 - CCH016 LAR Markups.pdf (1MB)
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| Attachment 2 Response FPL will revise the subject ITS 3.2.2 Bases wording as suggested. See attached CCH016 license Statement amendment request (LAR) markups.
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| Attachment
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| : 1. CCH016 LAR Markups
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| | |
| ===Response===
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| 6/24/2022 3:25 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 6/24/2022 2:23 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1295 1/1
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| F N H B 3.2.2 BASES ACTIONS A.1.1 With F N H ex ceeding its limit, the unit is allow ed 4 hours to restore F N H to within its limits. This restoration may , f or ex ample, inv olve realigning any misaligned rods or reducing pow er enough to b ring F N H within its pow er dependent limit. W hen the F N H limit is exceeded, the DNBR limit is not likely v iolated in steady state operation, b ecause ev ents that could significantly perturb the F N H value ( e.g., static control rod misalignment) are considered in the saf ety analyses. H ow ev er, the DNBR limit may b e violated if a DNB limiting ev ent occurs. Thus, the allow ed Completion Time of 4 hours prov ides an acceptable time to restore F N H to w ithin its limits w ithout allow ing the plant to remain in an unacceptab le condition f or an ex tended period of time.
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| Condition A is modified by a Note that requires that Required Actions A.2 and A.3 must b e completed w henev er Condition A is entered. Thus, if pow er is not reduced b ecause this Required Action is completed w ithin the 4 hour time period, Required Action A.2 nev ertheless requires another measurement and calculation of F N H within 24 hours in accordance w ith SR 3.2.2.1. verification that is within limits How ev er, if pow er is reduced b elow 50% RTP, Required Action A.3 verified requires that another determination of F N H must b e done prior to 1 ex ceeding 5 0% RTP, prior to ex ceeding 7 5% RTP, and w ithin 24 hours af ter reaching or ex ceeding 9 5% RTP. In addition, Required Action A.2 is performed if pow er ascension is delayed past 24 hours.
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| A.1.2.1 and A.1.2.2 If the v alue of F N H is not restored to w ithin its specified limit either b y adj usting a misaligned rod or b y reducing TH ERMAL POWER, the alternative option is to reduce TH ERMAL POWER to < 50% RTP in accordance with Required Action A.1.2.1 and reduce the Pow er Range Neutron F lux - High to 55% RTP in accordance w ith Required Action A.1.2.2. Reducing RTP to < 50% RTP increases the DNB margin and does not likely cause the DNBR limit to b e v iolated in steady state operation. The reduction in trip setpoints ensures that continuing operation remains at an acceptab le low pow er lev el w ith adequate DNBR margin. The allow ed Completion Time of 4 hours f or Required Action A.1.2.1 is consistent w ith those allow ed f or in Required Action A.1.1 and prov ides an acceptab le time to reach the required pow er lev el f rom f ull pow er operation w ithout allow ing the plant to remain in an unacceptab le condition f or an ex tended period of time. The Completion Times of 4 hours f or Required Actions A.1.1 and A.1.2.1 are not additive.
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| Turkey Point U nit 3 and U nit 4 Rev ision XXX Westinghouse STS B 3.2.2-4 Rev . 5.0 1
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| 7/1/22, 10:04 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1395 NRC Question CCH016 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/30/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 6/30/2022 4:50 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1395 1/1
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| 6/2/22, 4:05 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 755 NRC Question CCH017 Number Category Technical ITS 3.2 Section ITS 3.2.3 Number DOC Number JFD Number JFD Bases 2
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| Number Page 99, 104 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.2.3 - page 99 of 136 - ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
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| Question
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| : 1. JFD B 3.2.3-2 states:
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| Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description."
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| The markup of the Applicable Safety Analyses (ASA) section of the Bases for STS 3.2.3, fourth paragraph shows omission of STS Bases content in the ITS Bases, as shown:
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| The limits on the AFD ensure that the Heat Flux Hot Channel is not exceeded during either normal operation or in the event of xenon redistribution following power changes. The limits on the AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition 2, 3, or 4 events. This ensures that the fuel cladding integrity is maintained for these postulated accidents. The most important Condition 4 event is the LOCA. The most important Condition 3 event is the loss of flow accident. The most important Condition 2 events are uncontrolled bank withdrawal and boration or dilution accidents. Condition 2 accidents simulated to begin from within the AFD limits are used to confirm the adequacy of the Overpower T and Overtemperature T trip setpoints.
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| The reasons given in the JFD B 3.2.3-2 for this departure from NUREG-1431, Volume 2, do not explain why the lined-out text is not appropriate for Turkey Point Units 3 and 4; specifically, the licensee is asked to replace this STS Bases passage with a version that lists the most important plant-specific postulated Condition 2, 3, and 4 events, in the ITS 3.2.3 Bases ASA section.
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| : 2. On pages 97 and 98, in the markup of the Background section of the Bases for STS 3.2.3, Insert 1 says that the target band for Base Load operation is defined in the ... Peaking Factor Limit Report. The licensee is requested to describe in a Bases JFD the Peaking Factor Limit Report, its change control, and its relationship to the COLR AFD limits required to be met by ITS LCO 3.2.3. Consider whether the ITS 3.2.3 Bases should include a reference to the Peaking Factor Limit Report.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/2/2022 Added By Craig Harbuck Date Modified Modified https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=755 1/2
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| 6/2/22, 4:05 PM Turkey Point ITS Conversion Database By Date 6/2/2022 2:12 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=755 2/2
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| 8/3/22, 5:49 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1431 NRC Question CCH017 Number Select Licensee Response Application Attachment Attachment 1 - CCH017 LAR Markups(2) EA.pdf (1MB) 1 Attachment 2
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| Response 1. FPL will add Justification for Deviation (JFD) 8 to justify the deleted portion from the fourth paragraph Statement in the ASA Section of the ITS 3.2.3 Bases Markup. See Attachment 1 - CCH017 LAR Markups.
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| : 2. The information in the Peaking Factor Limit Report is located in the Core Operating Limits Report (COLR). Therefore, any reference to the Peaking Factor Limits Report will now reference the COLR. The Bases Insert and the Discussion of Changes have been revised to delete reference to the Peaking Factor Limit Report, as appropriate. See Attachment 1 - CCH017 LAR Markups.
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| Attachment
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| : 1. CCH017 - LAR Markups
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| ===Response===
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| 7/5/2022 10:45 AM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/5/2022 9:47 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1431 1/1
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| DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
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| ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS).
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 CTS 3.2.1 states the Axial Flux Difference (AFD) "shall be maintained within:
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| : a. the allowed Relaxed Axial Offset Control (RAOC) operational space as defined in the CORE OPERATING LIMITS REPORT (COLR), or b. within a +/- 2% or
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| +/- 3% target band about the target flux difference during Base Load operation."
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| CTS 3.2.1 ACTION provides ACTIONs to take when the indicated AFD is outside the COLR limits or Peaking Factor Limit Report. CTS 4.2.1.1 requires a determination that the indicated AFD is within limits. CTS 4.2.1.2 requires a determination that the indicated AFD is within limits. CTS 3.2.1 ACTION states that the indicated AFD shall be considered outside the limits when at least two OPERABLE excore channels are indicating the AFD to be outside the limits. ITS Limiting Condition for Operation (LCO) 3.2.3 states in part the AFD in % flux difference units shall be maintained within the limits specified in the COLR and Peaking Factor Limit Report. ITS LCO 3.2.3 is modified by a Note specifying when AFD is considered to be outside the limits. ITS Surveillance Requirement (SR) 3.2.3.1 and ITS SR 3.2.3.2 require verification that AFD is within limits. This changes the CTS by deleting "indicated" and adding "% flux difference units" to the LCO statement.
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| The purpose of CTS 3.2.1 is to ensure the AFD remains within the limits specified in the COLR and Peaking Factor Limit Report. AFD is the difference in normalized flux signals between the top and bottom excore detectors, therefore, this is a presentation change. This change is designated as administrative because it does not result in a technical change to the CTS.
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| A03 CTS 3.2.1 Applicability contains a footnote (footnote *) which states, "See Special Test Exception 3.10.2." ITS 3.2.3 Applicability does not contain this footnote. This changes the CTS by not including Footnote*.
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| The purpose of Footnote
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| * is to alert the Technical Specification user that a Special Test Exception exists that may modify the Applicability of this Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative because it does not result in a technical change to the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 6
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| DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
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| A04 CTS 3.2.1 ACTION c states "THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD is within the limits specified in the COLR." ITS 3.2.3 does not contain a similar requirement. This changes the CTS by eliminating a prohibition contained in the CTS.
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| This change is acceptable because deletion of the specific requirement to not exceed 50% when the AFD is not within limits is prohibited via CTS 3.0.4 and ITS LCO 3.0.4. These requirements prohibit entering the Applicability of a Technical Specification unless certain requirements of the LCO are met. These requirements are as follows: the Actions to be entered permit continued operation, risk assessment addressing inoperable systems and components show acceptable risk results, or an allowance is stated in the individual value, parameter, or other specification. In this case, none of the exceptions for entering the Applicability applies. CTS 3.2.1 and ITS LCO 3.2.3 are applicable in MODE 1 with THERMAL POWER > 50% RATED THERMAL POWER (RTP) and 50 RTP (ITS). Therefore, both the CTS and ITS prohibit exceeding 50% RTP without the LCO requirements being met. This change is designated as an administrative change because it does not result in technical changes to the CTS.
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| A05 CTS Action b.2 requires THERMAL POWER to reduced to less than PT within 30 minutes and Base Load operation to be discontinued within 30 minutes. ITS ACTION A requires THERMAL POWER to be reduced to less than PT within 30 minutes (A.1) OR Base Load operation to be discontinued within 30 minutes (A.2). This changes the CTS by changing the conjunction between the two Actions from "and" to "OR."
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| This change is acceptable because if THERMAL POWER is reduced to less than PT within 30 minutes the Condition on longer applies, thus the Condition no longer applies. The same goes if base load operation is discontinued, the Condition no longer applies. Therefore, the current "and" conjunction is essentially an "OR" because if either ACTION is performed the condition no longer applies. This change is designated as administrative because no technical change is being made to the CTS.
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| MORE RESTRICTIVE CHANGES M01 CTS 3.2.1 is applicable in MODE 1 with THERMAL POWER > 50% RTP. ITS LCO 3.2.3 is applicable in MODE 1 with THERMAL POWER 50% RTP. This changes the CTS by requiring LCO 3.2.3 to be met when THERMAL POWER is equal to 50 % RTP.
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| The purpose of CTS 3.2.1 is to maintain the AFD within the limits specified in the COLR and Peaking Factor Limit Report. When AFD is not within limits, CTS 3.2.1 ACTION a.2 requires reducing THERMAL POWER to less than 50%
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| RTP, or CTS 3.2.1 ACTION b.2 requires reducing THERMAL POWER to less than PT and discontinue Base Load operation. This change is acceptable because it aligns the Applicability to the Required Actions. The CTS and ITS Turkey Point Unit 3 and Unit 4 Page 2 of 6
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| DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
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| LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.2.1 ACTION a.1 and ACTION b.1 requires with the AXIAL FLUX DIFFERENCE (AFD) outside of the limits, to restore the indicated AFD to within the limits within 15 minutes. ITS LCO 3.2.3 does not include a Required Action to restore the indicated AFD to within the limits within 15 minutes. This changes the CTS by not including a specific requirement to restore the AFD to within limits.
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| The purpose of CTS 3.2.1 is to maintain the AFD within the limits specified in the COLR or Peaking Factor Limit Report. This change is acceptable because the requirement to restore the AFD to within limits has not changed. ITS LCO 3.2.3 allows a Completion Time of 30 minutes to reduce THERMAL POWER to < 50%
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| RTP or to reduce THERMAL POWER to less than PT and discontinue Base Load operation. During the time that power is being reduced, AFD can be restored to within limits. Per ITS LCO 3.0.2, if the LCO is met prior to expiration of the Completion Time, completion of the Required Actions is not required. This allowance also is provided in CTS 3.0.2. Therefore, restoration of AFD is always an option and a specific ACTION is not required. This change is designated as less restrictive because additional Completion Time is provided that was not provided in the CTS.
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| L02 (Category 4 - Relaxation of Required Action) CTS 3.2.1 ACTION a.2 states that with the indicated AFD outside of the limits specified in the COLR, reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55 percent of RATED THERMAL POWER within the next 4 hours. ITS LCO 3.2.3 ACTION A only requires THERMAL POWER to be reduced to less than 50% RTP. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux - High trip setpoints to 55 % of RTP within the next 4 hours.
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| The purpose of CTS 3.2.1 ACTION a.2 is to reduce THERMAL POWER to the point at which the LCO is met if AFD is not restored within its limit. With the AFD meeting the Technical Specification requirements, further actions are not required to ensure that the assumptions of the safety analyses are met.
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| Increases in THERMAL POWER are governed by ITS LCO 3.0.4, which requires the LCO to be met prior to entering a MODE or other specified condition in which the LCO applies, except under certain conditions. Therefore, power increases are prohibited while avoiding the risk of changing Reactor Trip System setpoints during operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L03 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.2.1.1.a requires the monitoring of the indicated AFD for each OPERABLE excore channel in accordance with the Surveillance Frequency Control Program when the alarm used to monitor the AFD is OPERABLE. CTS 4.2.1.1.b requires the monitoring and logging the indicated AFD for each OPERABLE excore channel at least once Turkey Point Unit 3 and Unit 4 Page 5 of 6
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| B 3.2.3 7
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| INSERT 1 PT is the Reactor Power at which predicted FQ would exceed its limit. At power level below PT, the limits on AFD are specified in the COLR for RAOC operation. These limits were calculated in a manner such that expected operational transients, e.g., load follow operations, would not result in the AFD deviating outside of those limits. However, in the event that such a deviation occurs, a 15 minute period of time allowed outside of the AFD limits at reduced power levels will not result in significant xenon redistribution such that the envelope of peaking factors would change sufficiently to prevent operation in the vicinity of the power level.
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| With PT greater than 100%, two modes are permissible: 1) RAOC with fixed AFD limits as a function of reactor power level, and 2) Base Load operation which is defined as the maintenance of the AFD within a band about a target value. Both the fixed AFD limits for RAOC operation and the target band for Base Load operation are defined in the COLR and the Peaking Factor Limit Report, respectively. However, it is possible during extended load following maneuvers that the AFD limits may result in restrictions in the maximum allowed power or AFD in order to guarantee operation with FQ(Z) less than its limiting value. Therefore, PT is calculated to be less than 100%. To allow operation at the maximum permissible value above PT Base Load operation restricts the indicated AFD to a relative small target band and power swings. For Base Load operation, it is expected that the plant will operate within the target band.
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| Operation outside of the target band for the short time period allowed (15 minutes) will not result in significant xenon redistribution such that the envelope of peaking factors will change sufficiently to prohibit continued operation in the power region defined above. To assure that there is no residual xenon redistribution impact from past operation on the Base Load operation, a 24-hour waiting period within a defined range of PT and AFD allowed by RAOC is necessary.
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| During this period, load changes and rod motion are restricted to that allowed by the Base Load requirement. After the waiting period, extended Base Load operation is permissible.
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| A target flux difference can be updated by linear interpolation between the most recently measured value and the predicted value at the end of cycle life.
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| Insert Page B 3.2.3-1
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| AFD (RAOC Methodology) 1 B 3.2.3B BASES APPLICABLE The AFD is a measure of the axial power distribution skewing to either the SAFETY top or bottom half of the core. The AFD is sensitive to many core related ANALYSES parameters such as control bank positions, core power level, axial burnup, axial xenon distribution, and, to a lesser extent, reactor coolant temperature and boron concentration.
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| The allowed range of the AFD is used in the nuclear design process to confirm that operation within these limits produces core peaking factors and axial power distributions that meet safety analysis requirements.
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| The RAOC methodology (Ref. 3) establishes a xenon distribution library with tentatively wide AFD limits. One dimensional axial power distribution calculations are then performed to demonstrate that normal operation power shapes are acceptable for the LOCA and loss of flow accident, and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requirements.
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| The limits on the AFD ensure that the Heat Flux Hot Channel Factor (FQ(Z)) is not exceeded during either normal operation or in the event of 8
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| xenon redistribution following power changes. The limits on the AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition 2, 3, or 4 events. This ensures that the fuel cladding integrity is maintained for these postulated accidents. The most important Condition 4 event is the LOCA. The most important Condition 3 2 event is the loss of flow accident. The most important Condition 2 events are uncontrolled bank withdrawal and boration or dilution accidents.
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| , Condition 2 accidents simulated to begin from within the AFD limits are 6 used to confirm the adequacy of the Overpower T and Overtemperature T trip setpoints.
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| The limits on the AFD satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).
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| LCO The shape of the power profile in the axial (i.e., the vertical) direction is largely under the control of the operator through the manual operation of the control banks or automatic motion of control banks. The automatic motion of the control banks is in response to temperature deviations resulting from manual operation of the Chemical and Volume Control System to change boron concentration or from power level changes.
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| 1 and 2 Signals are available to the operator from the Nuclear Instrumentation System (NIS) excore neutron detectors (Ref. 3). Separate signals are 6 2 s
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| taken from the top and bottom detectors. The AFD is defined as the difference in normalized flux signals between the top and bottom excore detectors in each detector well. For convenience, this flux difference is converted to provide flux difference units expressed as a percentage and labeled as % flux or %I.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.2.3B-2 Rev. 5.0 2 1
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| JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, AXIAL FLUX DIFFERENCE (AFD)
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| : 1. The type of Methodology (Relaxed Axial Offset Control (RAOC)) and the Specification designator "B" are deleted since they are unnecessary (only one AFD Specification is used in the Turkey Point Nuclear Generating Station (PTN) Plant Improved Technical Specifications (ITS)). This information is provided in NUREG-1431, Rev. 5.0, to assist in indentifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Constant Axial Offset Control (CAOC) methodology Specification (Improved Standard Technical Specification (ISTS)
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| B 3.2.3A) is not used and is not shown. Note: Some RAOC shown to be consistent with CTS bases.
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| : 2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
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| : 5. ISTS 3.2.3 Bases contains Figure B 3.2.3B-1. This Figure is located in the Turkey Point Nuclear Generating Station (PTN) Core Operating Limits Report (COLR).
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| Therefore, this figure is not included in the Bases for ITS 3.2.3.
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| : 6. Editorial changes made to enhance clarity/consistency.
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| : 7. Changes are made to be consistent with changes made to the Specification.
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| : 8. The safety analysis models the Axial Flux Difference (AFD) based on the methodology associated with that particular event. These analyses do not include sensitivities using varying AFD inputs, and each safety analysis has varying margins to the acceptance criteria.
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| Determining a single event that would be the limiting event for each event classification (i.e., the group of events that fall within Condition 2, 3, and 4 event categories) could lead to a limited evaluation should an operability issue arise. If an operability issue arose, all of the events need to be evaluated relative to the plant condition and each safety analysis. As such, the proposed bases markup includes the discussion regarding the Condition 24 events but removes listing the most important events for each category.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 7/11/22, 3:17 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1530 NRC Question CCH017 Number Select NRC Question Closure Application Attachment 1
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| Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed; the Safety Evaluation should include an implementation followup inspection item to Statement verify that the post improved TS implementation COLR explicitly addresses/references the post improved TS implementation Peaking Factor Limit Report for all associated parameter limits.
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| Question Closure 7/11/2022 Date Notification Victor Cusumano Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Craig Harbuck Date 7/11/2022 2:16 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1530 1/1
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| 6/2/22, 4:06 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 759 NRC Question CCH018 Number Category Technical ITS 3.2 Section ITS 3.2.4 Number DOC L-3 Number JFD Number JFD Bases 5
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| Number Page 116, 117, 118, 119, and 132 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.2.4 - pages 116, 117, 118, 119, and 132 of 136 - ITS 3.2.4, QPTR Question
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| : 1. Pages 116-117 - DOC 3.2.4-L03 does not explicitly state that (after having had to reduce THERMAL POWER below 50% RTP because QPTR was not restored to within limits within 24 hours) the CTS 3.2.4 ACTION a.3 requirement, to reduce the Power Range Neutron Flux - High Functions reactor [nominal] trip setpoint to 55% RTP, is being deleted; neither does it state why this deletion is acceptable by explaining why this setpoint reduction is not needed to ensure reactor power is not inadvertently increased (above 50% RTP) without QPTR within its limit. Please revise the DOC 3.2.4-L03 by adding justification for the deletion of this action requirement.
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| : 2. Page 117 - DOC 3.2.4-L03 repeatedly indicates measuring FQL(Z) to verify it is within limits, which is incorrect because FQL(Z) is a limiting value of FQ(Z) specified in the COLR. Please consider changing FQL(Z) to FQ(Z).
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| : 3. Page 118 - DOC 3.2.4-L05 is incorrectly categorized as relaxation of Surveillance acceptance criteria, when they actually relax Surveillance performance methods. Please consider changing the category.
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| : 4. Page 118 and 119 - DOC 3.2.4-L06 and -L07 are incorrectly categorized as relaxation of Surveillance acceptance criteria, when they actually relax the Frequency. Please consider changing the category.
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| : 5. Page 132 - JFD B 3.2.4-5 addresses typo correction in markup of STS Bases for SR 3.2.4.1, last paragraph, which states, For those causes of QPTR that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core power tilt.
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| The opening phrase seems to be missing a word, such as QPTR deviations or QPTR changes; please revise the sentence to clarify the intended meaning.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/2/2022 Added By Craig Harbuck Date Modified https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=759 1/2
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| 6/2/22, 4:06 PM Turkey Point ITS Conversion Database Modified By Date 6/2/2022 2:22 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=759 2/2
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| 8/3/22, 5:38 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1475 NRC Question CCH018 Number Select Licensee Response Application Attachment Attachment 1 - CCH018 ITS 3.2.4 LAR Markups.pdf (2MB) 1 Attachment Attachment 2 - CCH018 ITS 3.3.1 LAR Markups.pdf (2MB) 2
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| ===Response===
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| Statement 1. FPL will revise Discussion of Change (DOC) L03 to address the proposed deletion of requirements to reduce the Power Range Neutron Flux - High Functions reactor [nominal] trip setpoint from CTS 3.2.4, Actions a.3 and b.3. See attached CCH018 ITS 3.2.4 license amendment request (LAR) markups.
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| : 2. FPL will revise ITS 3.2.4, DOC L03, to replace FQL(Z) with FQ(Z). See attached CCH018 ITS 3.2.4 LAR markups.
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| : 3. Enclosure 1 of the PTN LAR lists nine different less restrictive change categories. The list does not include a category using terms associated with a surveillance performance method. Therefore, FPL has designated ITS 3.2.4, DOC L05, as "Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria," because the proposed methods of ITS Surveillance Requirement (SR) 3.2.4.1 performance result in a change to the acceptable criteria for meeting the SR. Based on this conclusion, no change is proposed to the categorization of ITS 3.2.4, DOC L05, at this time.
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| : 4. FPL will revise the category for ITS 3.2.4, DOCs L06 and L07 (relabeled as DOCs L05 and L06, respectively, discussed below), to be associated with "Category 7 - Relaxation of Surveillance Frequency." See attached CCH018 ITS 3.2.4 LAR markups.
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| : 5. FPL will revise the ITS SR 3.2.4.1 Bases markup to state "QPTR deviations". See attached CCH018 ITS 3.2.4 LAR markups.
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| In addition to the changes above, the DOC references on CTS page 3/4 2-13 and ITS pages 3.2.4-3 and 3.2.4-4 are revised to correctly align with the appropriate ITS 3.2.4 DOC, and the option of using the incore thermocouple map contained in CTS Surveillance 4.2.4.2 is restored as new ITS 3.4.2, SR 3.2.4.3 and associated Note 1. The incore thermocouple map receives temperature input from the core exit thermocouples (CETs) and QPTR is calculated based on the core thermal map results of the CETs when one Power Range Neutron Flux channel is inoperable. The incore thermocouple map results are compared to the QPTR calculated using three OPERABLE Power Range Neutron Flux channels. Since one excore detector is inoperable such that the core flux in one core quadrant cannot be determined, this comparison is used to verify the indicated QPTR is consistent with the incore thermocouple map results, thereby confirming periodically that QPTR is within limits. With the addition of ITS 3.2.4, SR 3.2.4.3, a new Bases is also included associated with the SR. The addition of ITS 3.2.4, SR 3.2.4.3, requires changes to the ITS 3.2.4 CTS markups, DOC LA01, ITS markup, and ITS Bases markup. See attached CCH018 LAR markups.
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| A second Note is added to ITS 3.2.4, SR 3.2.4.3, stating that the SR is not required to be performed until 12 hours after input from one Power Range Neutron Flux channel is inoperable with THERMAL POWER > 75%
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| RATED THERMAL POWER (RTP). This Note is not contained in the CTS and, therefore, a new DOC L08 is included to justify the addition of this Note.
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| Maintaining the CTS option associated with the use of the incore thermocouple map in a separate ITS 3.2.4 SR requires a revision to ITS 3.3.1, "Reactor Trip System (RTS) Instrumentation," ACTION D. With one Power Range Neutron Flux - High channel inoperable, ITS 3.3.1, Condition D, is entered. ITS 3.3.1, Required Action D.2.2 requires performance of ITS 3.2.4, SR 3.2.4.2, when the Power Range Neutron Flux -
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| High input to QPTR is inoperable. Because the option of using the incore thermocouple map is now retained as new ITS 3.2.4, SR 3.2.4.3, it is necessary to add the option of performing SR 3.2.4.3 to ITS 3.3.1, Required Action D.2.2. Therefore, markups of affected ITS 3.3.1 pages are included in this response to the NRC's request for additional information (RAI). See attached CCH018 ITS 3.2.4 and ITS 3.3.1 LAR markups.
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| Attachments
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| : 1. CCH018 ITS 3.2.4 LAR Markups
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| : 2. CCH018 ITS 3.3.1 LAR Markups Response 7/6/2022 2:40 PM https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1475 1/2
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| 8/3/22, 5:38 PM Turkey Point ITS Conversion Database Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/6/2022 1:41 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1475 2/2
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| ITS A01 ITS 3.2.4 POWER DISTRIBUTION LIMITS LIMITING CONDITION FOR OPERATION (Continued)
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| ACTION (Continued)
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| : 2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 2 hours and reduce the Power Range Neutron Flux -High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the nex t 4 hours; and L03
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| : 3. Identify and correct the cause of the out-of -limit limit condition prior to increasing THERMAL TH ERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed prov ided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours or until verified at 95% or greater RATED THERMAL POWER.
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| L05 SU RVEILLANCE REQ UIREMENTS Add proposed SR 3.2.4.1 Notes 1 and 2 L06 SR 3.2.4.1 4.2.4.1 The QUADRANT POWER TILT RATIO shall be determined to be within the limit ab ov e 50% of RATED THERMAL POWER by: L06
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| : a. Calculating the ratio in accordance with the Surveillance Frequency Control Program when the L07 Pow er Range Upper Detector High Flux Dev iation and Pow er Range Low er Detector High Flux Dev iation Alarms are OPERABLE, and
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| : b. Calculating the ratio at least once per 12 hours during steady -state operation when either alarm is inoperab le. L07 Add proposed SR 3.2.4.2 Note L08 SR 3.2.4.2 4.2.4.2 The QUADRANT POWER TILT RATIO shall be determined to be within the limit when ab ov e 75% of SR 3.2.4.2 NOTE RATED THERMAL POWER with one Pow er Range channel inoperable by using the mov ab le incore SR 3.2.4.3 NOTE detectors to conf irm that the normalized symmetric power distribution, ob tained either from two sets of SR 3.2.4.1 LA01 SR 3.2.4.3 four symmetric thimb le locations or full-core flux map, or by incore thermocouple map is consistent with the indicated QUADRANT POWER TILT RATIO in accordance with the Surveillance Frequency Control Program.
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| add proposed SR 3.2.4.3 Note 2 L08 restore TURKEY POINT - UNITS 3 & 4 3/4 2-13 AMENDMENT NOS. 279 AND 274 Page 3 of 3
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| DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
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| MORE RESTRICTIVE CHANGES M01 CTS 3.2.4 ACTION a.2.b states in part, within 2 hours, reduce THERMAL POWER at least 3% from RTP for each 1% of indicated QPTR in excess of 1.00.
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| ITS 3.2.4 Required Action A.1 has a similar requirement to reduce THERMAL POWER 3% from RTP for each 1% of QPTR > 1.00. The Completion Time for ITS 3.2.4 Required Action A.1 is 2 hours after each QPTR determination. This changes the CTS by specifically requiring a power reduction, if applicable, after each QPTR determination.
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| The purpose CTS 3.2.4 ACTION a.2.b is to commence a power level reduction to ensure that core power distributions that violate fuel design criteria are minimized. The maximum allowable power level initially determined by ITS 3.2.4 Required Action A.1 may be affected by subsequent determinations of QPTR.
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| However, any increases in QPTR would require additional power reductions within 2 hours of each QPTR determination, if necessary to comply with the decreased maximum allowable power level. This change is designated as more restrictive because it adds required actions to the CTS.
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| RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.4.2 states, in part, that the QPTR shall be determined to be within the limit by using the movable incore detectors to confirm that the normalized symmetric power distribution, obtained either from two sets of four symmetric thimble locations or full-core flux map, or by incore thermocouple and SR 3.2.4.3 map is consistent with the indicated QPTR. ITS Surveillance Requirement (SR) 3.2.4.2 requires verifying QPTR is within limit using the movable incore detectors. This changes the CTS by moving the procedural details for meeting the Surveillance to the Bases. or by incore thermocouple map, respectively The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide protection of public health and safety. The ITS still retains the requirement that the QPTR is or incore thermocouple verified to be within the limits using the movable incore detectors. The details map relating to system design do not need to appear in the specification in order for the requirement to apply. Additionally, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| Turkey Point Unit 3 and Unit 4 Page 3 of 8
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| DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR) minimize risk associated with continued operation while provided time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. With THERMAL POWER reduced by 3% from RTP for each 1% QPTR is greater than 1.00, further actions are not required to ensure that THERMAL POWER is not increased.
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| Power increases are administratively prohibited by the Technical Specification while avoiding the risk of changing Reactor Trip System setpoints during operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L03 (Category 4 - Relaxation of Required Action) CTS 3.2.4 ACTION a.3 states "Verify that the QUADRANT POWER TILT RATIO is within its limit within 24 hours after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours and reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours." CTS 3.2.4 ACTION b.3 and b.4 contain the same compensatory actions as CTS ACTION a.3 but requires the QPTR to be within limits within 2 hours. CTS 3.2.4 ACTIONS a.4, b.4, and c.3 state "Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours or until verified acceptable at 95% or greater RATED THERMAL POWER." ITS 3.2.4 Required Action A.3 requires performance of SR 3.2.1.1, SR 3.2.1.2, SR 3.2.2.1 within 24 hours after achieving equilibrium conditions from a THERMAL POWER reduction per Required Action A.1 and once per 7 days thereafter. ITS 3.2.4 Required Action A.4 requires reevaluation of the safety analyses and confirmation that the results remain valid for duration of operation under this condition prior to increasing THERMAL POWER above the limit of Required Action A.1. ITS 3.2.4 Required Action A.5 requires normalization of excore detectors to restore QPTR to within limit prior to increasing THERMAL POWER above the limit of Required Action A.1. ITS 3.2.4 Required Action A.6 requires performance of SR 3.2.1.1, SR 3.2.1.2, SR 3.2.2.1, in accordance with the COLR, within 24 hours after achieving equilibrium conditions at RTP not to exceed 48 hours after increasing THERMAL POWER above the limit of Required Action A.1. Additionally, ITS 3.2.4 Required Action A.5 contains two Notes and ITS 3.2.4 Required Action A.6 contains one Note. ITS 3.2.4 Required Action A.5 Note 1 states "Perform Required Action A.5 only after Required Action A.4 is completed." ITS 3.2.4 Required Action A.5 Note 2 states "Required Action A.6 shall be completed whenever Required Action A.5 is performed." ITS 3.2.4 Required Action A.6 Note states "Perform Required Action A.6 only after Required Action A.5 is completed."
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| Furthermore, ITS 3.2.4 ACTION B states that with a Required Action and associated Completion Time (of Condition A) not met, reduce THERMAL POWER to 50% RTP within 4 hours. This changes the CTS by eliminating requirements to be 50% RTP within a specified time of exceeding the LCO and substituting compensatory measures in ITS 3.2.4 ACTION A, which if not met, results in a reduction in power per ITS 3.2.4 ACTION B.
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| In addition, the requirements to reduce the Power Range Neutron Flux - High trip setpoints within 4 hours after reducing power to 50% RTP is eliminated.
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| Turkey Point Unit 3 and Unit 4 Page 5 of 8
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| DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
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| The purpose of the CTS actions is to lower reactor power to less than 50% when QPTR is not within its limit and cannot be restored to within its limit within a reasonable time period. In addition, the Power Range Neutron Flux-High Trip setpoints are reduced to 55% to ensure that reactor power is not inadvertently increased without QPTR within its limit. This action is taken because with QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical parameters such as F LQ (Z) and FNH may not be within the associated limits. A QPTR not within limit may not be an unacceptable FQ(Z) condition if the critical core parameters such as F LQ (Z) and FNH are within the associated limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while provided time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required With respect to eliminating the features, the capacity and capability of remaining features, a reasonable time for requirements to repairs or replacement of required features, and the low probability of a DBA reduce the Power FQ(Z) occurring during the repair period. ITS 3.2.4 Required Action A.3 requires Range Neutron Flux -
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| High trip setpoints measurement of F LQ (Z) and FNH within 24 hours and every 7 days thereafter to within 4 hours after reducing power to verify that those parameters are within limit. In addition, ITS 3.2.4 Required 50% RTP, this action Action A.4 requires the safety analyses to be reevaluated to ensure that the is not necessary because the unit has results remain valid. Assuming that these actions are successful, ITS 3.2.4 been removed from allows indefinite operation with QPTR out of its limit and allows the excore the mode of nuclear detectors to be normalized to eliminate the indicated QPTR. This applicability.
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| Increases in ensures the core is operated within the safety analyses. This change is THERMAL POWER designated as less restrictive because less stringent Required Actions are being are governed by ITS applied in the ITS than were applied in the CTS. LCO 3.0.4, which requires the LCO to be met prior to entering a L04 (Category 3 - Relaxation of Completion Time) CTS 3.2.4 ACTION b.2, applies MODE or other when QPTR is greater than 1.09 due to misalignment of either a shutdown or specified condition in control rod, requires a THERMAL POWER reduction from RTP for each 1% of which the LCO applies, except under indicated QPTR in excess of 1.00 within 30 minutes. ITS 3.2.4 Required certain conditions.
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| Action A.1 requires a THERMAL POWER reduction of 3% from RTP for each Therefore, power 1% QPTR exceeds 1.00 within 2 hours. This changes the CTS by allowing increases are prohibited while 2 hours to perform the required power reduction. avoiding the risk of changing Reactor Trip The purpose of CTS 3.2.4 is to provide appropriate compensatory actions for System setpoints during operation.
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| QPTR greater than that assumed in the safety analyses. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering other indications available to the operator, a reasonable time for restoring compliance with the LCO, and the low probability of a DBA occurring during the restoration period. Under the ITS, a QPTR of 1.09 would require THERMAL POWER to be reduced to 79% RTP. This will provide sufficient thermal margin to account for the radial power distribution. In addition, the 2-hour time limit is consistent with the CTS time allowed when QPTR is Turkey Point Unit 3 and Unit 4 Page 6 of 8
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| DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
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| > 1.00 but 1.09. This change is designated as less restrictive because additional time is allowed to decrease power than was allowed in the CTS.
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| L05 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
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| CTS 4.2.4.1.a states, in part, that the QPTR shall be determined to be within the limit by calculating the ratio in accordance with the Surveillance Frequency Control Program (SFCP). ITS SR 3.2.4.1 requires the same determination, but includes two Notes. ITS SR 3.2.4.1 Note 1 states when the input from one Power Range Neutron Flux channel is inoperable, the remaining three power range channels can be used for calculating QPTR as long as THERMAL POWER is less than or equal to 75% RTP. ITS SR 3.2.4.1 Note 2 states that SR 3.2.4.2 may be performed in lieu of this Surveillance. This changes the CTS by allowing use of three Power Range Neutron Flux channels for calculating the QPTR and by allowing the movable incore detectors to be used to determine QPTR instead of the excore detectors.
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| The purpose of CTS 4.2.4.1.a is to periodically verify that QPTR is within limit.
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| This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are sufficient for verification that the parameters meet the LCO. When one or more Power Range Neutron Flux channels are inoperable, tilt monitoring becomes degraded. With only one Power Range Neutron Flux channel inoperable, QPTR can still be verified by calculation as long as three Power Range Neutron Flux channels are OPERABLE and THERMAL POWER is less than or equal to 75% RTP. The movable incore detector system provides a more accurate indication of QPTR than the excore detectors. In fact, the movable incore detector system is used to calibrate the excore detectors. Therefore, allowing the use of the movable incore detector system or excore detector is appropriate. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS. (Category 7 - Relaxation of Surveillance Frequency)
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| L06 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
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| CTS 4.2.4.1.a states that the QPTR shall be determined to be within the limit by calculating the ratio in accordance with the SFCP when the Power Range Upper Detector High Flux Deviation and Power Range Lower Detector High Flux Deviation Alarms are OPERABLE. CTS 4.2.4.1.b states that the QPTR shall be determined to be within the limit by calculating the ratio in accordance with the SFCP during steady state operation when the alarm is inoperable. ITS SR 3.2.4.1 requires verification that the QPTR is within limits in accordance with the SFCP. This changes the CTS by eliminating the requirement to verify the QPTR more frequently when the QPTR alarm is inoperable.
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| The purpose of CTS 4.2.4.1.a and 4.2.4.1.b is to periodically verify that the QPTR is within limit. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the frequency of QPTR verification when the QPTR alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that the QPTR is outside its limit. The QPTR alarm is for indication only. Its use is not credited in any of the safety analyses. This change Turkey Point Unit 3 and Unit 4 Page 7 of 8
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| | |
| DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR) is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS. (Category 7 - Relaxation of Surveillance Frequency)
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| L07 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
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| CTS 4.2.4.2 states, in part, that the QPTR shall be determined to be within the limit when above 75 percent of RTP with one Power Range Channel inoperable by using the movable incore detectors, or by incore thermocouple map. ITS SR 3.2.4.2 requires determination of the QPTR by use of the movable incore detectors. Additionally, ITS SR 3.2.4.2 contains a Note which states "Not required to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER
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| > 75% RTP." This changes the CTS by not requiring the Surveillance to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable.
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| The purpose of CTS 4.2.4.2 is to verify that the QPTR is within limit using the movable incore detectors. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. When one or more Power Range Neutron Flux channels are inoperable, tilt monitoring becomes degraded. Therefore, the movable incore detector system provides a more accurate indication of QPTR than the excore detectors. The ITS SR 3.2.4.2 allowance, for not requiring performance of the Surveillance for 12 hours after input when one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER > 75% RTP, is required to allow time for the movable incore detectors to perform the initial measurement of the QPTR before the Surveillance is declared not met. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.
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| will be performed less frequently under the ITS than under L08 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.2.4.2, in part, permits verification of QPTR to be within limits with one Power Range Neutron Flux channel inoperable by use of the incore thermocouple map and verifying it is consistent with the indicated QPTR. This option is retained in ITS SR 3.2.4.3 and associated Note 1. Note 2 is added to proposed ITS SR 3.2.4.3 consistent with the allowance provided in ISTS SR 3.2.4.2, stating that the SR is not required to be performed until 12 hours after input from one Power Range Neutron Flux channel is inoperable with THERMAL POWER > 75% RATED THERMAL POWER (RTP). This changes the CTS by not requiring the Surveillance to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable.
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| The purpose of CTS 4.2.4.2 is to verify, when one Power Range Neutron Flux channel is inoperable, that the QPTR is within limit using other methods, which include use of the incore thermocouple map and verifying the results are consistent with the indicated QPTR from the remaining three OPERABLE Power Range Neutron Flux channels. This change is acceptable because the time to perform the Surveillance after input to one Power Range Neutron Flux channel is inoperable is consistent with the Note to ISTS SR 3.2.4.2 and the required Completion Time of ISTS 3.3.1, Required Action D.2.2, and has been evaluated to ensure that it provides an acceptable level of equipment reliability. The ITS SR 3.2.4.3 allowance, for not requiring performance of the Surveillance for 12 hours after input from one Power Range Neutron Flux channel is inoperable with THERMAL POWER > 75% RTP, provides time to perform the initial measurement of the QPTR using the incore thermocouple map and comparing results to the QPTR calculated from the remaining three Power Range Neutron Flux channels before the Surveillance is declared not met. This change is designated as less restrictive because the Surveillance will be performed less frequently under the ITS than under the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 8 of 8
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| CTS QPTR 3.2.4 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME ACTION a, B. Required Action and B.1 Reduce TH ERMAL 4 hours ACTION b, ACTION c associated Completion POWER to 50% RTP.
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| Time not met.
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| SURV EILLANCE REQUIREMENTS SU RVEILLANCE FREQUENCY 4.2.4.1 SR 3.2.4.1 ------------------------------NOTES-----------------------------
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| DOC L06
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| : 1. With input from one Pow er Range Neutron Flux channel inoperab le and TH ERMAL POWER 5
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| 75% RTP, the remaining three pow er range channels can be used for calculating QPTR.
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| : 2. SR 3.2.4.2 may be performed in lieu of this Surveillance.
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| Verif y QPTR is within limit by calculation. [ 7 day s 3 OR In accordance with the Surveillance Frequency Control Program ] 3 Turkey Point Unit 3 and Unit 4 Amendment XXX and YYY Westinghouse STS 3.2.4-3 Rev. 5.0 2
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| CTS QPTR 3.2.4 SURV EILLANCE REQUIREMENTS (continued)
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| SU RVEILLANCE FREQUENCY 4.2.4.2, SR 3.2.4.2 -------------------------------NOTE------------------------------
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| DOC L08 Not required to be performed until 12 hours after 7 input from one or more Pow er Range Neutron Flux channels are inoperab le with TH ERMAL POWER
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| > 75% RTP.
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| Verify QPTR is within limit using the mov ab le incore [ 12 hours 3 detectors.
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| OR In accordance with the Surveillance Frequency Control Program ] 3 SR 3.2.4.3 ---------------------------------------------------NOTES-------------------------------------------------
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| : 1. Only applicable when one Power Range Neutron Flux channel is inoperable.
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| 4.2.4.2, 2. Not required to be performed until 12 hours after input from one Power DOC L08 Range Neutron Flux channel is inoperable with THERMAL POWER > 75% RTP. 4 Verify QPTR is within limit using incore thermocouple map. In accordance with the Surveillance Frequency Control Program Turkey Point Unit 3 and Unit 4 Amendment XXX and YYY Westinghouse STS 3.2.4-4 Rev. 5.0 2
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| | |
| JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
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| : 1. Changes are made to be consistent with changes made to Specification 3.2.1 and 3.2.2.
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| : 2. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 4. A Surveillance is added to ITS 3.2.4 to verify QPTR is within limits using the incore thermocouple map consistent with current Technical Specifications. The Surveillance is modified by two Notes. Note 1 clarifies the current allowance using an incore thermocouple map to determine QPTR by limiting the use of the incore thermocouple map to verify QPTR within limits only when a single Power Range Neutron Flux channel is inoperable. With two or more Power Range Flux channels inoperable, the remaining channels are insufficient to determine QPTR using the core thermal mapping comparison. Note 2 is added consistent with the allowance provided in ISTS SR 3.2.4.2 and states that the SR is not required until 12 hours after the input from one Power Range Neutron Flux channel is inoperable and THERMAL POWER is > 75% RTP, consistent with the once per 12-hour Completion Time of ITS 3.3.1, "Reactor Trip System (RTS) Instrumentation," ACTION D.2.2. The incore thermocouple map receives temperature input from the core exit thermocouples (CETs) and QPTR is calculated based on the core thermal map results of the CETs when one Power Range Neutron Flux channel is inoperable. The incore thermocouple map results are compared to the QPTR calculated using the remaining three OPERABLE Power Range Neutron Flux channels. Since one excore detector is inoperable such that the core flux in one core quadrant cannot be determined, this comparison is used to verify the indicated QPTR is consistent with the incore thermocouple map results, thereby confirming periodically that QPTR is within limits. If the incore thermocouple map results cannot confirm QPTR is within limits, QPTR must be verified within limits using the movable incore detectors.
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| The Surveillance Frequency is in accordance with Surveillance Frequency Control Program consistent with ISTS SR 3.2.4.2.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| | |
| QPTR B 3.2.4 BASES SURV EILLANCE REQUIREMENTS (continued) 6 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REV IEW ER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given ab ov e, and the appropriate choice of Frequency in the Surveillance Requirement.
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| 6
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| ------------------------------------------------------------------------------------------------ ]
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| QPTR For those causes of QPT that occur quickly (e.g., a dropped rod), there 5 QPTR deviations typically are other indications of ab normality that prompt a verification of core pow er tilt.
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| SR 3.2.4.2 This Surveillance is modified by a Note, which states that it is not required until 12 hours after the input from one or more Pow er Range Neutron Flux channels are inoperab le and the TH ERMAL POWER is > 75% RTP.
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| With an NIS pow er range channel inoperab le, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels, but the capab ility for detection of small pow er tilts in some quadrants is decreased. [ Performing SR 3.2.4.2 at a Frequency 6 of 12 hours provides an accurate alternative means for ensuring that any tilt remains within its limits.
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| OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REV IEW ER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4
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| description, given ab ov e, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ] 6 Turkey Point Unit 3 and Unit 4 Rev ision XXX Westinghouse STS B 3.2.4-6 Rev. 5.0 2
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| | |
| QPTR B 3.2.4 BASES SURV EILLANCE REQUIREMENTS (continued)
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| , or by incore thermocouple map For purposes of monitoring the QPTR when one pow er range channel is inoperab le, the mov eab le incore detectors are used to conf irm that the 1 normalized symmetric power distribution is consistent with the indicated QPTR and any prev ious data indicating a tilt. The incore detector monitoring is performed with a full incore flux map or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8 for three and 2 four loop cores.
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| The symmetric thimble flux map can be used to generate symmetric thimble "tilt." This can be compared to a ref erence symmetric thimble tilt, from the most recent full core flux map, to generate an incore QPTR.
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| Theref ore, incore monitoring of QPTR can be used to conf irm that QPTR is within limits.
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| With one NIS channel inoperab le, the indicated tilt may be changed from the value indicated with all four channels OPERABLE. To confirm that no change in tilt has actually occurred, which might cause the QPTR limit to be ex ceeded, the incore result may be compared against previous flux maps either using the symmetric thimbles as described ab ov e or a complete flux map. Nominally, quadrant tilt from the Surveillance should be within 2% of the tilt show n by the most recent flux map data.
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| REFERENCES 1. 10 CF R 50.46.
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| UFSAR Section14.2.6
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| : 2. Regulatory Guide 1.77, Rev [0], May 19 74.
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| 19 67 AEC Proposed General Design Criteria, GDC 27 2
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| : 3. 10 CF R 50, Appendix A, G DC 26.
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| : 4. UFSAR, Section 3.1.2 SR 3.2.4.3 The incore thermocouple map receives temperature input from the core exit thermocouples (CETs) and QPTR is calculated based on the core thermal map results of the CETs when one Power Range Neutron Flux channel is inoperable. The incore thermocouple 2 map results are compared to the QPTR calculated using three OPERABLE Power Range Neutron Flux channels. Since one excore detector is inoperable such that the core flux in one core quadrant cannot be determined, this comparison is used to verify the indicated QPTR is consistent with the incore thermocouple map results; thereby confirming periodically that QPTR is within limits. If the incore thermocouple map results cannot confirm QPTR is within limits, QPTR must be verified within limits using the movable incore detectors.
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| This Surveillance is modified by two Notes. Note 1 limits the use of the incore thermocouple map to verify QPTR within limit to only 2 when a single Power Range Neutron Flux channel is inoperable. With two or more Power Range Flux channels inoperable, the remaining channels are insufficient to determine QPTR using the core thermal mapping comparison. Note 2 states that the SR is not required until 12 hours after the input from one Power Range Neutron Flux channel is inoperable and THERMAL POWER is >
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| 75% RTP.
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| The Surveillance Frequency is controlled under the Surveillance Frequency Control Program and is consistent with the Completion Time to perform SR 3.2.4.3 in Specification 3.3.1, "Reactor Trip System (RTS) Instrumentation."
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| Turkey Point Unit 3 and Unit 4 Rev ision XXX Westinghouse STS B 3.2.4-7 Rev. 5.0 2
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| | |
| ITS ITS 3.3.1 A01 Table 3.3.1-1 TABLE 3.3-1 (Continued)
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| TABLE NOTATION Table 3.3.1-1 NOTE (a)
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| * When the Reactor Trip System breakers are in the closed position and the Control Rod Drive System is capable of rod withdrawal. A04 or one or more rods not fully inserted
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| ** When the Reactor Trip System breakers are in the open position, one or both of the backup NIS instrumentation channels may be used to satisfy this requirement. For backup NIS testing L06 requirements, see Specification 3/4.3.3.3, ACCIDENT MONITORING.
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| *** Reactor Coolant Pump breaker A is tripped by underfrequency sensor UF-3A1(UF-4A1) or UF-3B1(UF-4B1). Reactor Coolant Pump breakers B and C are tripped by underfrequency LA03 sensor UF-3A2(UF-4A2) or UF-3B2(UF-4B2).
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| Table 3.3.1-1 NOTE (e)
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| # Below the P-6 (Intermediate Range Neutron Flux Interlock) Setpoint.
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| Table 3.3.1-1 NOTE (d) ## Below the P-10 (Low Setpoint Power Range Neutron Flux Interlock) Setpoint.
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| ACTION STATEMENTS ACTION B ACTION 1 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours or in accordance with the Risk Informed Completion Time Program, or be in HOT STANDBY ACTION U within the next 6 hours.
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| ACTION D ACTION 2 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:
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| ACTION D R.A. D.1.1, D.2.1, & E.1 a. The inoperable channel is placed in the tripped condition within 6 hours, ACTION D & E R.A. NOTE b. The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 4 hours for surveillance testing of other channels per Specification 4.3.1.1, and ACTION D R.A. D.1.2 c. Either, THERMAL POWER is restricted to less than or equal to 75% of RATED THERMAL POWER and the Power Range Neutron Flux Trip Setpoint is reduced to less L02 than or equal to 85% of RATED THERMAL POWER within 4 hours; or, the QUADRANT ACTION D R.A. D.2.2 POWER TILT RATIO is monitored per Specification 4.2.4.2.
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| SR 3.2.4.2 A01
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| -----------------NOTE----------------
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| or SR 3.2.4.3 Only required to be performed when the Power Range Neutron A05 ACTION D R.A. D.2.2 NOTE flux input to QPTR is inoperable.
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| ACTION D R.A. D.2.Completion Time once per 12 hours A01 ACTION U TURKEY POINT - UNITS 3 & 4 3/4 3-5 AMENDMENT NOS. 284 AND 278
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| | |
| RTS Instrumentation 3.3.1 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME 6
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| ACTION 2.a D.2.1 Place channel in trip. 72 hours 4
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| [OR In accordance with the Risk Informed 1
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| Completion Time Program]
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| AND D.2.2 --------------NOTE--------------
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| Only required to be DOC A05 performed when the Power DOC L0x Range Neutron Flux input to QPTR is inoperable.
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| ACTION 2.c Perform SR 3.2.4.2. Once per 12 hours 3
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| or SR 3.2.4.3 Westinghouse STS 3.3.1-3 Rev. 5.0 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY 1
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| | |
| RTS Instrumentation B 3.3.1 BASES ACTIONS (continued)
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| D.1.1, D.1.2, D.2.1, and D.2.2 Condition D applies to the Power Range Neutron Flux - High Function.
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| The NIS power range detectors provide input to the Rod Control System 1
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| and the SG Water Level Control System and, therefore, have a two-out-of-four trip logic. A known inoperable channel must be placed in the Completion Time tripped condition. This results in a partial trip condition requiring only one-out-of-three logic for actuation. The 72 hours allowed to place the 6 hours.
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| inoperable channel in the tripped condition is justified in 1 WCAP-14333-P-A (Ref. 8). [Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time 3 Program.]
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| In addition to placing the inoperable channel in the tripped condition, 4 1 THERMAL POWER must be reduced to 75% RTP within 78 hours [or in accordance with the Risk Informed Completion Time Program]. Reducing 3 the power level prevents operation of the core with radial power distributions beyond the design limits. With one of the NIS power range detectors inoperable, 1/4 of the radial power distribution monitoring capability is lost.
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| As an alternative to the above actions, the inoperable channel can be 6 1 placed in the tripped condition within 72 hours [or in accordance with the 3
| |
| Risk Informed Completion Time Program] and the QPTR monitored once every 12 hours as per SR 3.2.4.2, QPTR verification. Calculating QPTR every 12 hours compensates for the lost monitoring capability due to the or SR 3.2.4.3 inoperable NIS power range channel and allows continued unit operation at power levels > 75% RTP. The 12-hour Frequency is consistent with LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)."
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| [ The Required Actions have been modified by a Note that allows placing 4 the inoperable channel in the bypass condition for up to 12 hours while performing routine surveillance testing of other channels. The Note also 3 allows placing the inoperable channel in the bypass condition to allow setpoint adjustments of other channels when required to reduce the setpoint in accordance with other Technical Specifications. The 12 hour time limit is justified in Reference 8. ]
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| Westinghouse STS B 3.3.1-35 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| | |
| RTS Instrumentation B 3.3.1 BASES ACTIONS (continued)
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| The below text should be used for plants with installed bypass test capability:
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| The Required Actions are modified by a Note that allows placing one 2 channel in bypass for 12 hours while performing routine surveillance testing, and setpoint adjustments when a setpoint reduction is required by other Technical Specifications. The 12 hour time limit is justified in Reference 8.
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| Required Action D.2.2 has been modified by a Note which only requires SR 3.2.4.2 to be performed if the Power Range Neutron Flux input to QPTR becomes inoperable. Failure of a component in the Power Range or SR 3.2.4.3 Neutron Flux Channel which renders the High Flux Trip Function inoperable may not affect the capability to monitor QPTR. As such, determining QPTR using this movable incore detectors once per 12 hours may not be necessary. 1 or by incore thermocouple map the E.1 Condition E applies to the following reactor trip Functions:
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| * Power Range Neutron Flux - Low,
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| * Overtemperature T,
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| * Overpower T,
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| * Power Range Neutron Flux - High Positive Rate, 1
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| * Power Range Neutron Flux - High Negative Rate,
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| * Pressurizer Pressure - High,
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| * SG Water Level - Low Low, and
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| * SG Water Level - Low coincident with Steam Flow/Feedwater Flow Mismatch.
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| Westinghouse STS B 3.3.1-36 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 7/14/22, 2:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1566 NRC Question CCH018 Number Select NRC Question Closure Application Attachment 1
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| Attachment 2
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| | |
| ===Response===
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| Statement
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| | |
| ===Response===
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| Date/Time Closure This question is closed Statement The use of core exit thermocouple map to compensate for an inoperable excore power range neutron flux indication channel with Thermal Power above 75% RTP, is verified as part of current TS and recognizes the site-specific unique CET system capability to support QPTR determination in these circumstances, as an alternative to using the incore detectors to verify QPTR is within limits. Licensee stated in conference call on 7/14/22, that the site-specific TS and associated Bases for the Surveillance have included this optional method at least since the conversion to the previous Westinghouse STS. Retaining this method as a separate SR in ITS is therefore acceptable.
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| No further information is required at this time to draft the Safety Evaluation.
| |
| Question Closure 7/14/2022 Date Notification Victor Cusumano Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date 7/14/2022 12:38 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1566 1/1
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| 7/11/22, 6:01 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1538 NRC Question CCH018 Number Select NRC Response Application Attachment 1
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| Attachment 2
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| Response CTS 4.2.4.2 states Statement The QPTR shall be determined to be within the limit when above 75% of RTP with one Power Range channel inoperable by using the movable incore detectors to confirm that the normalized symmeteric power distribution, obtained either from two sets of four symmetric thimble locations or full core flux map, or by incore thermocouple map is consistent with the indicated QPTR in accordance with the SFCP.
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| The red-italicized text is proposed for relocation according to Discussion of Change (DOC) 3.2.4-L01.
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| The determination that QPTR is within limits by using the movable incore detectors is retained as ITS SR 3.2.4.2:
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| SR 3.2.4.2 Verify QPTR is within limit using the movable incore detectors. l IAW the SFCP The determination that QPTR is within limits by using an incore thermocouple map is retained as ITS SR 3.2.4.3, which is not in STS Subsection 3.2.4.
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| SR 3.2.4.3 Verify QPTR is within limit using incore thermocouple map. l IAW the SFCP The STSB staff need technical staff to concur that the incore thermocouple map method can be used in combination with the three operable excore channels to determine or confirm QPTR is within limits, and does not require core flux distribution input from the movable incore detectors. The CTS 4.2.4.2 language is not clear about this. That is "the normalized symmeteric power distribution, obtained either from two sets of four symmetric thimble locations or full core flux map, or by incore thermocouple map"
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| | |
| ===Response===
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| 7/11/2022 6:00 PM Date/Time Closure Statement Question Closure Date Notification Victor Cusumano Gregg Ellis Matthew Hamm Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date 7/11/2022 5:00 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1538 1/1
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| 7/14/22, 2:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1566 NRC Question CCH018 Number Select NRC Question Closure Application Attachment 1
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| Attachment 2
| |
| | |
| ===Response===
| |
| Statement
| |
| | |
| ===Response===
| |
| Date/Time Closure This question is closed Statement The use of core exit thermocouple map to compensate for an inoperable excore power range neutron flux indication channel with Thermal Power above 75% RTP, is verified as part of current TS and recognizes the site-specific unique CET system capability to support QPTR determination in these circumstances, as an alternative to using the incore detectors to verify QPTR is within limits. Licensee stated in conference call on 7/14/22, that the site-specific TS and associated Bases for the Surveillance have included this optional method at least since the conversion to the previous Westinghouse STS. Retaining this method as a separate SR in ITS is therefore acceptable.
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| No further information is required at this time to draft the Safety Evaluation.
| |
| Question Closure 7/14/2022 Date Notification Victor Cusumano Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date 7/14/2022 12:38 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1566 1/1
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| | |
| 6/2/22, 4:12 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 763 NRC Question CCH019 Number Category Technical ITS 3.1 Section ITS 3.1.6 Number DOC L-2 Number JFD 1
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| Number JFD Bases Number Page 138, 142, 145 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.1.6 - page 42 of 258 - ITS 3.1.6, Control Bank Insertion Limits Question DOC 3.1.6-L02 (Category 3 - Relaxation of Completion Time) needs clarification.
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| (1) The first sentence states CTS 3.1.3.6 does not have an ACTION associated with control bank A, B, or C inserted 12 steps beyond the insertion, sequence, or overlap limits specified in the COLR.
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| The licensee is requested to explain what the 12-step value is based on.
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| The staff observes that Figure A3 in the latest Unit 3 COLR and Unit 4 COLR does not appear to include a limit of control bank A, B, C, or D inserted 12 or 20 steps beyond the insertion, sequence, or overlap limits.
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| (2) The licensee is requested to explain why DOC 3.1.6-L02 at end of first paragraph includes the statement (which is also included in DOC 3.1.5-L03) It also eliminates the requirement to enter CTS 3.0.3 if more than one shutdown rod is not fully withdrawn. The subject action requirement cannot be located in CTS 3.1.3.6.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/2/2022 Added By Craig Harbuck Date Modified Modified By Date 6/2/2022 3:10 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=763 1/1
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| 8/3/22, 5:45 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1439 NRC Question CCH019 Number Select Licensee Response Application Attachment Attachment 1 - CCH019 LAR Markups EA.pdf (1MB) 1 Attachment 2
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| Response 1. FPL will change 12 steps to 20 steps in the first sentence of DOC L02. This change is consistent with Statement the requirements in TSTF-547 and PTN current procedures for verifying OPERABILITY of the Rod Control Cluster Assembly drive mechanisms and associated control circuits by movement of at least 10 steps but not more than 20 steps. The COLR does not reference the number of steps; the DOC states that the COLR contains insertion, sequence, or overlap limits; which, it does in figure A3. See Attachment 1 - CCH019 LAR Markups.
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| : 2. FPL will delete the last sentence in ITS 3.1.6 DOC L02 referencing Shutdown Banks. See Attachment 1
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| - CCH019 LAR Markups.
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| Attachment
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| : 1. CCH019 - LAR Markups
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| ===Response===
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| 7/5/2022 2:35 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/5/2022 1:35 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1439 1/1
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| DISCUSSION OF CHANGES ITS 3.1.6, CONTROL BANK INSERTION LIMITS change is designated as more restrictive because requirements are added to the CTS.
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| RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 5 - Deletion of Surveillance Requirement) CTS 4.1.3.6 requires that during time intervals when the Rod Insertion Limit Monitor is inoperable, the individual rod positions be verified at least once per 4 hours. ITS 3.1.6.2 requires verification that each control bank insertion is within the insertion limits specified in the COLR in accordance with the SFCP. This changes the CTS by eliminating the requirement to verify the control bank insertion to be within limits every 4 hours when the Rod Insertion Limit Monitor is inoperable.
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| The purpose of CTS 4.1.3.6 is to periodically verify that the rods are within the alignment limit specified in the LCO. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the Frequency of rod position verification when the Rod Insertion Limit Monitor is inoperable is unnecessary because inoperability of the alarm does not increase the possibility that the control banks are inserted below the limits. The Rod Insertion Limit Monitor alarm is for indication only; its use is not credited in any of the safety analyses. This change is designated as less restrictive because a Surveillance which was required in CTS will not be required in the ITS. 20 L02 (Category 3 - Relaxation of Completion Time) CTS 3.1.3.6 does not have an ACTION associated with control bank A, B, or C inserted 12 steps beyond the insertion, sequence, or overlap limits specified in the COLR. ITS 3.1.5 ACTION A provides Required Actions for one shutdown bank inserted 20 steps beyond the insertion limits specified in the COLR. ITS 3.1.6 Required Action A.1 requires verification of all control banks are within the insertion limits specified in the COLR and either verification that the SDM is within the limits specified in the COLR (Required Action A.1.1) or the initiation of boration to restore SDM to within limits (Required Action A.1.2), all three within 1 hour. ITS 3.1.6 Required Action A.3 requires restoration of the shutdown banks to within limits within 24 hours. Additionally, ITS 3.1.6 ACTION C requires that if any Required Action and associated Completion Time is not met, the unit must be in MODE 3 within 6 hours. This changes the CTS by allowing one control bank to be beyond the insertion, sequence, or overlap limits specified in the COLR for 24 hours to restore the control rod bank to within limits, eliminates the allowance to declare the rod inoperable and to take the ACTIONS of Specification 3.1.3.1, and adds Turkey Point Unit 3 and Unit 4 Page 3 of 4
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| DISCUSSION OF CHANGES ITS 3.1.6, CONTROL BANK INSERTION LIMITS the requirement to verify SDM or to initiate boration within one hour. It also eliminates the requirement to enter CTS 3.0.3 if more than one shutdown rod is not fully withdrawn.
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| The purpose of CTS 3.1.3.6 ACTION is to ensure the control rod banks are fully withdrawn in order to ensure that there is sufficient SDM available to quickly shutdown the reactor. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering that only a small amount of time is provided to establish the required features, and the low probability of a DBA occurring during the repair period.
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| Allowing 24 hours to restore one control rod bank to within insertion limits is appropriate as it may avoid a shutdown, a unit transient, while the rod control system is not in full working order. The ITS requires verification that the shutdown margin requirement is met or actions to restore the SDM to within its limit within 1 hour, so all safety analysis assumptions are being met. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L03 (Category 7 - Relaxation of Surveillance Frequency Change - NON-24 MONTH TYPE CHANGE) CTS Surveillance Requirement (SR) 4.1.1.1.1.b requires control bank withdrawal to be verified within the limits specified in CTS 3.1.3.6 in accordance with the SFCP. ITS SR 3.1.6.2 requires the control bank to be within the insertion limits specified in the COLR. The ITS is modified by a Note which states "Not required to be performed until 1 hour after the associated rod motion." This changes the CTS by adding the ITS Note; which, allows the SR to be delayed 1 hour after rod motion.
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| The purpose of ITS SR 3.1.6.2 is to keep control banks within the insertion limits specified in the COLR. This ensures that when the reactor is critical the required SDM will be maintained following a reactor trip. The purpose of the allowed one-hour delay in verification of the insertion limits ensures the accuracy of the rod position indication system is not affected by rod temperature. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. This change is acceptable because it delays the SR performance for a sufficient time to ensure the accuracy of the position indication system. This change in designated as less restrictive because a delay of one hour is allowed to perform the SR that is not currently allowed.
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| Turkey Point Unit 3 and Unit 4 Page 4 of 4
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| 7/13/22, 10:05 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1550 NRC Question CCH019 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/12/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/12/2022 5:01 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1550 1/1
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| 6/2/22, 4:23 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 767 NRC Question CCH020 Number Category Technical ITS 3.1 Section ITS 3.1.8 Number DOC M-1 Number JFD 1
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| Number JFD Bases 1
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| Number Page 200, 202, 209, 213, 214 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.1.8 - pages 200, 202, 209, 213, and 214 of 258 - ITS 3.1.8, PHYSICS TESTS Exceptions - MODE 2 Question (1) DOC 3.1.8-M01 states in part, ITS LCO 3.1.8 adds a requirement that SHUTDOWN MARGIN must be within the limits provided in the COLR. A Surveillance (ITS SR 3.1.8.4), to verify the SHUTDOWN MARGIN in accordance with the [Surveillance]
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| Frequency Control Program [SFCP], and an ACTION (ITS 3.1.8, ACTION A), to follow if the SHUTDOWN MARGIN (SDM) is not met, are also added.[TC1] [HC2]
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| Because the ITS Surveillance to verify SDM is added to support the new LCO to maintain SDM within limits of ITS LCO 3.1.1 during physics testing in MODE 2, is not in the CTS, and therefore is not currently addressed in the SFCP, the licensee is requested to clarify DOC 3.1.8M01 by stating (a) the proposed initial Frequency in the SFCP for the new Surveillance to verify SDM, and (b) the Bases for the initial Frequency.
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| (2) JFD B 3.1.8-1 addresses the departure from STS 3.1.8 Bases to not include Reference 6, WCAP-11618, including Addendum 1, April 1989, and the associated paragraph at the end of the Applicable Safety Analyses section of the Bases (Reference 6 allows special test exceptions (STEs) to be included as part of the LCO that they affect. It was decided, however, to retain this STE as a separate LCO because it was less cumbersome and provided additional clarity.)
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| JFD B 3.1.8-1 states, Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| The licensee is requested to explain why the omitted paragraph and reference are not appropriate for PTN Units 3 and 4, such that this departure from STS is justified.
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| (3) The second paragraph of the LCO section of the Bases for ITS 3.1.8 lists the LCO 3.3.1 RTS instrumentation Function numbers for which one of four channels are permitted to be placed in bypass; the STS list of Functions (2, 3, 6, and 18.e) on page 209 is requested to be marked up to match the ITS list of Functions (2 and 17.e) as shown on page 200 in the markup of STS LCO 3.1.8, and as addressed by JFD 3.1.8-2.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/2/2022 Added By Craig Harbuck Date Modified https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=767 1/2
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| 6/2/22, 4:23 PM Turkey Point ITS Conversion Database Modified By Date 6/2/2022 3:21 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=767 2/2
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| 8/3/22, 5:44 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1443 NRC Question CCH020 Number Select Licensee Response Application Attachment Attachment 1 - CCH020 LAR Markups (3) EA.pdf (1MB) 1 Attachment 2
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| Response 1. FPL will revise Improved Technical Specifications (ITS) 3.1.8, Discussion of Change (DOC) M01, to add the Statement proposed initial frequency for ITS 3.1.8, Surveillance Requirement (SR) 3.1.8.4, and the bases for the frequency. See Attachment 1 - CCH020 LAR Markups.
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| : 2. The last paragraph of ISTS B 3.1.8, "Applicable Safety Analysis," states:
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| Reference 6 allows special test exceptions (STEs) to be included as part of the LCO that they affect. It was decided, however, to retain this STE as a separate LCO because it was less cumbersome and provided additional clarity.
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| This statement is historical and does not provide any added benefit to the Turkey Point Nuclear Power Plant (PTN) ITS Bases. The PTN ITS does not contain STEs in any of the LCOs. The two STEs in the Improved Standard Technical Specifications (ISTS) are both stand-alone STEs such that this statement is not applied in the ISTS. Therefore, FPL will retain the deletion of this paragraph but will add a new Justification for Deviation (JFD) 7 providing the bases for its deletion. See Attachment 1 - CCH020 LAR Markups.
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| : 3. FPL will revise the ITS 3.1.8 Bases reference to the RTS Instrumentation Functions in the LCO Section to be consistent with the ITS 3.1.8 LCO. See Attachment 1 - CCH020 LAR Markups.
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| Attachment
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| : 1. CCH020 LAR Markups
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| ===Response===
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| 7/5/2022 2:40 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/5/2022 1:38 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1443 1/1
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| DISCUSSION OF CHANGES ITS 3.1.8, PHYSICS TESTS EXCEPTIONS - MODE 2 This change is acceptable because the Reactor Trip Setpoints on the OPERABLE Intermediate and Power Range Channels are contained in ITS LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." Repeating that requirement in the test exception LCO is unnecessary. This change is designated as administrative as it eliminates a repeated requirement from the CTS, resulting in no technical change to the CTS.
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| A05 CTS 3.10.3 is applicable in MODE 2. ITS LCO 3.1.8 is applicable during PHYSICS TESTS initiated in MODE 2. This changes the CTS such that the Specification is applicable in MODE 2 only when a PHYSICS TEST is initiated.
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| The purpose of ITS 3.1.8 Applicability is to ensure the ACTIONS contained in the Specification are followed. The wording of the CTS appears to be contradictory because, if THERMAL POWER exceeds 5% RATED THERMAL POWER (RTP),
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| then the test exception Specification Applicability is exited and the Actions no longer apply. However, it is clear that the CTS Action should be applied if THERMAL POWER exceeds 5% RTP and PHYSICS TESTS are in progress.
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| The ITS Applicability eliminates this apparent contradiction and allows the test exception Conditions and Required Actions to be applied when the LCO is not met. This is consistent with the wording of the CTS ACTION. This change is designated as administrative because it clarifies the current wording of the Specification with no change in intent.
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| MORE RESTRICTIVE CHANGES (SDM)
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| M01 CTS 3.10.3 states that limitations of certain Specifications may be suspended during the performance of PHYSICS TESTS and provides restrictions that must be followed when utilizing the CTS exception. ITS LCO 3.1.8 adds a requirement that SHUTDOWN MARGIN must be within the limits provided in the COLR. A Surveillance (ITS SR 3.1.8.4), to verify the SHUTDOWN MARGIN in accordance with the Frequency Control Program, and an ACTION (ITS 3.1.8, ACTION A), to follow if the SHUTDOWN MARGIN (SDM) is not met, are also added. This changes the CTS by imposing an additional requirement on the application of the test exception LCO.
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| This change is acceptable because it imposes reasonable restrictions on the performance of PHYSICS TESTS when the control rod and Reactor Coolant System (RCS) minimum temperature Specifications are allowed to be suspended. The Bases for ITS 3.1.1, "SHUTDOWN MARGIN," states that during MODE 2, the SDM is ensured by compliance with the rod insertion limit Specifications. Under this test exception, those limits are allowed to be violated.
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| This change is designated as more restrictive because it imposes additional restrictions not found in the CTS.
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| The initial SR frequency will be consistent with ITS 3.1.1, SDM, SR RELOCATED SPECIFICATIONS 3.1.1.1, which verifies the SDM (currently 31 days in the SFCP).
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| This frequency is based on the generally slow change in required None boron concentration and the low probability of an accident occurring without the required SDM. It also allows time for the operator to collect the required data, which includes performing a boron concentration analysis, and complete the calculation.
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| Turkey Point Unit 3 and Unit 4 Page 2 of 3
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| PHYSICS TESTS Exceptions - MODE 2 B 3.1.8 BASES APPLICABLE SAFETY ANALYSES (continued)
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| As described in LCO 3.0.7, compliance with Test Exception LCOs is optional, and therefore no criteria of 10 CFR 50.36(c)(2)(ii) apply. Test 7
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| Exception LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
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| Reference 6 allows special test exceptions (STEs) to be included as part of the LCO that they affect. It was decided, however, to retain this STE 1 as a separate LCO because it was less cumbersome and provided additional clarity.
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| LCO This LCO allows the reactor parameters of MTC and minimum temperature for criticality to be outside their specified limits. In addition, it allows selected control and shutdown rods to be positioned outside of their specified alignment and insertion limits. One power range neutron flux channel may be bypassed, reducing the number of required channels from 4 to 3. Operation beyond specified limits is permitted for the purpose of performing PHYSICS TESTS and poses no threat to fuel integrity, provided the SRs are met.
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| 17.d The requirements of LCO 3.1.3, LCO 3.1.4, LCO 3.1.5, LCO 3.1.6, and LCO 3.4.2 may be suspended and the number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 3, 6 and 18.e may be reduced to 3 required channels during the performance of PHYSICS TESTS provided:
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| : a. RCS lowest loop average temperature is [531]°F, 2
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| : b. SDM is within the limits provided in the COLR, and
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| : c. THERMAL POWER is 5% RTP.
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| APPLICABILITY This LCO is applicable when performing low power PHYSICS TESTS.
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| The Applicability is stated as "during PHYSICS TESTS initiated in MODE 2" to ensure that the 5% RTP maximum power level is not exceeded. Should the THERMAL POWER exceed 5% RTP, and consequently the unit enter MODE 1, this Applicability statement prevents exiting this Specification and its Required Actions.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.8-5 Rev. 5.0 1
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| JUSTIFICATION FOR DEVIATIONS ITS 3.1.8 BASES, PHYSICS TESTS EXCEPTIONS - MODE 2
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| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 3. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
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| : 4. Editorial changes made for enhanced clarity/consistency.
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| : 5. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Technical Specifications, TSTF-GG-05-01, Section 5.1.3.
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| : 6. Typographical/grammatical error corrected.
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| : 7. This statement is historical and does not provide any added benefit to the Bases. The PTN ITS does not contain STEs in any of the LCOs. The two STEs in the Improved Standard Technical Specifications (ISTS) are both stand-alone STEs such that this statement is not applied in the ISTS.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 7/13/22, 10:07 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1554 NRC Question CCH020 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/12/2022 Date Notification Gregg Ellis Craig Harbuck Christina Long Caroline Tilton Added By Craig Harbuck Date Added 7/12/2022 7:14 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1554 1/1
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| 2/1/23, 11:33 AM Turkey Point ITS Conversion Database - New - ITS NRC Questions Turkey Point ITS Conversion Database - New Logged In As: Christina Long February 1, 2023 ITS NRC Questions NRC Question CCH021 Number Library Link Category Technical ITS Section 3.1 ITS Number 3.1.7 DOC Number JFD Number 1 JFD Bases 1
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| Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call Requested NRC This is a followup of the revised response to portal question CCH009 with Attachment CCH009-1, Question and an apparent unintended effect of adopting STS SR 3.1.7.1 language, which includes +/- 12 step acceptance criterion for allowed difference between the rod position indication and the group step counter for each rod, that appears to conflict with the ITS LCO 3.1.4 allowance for a +/- 18 step difference if Thermal Power is <= 90 percent RTP.
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| Staff understanding of rod position indication systems: The analog Rod Position Indication (RPI)
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| System is used to provide indication of the actual rod position and the rod group step counter demand position is calibrated for the full range of rod travel to be within the Allowed Rod Misalignment of the group step counter demand position. A misalignment outside the Allowed Rod Misalignment of the group step counter demand position can be caused by (1) a failed RPI System for the rod, (2) a failed group step counter for the rod, or (3) both.
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| Questions for discussion:
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| Question (1) Which ITS LCO ACTIONS Conditions apply upon discovery that a rods group step https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16624&id=812 1/4
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| 2/1/23, 11:33 AM Turkey Point ITS Conversion Database - New - ITS NRC Questions counter demand position indication exceeds the Allowed Rod Misalignment with the rods RPI System indicated position?
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| Question (2) What is the Allowed Rod Misalignment acceptance criteron of the Channel Calibration and Channel Operational Test Surveillances specified by CTS 4.1.3.2.2 and Table 4.1-1, as stated in the actual plant surveillance procedures?
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| Steps and inches of the Demand Position Indication System 1 step is 5/8 inches = 0.625 inches 12 steps are 7.5 inches - the spacing between the analog coils of the RPI System 18 steps are 11.25 inches Scenario using ITS 3.1.4 and ITS 3.1.7 In Mode 3 before Unit startup - the operators verified for full range of rod travel, that each rod has +/-
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| 12 step agreement between its analog Rod Position Indication (RPI) System and its Demand Postion Indication System (group step counter) in accordance with the acceptance criterion of ITS SR 3.1.7.1.
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| The Unit enters Mode 1 with Thermal Power above 5% RTP but less than 90% RTP in which ITS LCO 3.1.4 allows +/- 18 step misalignment between the analog RPI and the group step counter. But this is outside the misalignment acceptance criterion of SR 3.1.7.1.
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| Question (3) Is an ITS requirement not met in this situation?
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| The Background section of the Bases for ITS 3.1.4 says the following about rod position indication (Westinghouse STS Bases markup from the ITS LAR Enclosure 2, Volume 6, Attachment 4, is shown):
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| The axial position of shutdown rods and control rods is indicated by two separate and independent systems, which that are the Bank Demand Position Indication System (commonly called group step counters) and the Digital Rod Position Indication (DRPI)
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| System.
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| The Bank Demand Position Indication System counts the pulses from the rod control system that moves the rods. There is one step counter for each group of rods.
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| Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise (+/- 1 step or +/- 5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.
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| The Rod Position Indication (DRPI) System provides a highly accurate an indication of actual rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube. To increase the reliability of the system, the inductive coils are connected alternately to data system A or B. Thus, if one data system fails, the DRPI) will go on half accuracy. The Rod Position Indication (DRPI) System is capable of monitoring rod position within at least +/- 12 steps with either full accuracy or half accuracy.
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| The LCO section of the Bases for ITS 3.1.4 says (LAR Insert 2)
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| The allowed rod misalignment when THERMAL POWER is less than or equal to 90% of RATED THERMAL POWER, is +/- 18 steps. When THERMAL POWER is greater than 90%
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| of RATED THERMAL POWER, the allowed rod misalignment is +/- 12 steps.
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| https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16624&id=812 2/4
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| 2/1/23, 11:33 AM Turkey Point ITS Conversion Database - New - ITS NRC Questions o O , t e a o ed od sa g e t s steps The ITS 3.1.4 Bases for SR 3.1.4.1 says the following about position indication requirements of LCO 3.1.4:
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| [SR 3.1.4.1] is modified by a Note that permits it to not be performed for rods associated with an inoperable demand position indicator or an inoperable rod position indicator. The alignment limit is based on the demand position indicator which is not available if the indicator is inoperable. LCO 3.1.7 , "Rod Position Indication," provides Actions to verify the rods are in alignment when one or more rod position indicators are inoperable.
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| If one rod in one or more regulating groups has postion indication difference > +/-12 steps but
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| +/-18 steps, then (based on Attachment to response to RAI CCH008) if the cause of this difference is an RPI, then ITS 3.1.7 Action A would apply, and says in part:
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| A. One [D]RPI per group inoperable in one or more groups. l A.1 Verify the position of the rods with inoperable [D]RPI indirectly by using movable incore detectors. l 8 hours OR A.2 Verify the position of the rods with inoperable [D]RPI indirectly by using the moveable incore detectors.l 8 hours OR A.3 Reduce THERMAL POWER to 50< 75% RTP. l 8 hours if the cause of this difference is a group step counter, then ITS 3.1.7 Action D would apply and says:
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| D. One or more demand position indicators per bank inoperable in one or more banks. l D.1.1 Verify by administrative means all [D]RPIs for the affected banks are OPERABLE. l Once per 8 hours AND D.1.2 Verify the most withdrawn rod and the least withdrawn rod of the affected banks are 12 steps apart. l Once per 8 hours OR D.2 Reduce THERMAL POWER to 50< 75% RTP. l 8 hours The CTS would require entering neither Condition A nor Condition D because the CTS 4.1.3.2.2 (which corresponds to ITS SR 3.1.7.1) does not explicitly state the +/- 12 step position indication system agreement criterion for a rod; CTS 4.1.3.2.2 states:
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| Each of the above required analog rod position indicator(s) shall be determined to be OPERABLE by performance of a CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST performed in accordance with the Table 4.1-1.
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| Question (4) The licensee is requested to make appropriate changes to the ITS requirements related to the allowed rod misalignment of the rod position indication systems for a rod so that they are clear and no apparent conflict exists between LCO 3.1.4 and SR 3.1.7.1.
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| Attach File 1 Attach File 2 Issue Date 02/01/2023 Notification Gregg Ellis Christina Long ID 812 https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16624&id=812 3/4
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| 2/1/23, 11:33 AM Turkey Point ITS Conversion Database - New - ITS NRC Questions ID 812 Added By Craig Harbuck Date Added 2/1/2023 10:20 AM CST Modified By Date Modified Locked No https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16624&id=812 4/4
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| 2/21/23, 9:56 AM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure Turkey Point ITS Conversion Database - New Logged In As: Christina Long February 21, 2023 Licensee Response/NRC Response/NRC Question Closure NRC Question View Question Link Select Licensee Response Application Attachment
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| : 1. Attachment 1 - CCH021 LAR Markups (23-02-16).pdf (3MB) 1 Attachment 2
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| Response Staff understanding of rod position indication systems: The analog Rod Position Indication (RPI) System is Statement used to provide indication of the actual rod position and the rod group step counter demand position is calibrated for the full range of rod travel to be within the Allowed Rod Misalignment of the group step counter demand position. A misalignment outside the Allowed Rod Misalignment of the group step counter demand position can be caused by (1) a failed RPI System for the rod, (2) a failed group step counter for the rod, or (3) both.
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| FPL Response:
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| The NRC staff premise that a misalignment outside the Allowed Rod Misalignment of the group step counter demand position can be caused by (1) a failed RPI System for the rod, (2) a failed group step counter for the rod, or (3) both does not consider an actual rod misalignment. Indicated deviations of a rod from the rod group are considered actual rod deviations unless there is evidence of an inaccurate rod position indication system.
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| When a rod indicates a deviation from the group greater than the specified acceptance criteria of CTS 3.1.3.1 (ITS LCO 3.1.4), a decision is made based on other operational parameters to determine if the rod is misaligned or if the rod position indication is inoperable.
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| In addition, the NRC staff premise that the rod group step counter demand position is calibrated for the full range of rod travel to be within the Allowed Rod Misalignment of the group step counter demand position is inaccurate. As stated in the Background section of the Improved Standard Technical Specifications (ISTS) 3.1.7 Bases, the Demand Position Indication System counts the pulses from the Rod Control System that moves the rods. The Demand Position Indication System is operationally tested at the frequency specified in the Surveillance Frequency Control Program and is verified functional each time the Rod Control System moves the associated rod group. The purpose of ISTS SR 3.1.7.1 is to verify the analog rod position indicators (RPIs) are within the RPI System indication uncertainty of 12 steps by comparing the analog RPI to the Demand Position Indication System.
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| Question (1) - Which ITS LCO ACTIONS Conditions apply upon discovery that a rods group step counter demand position indication exceeds the Allowed Rod Misalignment with the rods RPI System indicated position?
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| FPL Response:
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| Upon discovery of a misalignment between a rods group step counter demand position and the rods analog rod position indication in MODE 1 or 2, the ACTIONS of ITS 3.1.4, "Rod Group Alignment Limits," are applied and associated Conditions entered unless the operator has evidence that the indication system is inoperable.
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| https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1707 1/3
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| 2/21/23, 9:56 AM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure With one rod not within alignment limits, ITS 3.1.4 Condition B applies and with more than one rod not within alignment limits, ITS 3.1.4 Conditions B and D apply.
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| If the operator determines that the Rod Position Indication (either the Demand Position Indication System or the RPI System) is inoperable in MODE 1 or 2 based on operational parameters (e.g., group demand position indication does not change when the Rod Control System moves a rod group as evidenced by each RPI in the group moving consistent with the number of Rod Control System pulses), the ACTIONS of ITS 3.1.7, Rod Position Indication, are applied and associated Conditions entered. With one RPI per group inoperable in one or more groups, ITS 3.1.7 Condition A applies and with more than one RPI per group inoperable in one or more groups, ITS 3.1.7 Conditions A and B apply. Additionally, ITS 3.1.7 Condition C is applied when the stated condition occurs. With one or more demand position indicators per bank inoperable in one or more banks, ITS 3.1.7 Condition D applies.
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| Question (2) - What is the Allowed Rod Misalignment acceptance criterion of the Channel Calibration and Channel Operational Test Surveillances specified by CTS 4.1.3.2.2 and Table 4.1-1, as stated in the actual plant surveillance procedures?
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| FPL Response:
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| There is no specific Allowed Rod Misalignment acceptance criterion for the operational test associated with the analog demand position indication specified in CTS 4.1.3.2.2 and Table 4.1-1. The operational test is a functional test of the demand position indication counters. The acceptance criterion for the demand position indicators is specified in CTS 3.1.3.2.b. This system, as described in the Background section of the ITS 3.1.7 Bases, counts pulses from the Rod Control System that moves each group of rods. Observation of the demand position indication counter changes within the CTS 3.1.3.2.b limit of +/- 2 steps as a result of a rod group movement from the Rod Control System satisfies the demand position operational test. Likewise, observation of individual analog RPI changes within the limits of CTS 3.1.3.2.a as a result of a rod group movement from the Rod Control System satisfies the individual rod position operational test.
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| The channel calibration requirement for the individual rod position indication specified in CTS 4.1.3.2.2 and Table 4.1-1 does not specify specific acceptance criteria. Plant surveillance procedures have adopted an administrative acceptance criterion to ensure the most accurate rod position indication. Each RPI is calibrated as close to actual rod position as practical such that during operation each analog rod position indicator agrees with the Demand Position Indication System within the allowed rod misalignment limits of CTS 3.1.3.1. The RPI System indication uncertainty, as specified by the manufacturer, is 12 steps as stated in the NRC safety evaluation of License Amendments 186 and 180 for PTN Units 3 and 4, respectively, dated July 12, 1996 (NRC ADAMS Accession No. ML013390277). This manufacturer uncertainty represents the channel calibration acceptance criterion for the analog RPI.
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| Question (3) - Is an ITS requirement not met in this situation?
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| FPL Response:
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| Yes. Based on the acceptance criteria provided in ISTS SR 3.1.7.1, ISTS LCO 3.1.7 is not met when an RPI does not agree within 12 steps of the group demand position for the full indicated range of rod travel in MODES 1 and 2. Because the acceptance criterion specified in CTS 3.1.3.1.a (ITS LCO 3.1.4.a) is greater than 12 steps when thermal power is 90% RTP, adoption if ISTS SR 3.1.7.1 creates the operational conflict as indicated herein. Therefore, FPL proposes to retain the current channel calibration requirement specified in CTS 4.1.3.2.2 and Table 4.1-1, as shown in Attachment 1 CCH021 LAR Markups instead of adopting ISTS SR 3.1.7.1. This change is consistent with that approved by the NRC in ITS conversions for DC Cook (ADAMS Accession Nos. ML050620034 and ML051530440) and Point Beach (ADAMS Accession Nos.
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| ML012250504.and ML012250387).
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| Question (4) - The licensee is requested to make appropriate changes to the ITS requirements related to the allowed rod misalignment of the rod position indication systems for a rod so that they are clear and no apparent conflict exists between LCO 3.1.4 and SR 3.1.7.1, FPL Response:
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| See Attachment 1 - CCH021 LAR Markups for the requested changes. Note that CCH021 LAR Markups associated with ITS 3.1.7 DOC L05 are based on changes first proposed in FPL's response to NRC RAI Question CCH009-1.
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| Attachment
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| : 1. CCH021 LAR Markups https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1707 2/3
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| 2/21/23, 9:56 AM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure
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| ===Response===
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| 02/21/2023 9:50 am Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long ID 1707 Added By Christina Long Date Added 2/21/2023 8:51 AM CST Modified By Date Modified Locked No https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1707 3/3
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| A01 ITS 3.1.4 ITS REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS 4.1.3.2.1 Each analog rod position indicator shall be determined to be OPERABLE by verifying that the Demand SR 3.1.4.1 Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of Specification 3.1.3.1 (allowing for one hour thermal soak after rod motion) in accordance with the Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is L09 inoperable, then compare the Demand Position Indication System and the Analog Rod Position Indication System at least once per 4 hours.
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| 4.1.3.2.2 Each of the above required analog rod position indicator(s) shall be determined to be OPERABLE by performance of a CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST performed in accordance with the Table 4.1-1.
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| See ITS 3.1.7 TURKEY POINT - UNITS 3 & 4 3/4 1-21 AMENDMENT NOS. 263 AND 258
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| DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS SR 3.1.1.1 every 24 hours. This change is acceptable since SDM will still be required to be monitored every 24 hours, and based on the definition of SDM the reactivity worth of any rod not capable of being fully inserted must be accounted for in the determination of SDM. Thus, SDM continues to be monitored in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.
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| L08 (Category 7 - Relaxation Of Surveillance Frequency Change - NON-24 MONTH TYPE CHANGE) CTS 3.1.3.1 states "within one hour after rod motion." ITS SR 3.1.4.1 Note states "Not required to be performed until 1 hour after associated rod motion." This changes the CTS by allowing verification after 1 hour.
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| The purpose of CTS 3.1.3.1 and ITS SR 3.1.4.1 is verification of position of individual rods within alignment limit. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Allowing verification after 1 hour may result in additional time to complete the Surveillance. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
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| L09 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.1.3.2.1 requires determining that each analog rod position indicator is OPERABLE by verifying that the Demand Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of CTS Specification 3.1.3.1 in accordance with the Surveillance Frequency Control Program (currently every 12 hours). When the Rod Position Deviation Monitor is inoperable the determination frequency is increased to at least once per 4 hours. ITS does not include this increased frequency when the Rod Position Deviation Monitor is inoperable. This changes the CTS by eliminating the increased alignment determination frequency based on OPERABILITY of the Rod Position Deviation Monitor.
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| The purpose of ITS 3.1.4 is to ensure that ensure that the assumptions in the safety analysis will remain valid and that the RCCAs and banks maintain the correct power distribution and rod alignment. This change is acceptable because the remaining Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the Frequency of monitoring Demand Position Indication and the Analog Rod Position Indication alignment when the Rod Position Deviation Monitor is inoperable is unnecessary as inoperability of the monitor does not increase the probability that RPI/Demand alignment is outside of its limit. The Rod Position Deviation Monitor is for indication only. Its use is not credited in any safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 8 of 8
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| CTS Rod Group Alignment Limits 3.1.4 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME 3.1.3.1 ACTION b, 3.1.3.1 ACTION c D.1.2 Initiate boration to restore 1 hour required SDM to within limit.
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| AND D.2 Be in MODE 3. 6 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.1.3.1.1 SR 3.1.4.1 ---------------------------- NOTES -----------------------------
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| 4.1.3.2.1 1. Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
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| 3.1.3.1 LCO
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| [ 2. Not required to be performed until 1 hour after 2 associated rod motion.]
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| Verify position of individual rods within alignment [ 12 hours limit. 2 OR In accordance with the Surveillance Frequency Control Program ] 2 4.1.3.1.2 SR 3.1.4.2 Verify rod freedom of movement (trippability) by [ 9 2 days 2 moving each rod not fully inserted in the core 10 steps in either direction. OR In accordance with the Surveillance Frequency 2
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| Control Program ]
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| Turkey Point Unit 3 and Unit 4 Westinghouse STS 3.1.4-3 Amendment Nos. XXX and YYY Rev. 5.0 1
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| A01 ITS ITS 3.1.7 REACTIVITY CONTROL SYSTEMS See ITS 3.1.4 SURVEILLANCE REQUIREMENTS 4.1.3.2.1 Each analog rod position indicator shall be determined to be OPERABLE by verifying that the Demand Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of Specification 3.1.3.1 (allowing for one hour thermal soak after rod motion) in accordance with the M02 Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the Demand Position Indication System and the Analog Rod Position Indication System at least once per 4 hours.
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| 4.1.3.2.2 Each of the above required analog rod position indicator(s) shall be determined to be OPERABLE by LA02 SR 3.1.7.1 performance of a CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST performed in accordance with the Table 4.1-1.
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| STET Add proposed SR 3.1.7.1 M02 Add proposed SR 3.1.7.1 Note L05 TURKEY POINT - UNITS 3 & 4 3/4 1-21 AMENDMENT NOS. 260 AND 255 Page 3 of 4
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| A01 ITS ITS 3.1.7 STET TABLE 4.1-1 L05 by CCH009-1 ROD POSITION INDICATOR SURVEILLANCE REQUIREMENTS Functional Unit Check Calibration Operational Test M02 SR 3.1.7.1 Individual Rod Position SFCP SFCP SFCP Demand Position SFCP N/A SFCP STET TURKEY POINT - UNITS 3 & 4 3/4 1-22 AMENDMENT NOS. 263 AND 258 Page 4 of 4
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| CCH021 Changes to CCH009-1 Response a CHANNEL CHECK or an ITS 3.1.7 DOC INSERTS ANALOG CHANNEL OPERATIONAL TEST requires performance of a CHANNEL INSERT DOC L05 CALIBRATION for each RPI.
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| (Category 5 - Deletion of Surveillance Requirement) CTS 4.1.3.2.2 requires a CHANNEL CHECK, CHANNEL CALIBRATION, and ANALOG CHANNEL OPERATIONAL TEST for each required analog rod position indicator as specified in Table 4.1-1. ITS 3.1.7 does not contain this Surveillance Requirement (SR) or Table 4.1-1 for the analog rod position indicators.
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| Additionally, ITS SR 3.1.7.1 is added and will require a verification that each rod position indicator (RPI) agrees within 12 steps of the group demand position for the full indicated range CHANNEL of rod travel. This verification will be performed once prior to criticality after each removal of the CALIBRATION reactor head. ITS SR 3.1.7.1 includes a note that the SR is not required to be met for RPI associated with a rod that is not within the alignment limits of limiting condition for operation (LCO) 3.1.4. The CTS is revised to conform to the ISTS. This changes the CTS by deleting surveillances. RPI detectors are excluded from CHANNEL CALIBRATION. OPERABLE The purpose of CTS 4.1.3.2.2 and testing specified in CTS Table 4.1-1 is to ensure that the individual rod position indicators (RPIs) and demand position indicators are capable of assessing OPERABILITY and misalignment of the shutdown and control rods. The Rod Position Indication System is an indication-only system and the RPI and demand position indicators do not function or actuate to mitigate a design basis accident or transient. The acceptance criteria for rod position indication are that rod positions must be known with sufficient accuracy in order to verify the core is operating within the group sequence, overlap, design peaking limits, ejected rod worth, and with minimum SHUTDOWN MARGIN. The rod SRs are positions must also be known in order to verify the alignment limits are preserved. This change is acceptable because the deleted SR is not necessary to verify that the equipment used to meet the LCO can perform their required functions. Other SRs retained in Technical Specifications and proposed ITS SR 3.1.7.1 continue to ensure the necessary quality of the RPIs and demand position indicators is maintained with sufficient accuracy to monitor rod positions. The Channel Check requirement specified in CTS Table 4.1-1 is redundant to CTS 4.1.3.1.1 (ITS SR 3.1.4.1). ITS SR 3.1.4.1 requires that the alignment limits (rod alignment is maintained between analog RPI and group step counter demand position) be verified at a frequency in accordance with the Surveillance Frequency Control Program (SFCP), which is currently every 12 hours. This rod alignment limit surveillance accomplishes the same and Table 4.1-1 verification as required by the Channel Check specified in CTS 4.1.3.2.2. In addition, CTS 4.1.3.1.2 (ITS SR 3.1.4.2) verifies rod freedom of movement (trippability) by moving each rod not fully inserted in the core 10 steps in either direction at a frequency in accordance with the ITS SFCP, which is currently every 18 months. Performance of ITS SR 3.1.4.2 confirms the OPERABILITY of each RPI and demand position indicator by periodically actuating the associated RPI channel and demand position indicator channel eliminating the need for a is calibrated periodic Channel Operational Test. ISTS SR 3.1.7.1 is being adopted, which verifies that each RPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. This SR ensures each RPI is operating correctly. This SR is performed prior to reactor criticality after each removal of the reactor head, as there is the potential for unnecessary plant transients if the SR were performed with the reactor at power. Calibration errors that could impact the capability of an RPI to determine the rod position with sufficient accuracy would be performance of identified during the performance of ITS SR 3.1.7.1 prior to criticality. Therefore, an explicit requirement to perform a Channel Calibration at a frequency in accordance with the SFCP, which is currently 18 months, is unnecessary. RPI detectors are excluded from the CHANNEL CALIBRATION because the periodic RPI detector consists of a stack of inductive coils that are not adjustable.
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| Page 4 of 6
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| CCH021 Changes to CCH009-1 Response ITS 3.1.7 DOC INSERTS in ITS 3.1.4, retaining the RPI CHANNEL CALIBRATION INSERT DOC L05 (continued) Surveillance (ITS SR 3.1.7.1),
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| The combination of the retained SRs, the addition of ITS SR 3.1.7.1, and considering that the RPIs are prominent in the control room and routinely observed by the operators, provides assurance the OPERABILITY of the analog rod position indicators are adequately monitored and maintained. Therefore, the analog rod position indicators (i.e., RPIs and group demand position indicators) continue to be tested in a manner and at a frequency necessary to give adequate confidence, pursuant to the requirements of 10 CFR 50.36(c)(3), that the necessary quality of systems and components is maintained, facility operation will be within safety limits, and that the Rod Position Indication LCO will be met. This change is designated as a less restrictive because Surveillances, which were required in the CTS, will not be required in the ITS.
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| Page 5 of 6
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| Rod Position Indication 3.1.7 CTS SURVEILLANCE REQUIREMENTS RPI detectors are excluded from SURVEILLANCE FREQUENCY CHANNEL CALIBRATION.
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| 4.1.3.2.2 SR 3.1.7.1 ----------------------------- NOTE ------------------------------
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| Not required to be met for [D]RPIs associated with DOC L05 rods that do not meet LCO 3.1.4. 4 1
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| Verify each [D]RPI agrees within [12] steps of the Once prior to Perform CHANNEL group demand position for the [full indicated range] criticality after CALIBRATION of each RPI. of rod travel. each removal of the reactor head Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-4 Rev. 5.0 3
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| JUSTIFICATION FOR DEVIATIONS ITS 3.1.7, ROD POSITION INDICATION
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| : 1. The Improved Standard Technical Specifications (ISTS) contain bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 2. ISTS 3.1.7 ACTION A provides compensatory actions when one rod position indicator is inoperable. Turkey Point Nuclear Generating Station (PTN) Improved Technical Specification (ITS) 3.1.7 provides an additional Required Action that can be taken when one rod position indicator is inoperable. The new Required Action allows the use of an alternate means other than the movable incore detectors to monitor the position of a control or shutdown rod when the analog rod position indication system is inoperable.
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| : 3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| See CH009-1 Response for other
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| : 4. Editorial changes made for enhanced clarity/consistency. changes to the ITS 3.1.7 JFDs
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| : 5. Changes are made to be consistent with the Specification.
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| : 4. ISTS SR 3.1.7.1 has been revised to be consistent with the current licensing basis requirement to perform a CHANNEL CALIBRATION for the analog rod position indicators. The ISTS requirement to verify each RPI agrees within 12 steps of the group demand position for the full indicated range of rod travel prior to criticality after each removal of the reactor vessel head is replaced with the requirement to perform a CHANNEL CALIBRATION of each RPI, except for the RPI detector. Because of the thermal drift characteristics of the PTN RPIs, performing a full range comparison of RPI and demand position before criticality is not useful, as the RPI response will change with RPI temperature. The ITS requires a CHANNEL CALIBRATION of each RPI, which involves calibrating the electronics to known input voltages. This change is consistent with that approved by the NRC in ITS conversions for DC Cook (ADAMS Accession Nos. ML050620034 and ML051530440) and Point Beach (ADAMS Accession Nos. ML012250504.and ML012250387).
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| Rod Position Indication B 3.1.7 BASES LCO LCO 3.1.7 specifies that one [ D] RPI System and one Bank Demand 2 Position Indication System be OPERABLE for each control rod. For the 1 control rod position indicators to be OPERABLE requires meeting the SR 5 of the LCO and the following:
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| 2
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| : a. The [ D] RPI System indicates within 12 steps of the group step counter demand position as required by LCO 3.1.4, " Rod Group a Alignment Limits,"
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| b 2
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| : b. For the [ D] RPI System there are no failed coils, and Position 1 4
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| : c. The Bank Demand Indication System has been calibrated either in 2
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| the fully inserted position or to the [ D] RPI System.
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| The 12 step agreement limit between the Bank Demand Position 1 Indication System and the [ D] RPI System indicates that the Bank 2 Demand Position Indication System is adequately calibrated, and can be used for indication of the measurement of control rod bank position.
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| A deviation of less than the allowable limit, given in LCO 3.1.4, in position indication for a single control rod, ensures high confidence that the position uncertainty of the corresponding control rod group is within the assumed values used in the analysis (that specified control rod group insertion limits).
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| These requirements ensure that control rod position indication during power operation and PHYSICS TESTS is accurate, and that design assumptions are not challenged.
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| OPERABILITY of the position indicator channels ensures that inoperable, misaligned, or mispositioned control rods can be detected. Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.
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| ---------------------------------- Reviewer' s Note ----------------------------------------
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| The bracketed LCO Note is only applicable to plants with an analog rod 6 position indication system.
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| [ The LCO is modified by a Note stating that the RPI system is not 2
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| required to be met OPERABLE for 1 hour following movement of the associated rods. Control and shutdown rod temperature affects the accuracy of the RPI System. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows temperature to stabilize following rod movement in order to ensure the indicated position is accurate.]
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7 -3 Rev. 5.0 1
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| Rod Position Indication B 3.1.7 BASES ACTIONS (continued)
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| D.2
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| <7 5 4
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| Reduction of THERMAL POWER to 50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factor limits (Ref. 3). The allowed Completion Time of 8 hours provides an acceptable period of time to verify the rod positions per Required Actions C.1.1 and C.1.2 or reduce power to 50% RTP. 4
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| <7 5 E.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours. The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
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| SURVEILLANCE SR 3.1.7 .1 REQUIREMENTS Verification that the [ D] RPI agrees with the demand position within
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| [ 12] steps ensures that the [ D] RPI is operating correctly. Since the 2
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| [ D] RPI does not display the actual shutdown rod positions between 18 and 210 steps, only points within the indicated ranges are required in comparison.
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| The CHANNEL CALIBRATION is a calibration of the indicating channel of each RPI and verification that the This Surveillance is performed prior to reactor criticality after each 4 channel responds to a measured removal of the reactor head, as there is the potential for unnecessary parameter within the necessary range plant transients if the SR were performed with the reactor at power.
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| and accuracy.
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| The Surveillance is modified by a Note which states it is not required to be met for [ D] RPIs associated with rods that do not meet LCO 3.1.4. If a 2 rod is known to not to be within [ 12] steps of the group demand position, the ACTIONS of LCO 3.1.4 provide the appropriate Actions.
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| The Surveillance is modified by a Note stating that the RPI detectors are excluded from the CHANNEL 4 CALIBRATION because the RPI detectors consist of a stack of inductive coils that are not adjustable.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7 -7 Rev. 5.0 1
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| 3/26/23, 4:06 PM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure Turkey Point ITS Conversion Database - New Logged In As: Christina Long March 26, 2023 Licensee Response/NRC Response/NRC Question Closure NRC Question Link View Question Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 03/24/2023 Date Notification Gregg Ellis Christina Long ID 1712 Added By Craig Harbuck Date Added 3/24/2023 9:35 PM CST Modified By Date Modified Locked No https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1712 1/1
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| 3/21/23, 9:24 AM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure Turkey Point ITS Conversion Database - New Logged In As: Christina Long March 21, 2023 Licensee Response/NRC Response/NRC Question Closure NRC Question View Question Link Select Licensee Response Application Attachment 1 1. Attachment 1 - CCH021-1 LAR Markups (23-03-15).pdf (3MB)
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| Attachment 2 Response Question (1) Attachment 1, page 2 of 11, ITS 3.1.4 Discussion of Change (DOC) L09 discusses the Statement acceptability of the change in paragraph two. The change explains that the increased frequency is unnecessary because the inoperability of the monitor does not increase the probability that RPI/Demand alignment is outside of its limit. This statement appears unnecessary to justify the change. Please clarify the discussion.
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| FPL Response The purpose of ITS 3.1.4 DOC L09 is to justify the deletion of an increased Frequency of verifying that the Demand Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment limits when the Rod Position Deviation Monitor is inoperable.
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| ITS 3.1.4 DOC L09 will be revised to remove the statement explaining how an inoperable Rod Position Deviation Monitor does not impact the probability of a rod misalignment and further clarify that, The specified Frequency takes into account other rod position information that is continuously available to the operator in the control room, so that during actual rod motion, deviations can immediately be detected."
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| Refer to CCH021-1 Attachment 1 for changes.
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| Question (2) Attachment 1 page 6 of 11 discusses the alignment limits between the rod position indicators and their group step counter demand position indication. Please clarify if the group step counter demand position is analog or digital.
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| FPL Response The individual rod position indicators are analog while the demand position indication is digital.
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| ITS 3.1.7 DOC L05 is revised to delete the word analog where it is not needed to enhance readability and avoid confusion. Refer to CCH021-1 Attachment 1 for changes.
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| Question (3) Attachment 1, page 6 of 11 the last sentence describes the performance of a channel calibration. Should this be the performance of a channel operational test (COT)?
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| FPL Response This sentence is intended to refer to the Channel Calibration and not a COT. This sentence provides the conclusion that the proposed Channel Calibration frequency of, "Once prior to criticality after each removal of the reactor head," is adequate and the Frequency of, "In accordance with the SFCP," is not necessary.
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| The subject sentence will be revised for clarity. Refer to CCH021-1 Attachment 1 for changes.
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| Question (4) Attachment 1 page 10 of 11 last paragraph, first sentence does not appear to make sense.
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| Although it is recognized that this sentence is consistent with NUREG-1431, please consider revising the ITS 3.1.7.1 Bases text to enhance the readability.
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| FPL Response https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1711 1/2
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| 3/21/23, 9:24 AM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure FPL has reviewed this paragraph and revised as shown in Attachment 1 to CCH021-1 response. Refer to CCH021-1, Attachment 1 for details.
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| Question (5) Please provide the NRC ADAMS Accession number for the PTN license amendment that approved the use of an 18-step rod misalignment when less than 90% RTP to assist in the NRC review.
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| FPL Response The PTN license amendments that approved revision to the rod misalignment requirements allowing operation up to +/- 18 steps of rod misalignment at or below 90 percent power was license amendments 186 and 180, dated July 12, 1996, for Unit 3 and Unit 4, respectively (NRC ADAMS Accession No. ML013390277).
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| Attachments
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| : 1. CCH021-1 LAR Markups
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| ===Response===
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| 03/21/2023 9:25 am Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long ID 1711 Added By Christina Long Date Added 3/21/2023 8:24 AM CST Modified By Date Modified Locked No https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1711 2/2
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| A01 ITS 3.1.4 ITS REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS 4.1.3.2.1 Each analog rod position indicator shall be determined to be OPERABLE by verifying that the Demand SR 3.1.4.1 Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of Specification 3.1.3.1 (allowing for one hour thermal soak after rod motion) in accordance with the Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is L09 inoperable, then compare the Demand Position Indication System and the Analog Rod Position Indication System at least once per 4 hours.
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| 4.1.3.2.2 Each of the above required analog rod position indicator(s) shall be determined to be OPERABLE by performance of a CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST performed in accordance with the Table 4.1-1.
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| See ITS 3.1.7 TURKEY POINT - UNITS 3 & 4 3/4 1-21 AMENDMENT NOS. 263 AND 258
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| DISCUSSION OF CHANGES ITS 3.1.4, ROD GROUP ALIGNMENT LIMITS SR 3.1.1.1 every 24 hours. This change is acceptable since SDM will still be required to be monitored every 24 hours, and based on the definition of SDM the reactivity worth of any rod not capable of being fully inserted must be accounted for in the determination of SDM. Thus, SDM continues to be monitored in a manner and at a Frequency necessary to give confidence that the assumptions in the safety analyses are protected. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.
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| L08 (Category 7 - Relaxation Of Surveillance Frequency Change - NON-24 MONTH TYPE CHANGE) CTS 3.1.3.1 states "within one hour after rod motion." ITS SR 3.1.4.1 Note states "Not required to be performed until 1 hour after associated rod motion." This changes the CTS by allowing verification after 1 hour.
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| The purpose of CTS 3.1.3.1 and ITS SR 3.1.4.1 is verification of position of individual rods within alignment limit. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Allowing verification after 1 hour may result in additional time to complete the Surveillance. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
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| L09 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.1.3.2.1 requires determining that each analog rod position indicator is OPERABLE by verifying that the Demand Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of CTS Specification 3.1.3.1 in accordance with the Surveillance Frequency Control Program (currently every 12 hours). When the Rod Position Deviation Monitor is inoperable the determination frequency is increased to at least once per 4 hours. ITS does not include this increased frequency when the Rod Position Deviation Monitor is inoperable. This changes the CTS by eliminating the increased alignment determination frequency based on OPERABILITY of the Rod Position Deviation Monitor.
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| The purpose of ITS 3.1.4 is to ensure that the assumptions in the safety analysis will remain valid and that the RCCAs and banks maintain the correct power distribution and rod alignment. This change is acceptable because the remaining Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. The specified Frequency also takes account other rod position information that is continuously available to the operator in the control room, so that during actual rod motion, deviations can immediately be detected. The Rod Position Deviation Monitor is for indication only. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 8 of 8
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| CTS Rod Group Alignment Limits 3.1.4 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME 3.1.3.1 ACTION b, 3.1.3.1 ACTION c D.1.2 Initiate boration to restore 1 hour required SDM to within limit.
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| AND D.2 Be in MODE 3. 6 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.1.3.1.1 SR 3.1.4.1 ---------------------------- NOTES -----------------------------
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| 4.1.3.2.1 1. Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
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| 3.1.3.1 LCO
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| [ 2. Not required to be performed until 1 hour after 2 associated rod motion.]
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| Verify position of individual rods within alignment [ 12 hours limit. 2 OR In accordance with the Surveillance Frequency Control Program ] 2 4.1.3.1.2 SR 3.1.4.2 Verify rod freedom of movement (trippability) by [ 9 2 days 2 moving each rod not fully inserted in the core 10 steps in either direction. OR In accordance with the Surveillance Frequency 2
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| Control Program ]
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| Turkey Point Unit 3 and Unit 4 Westinghouse STS 3.1.4-3 Amendment Nos. XXX and YYY Rev. 5.0 1
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| A01 ITS ITS 3.1.7 See ITS 3.1.4 REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS 4.1.3.2.1 Each analog rod position indicator shall be determined to be OPERABLE by verifying that the Demand Position Indication System and the Analog Rod Position Indication System agree within the Allowed Rod Misalignment of Specification 3.1.3.1 (allowing for one hour thermal soak after rod motion) in accordance with the M02 Surveillance Frequency Control Program except during time intervals when the Rod Position Deviation Monitor is inoperable, then compare the Demand Position Indication System and the Analog Rod Position Indication System at least once per 4 hours.
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| 4.1.3.2.2 Each of the above required analog rod position indicator(s) shall be determined to be OPERABLE by LA02 SR 3.1.7.1 performance of a CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST performed in accordance with the Table 4.1-1.
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| STET Add proposed SR 3.1.7.1 M02 Add proposed SR 3.1.7.1 Note L05 TURKEY POINT - UNITS 3 & 4 3/4 1-21 AMENDMENT NOS. 260 AND 255 Page 3 of 4
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| A01 ITS ITS 3.1.7 STET TABLE 4.1-1 L05 ROD POSITION INDICATOR SURVEILLANCE REQUIREMENTS Functional Unit Check Calibration Operational Test M02 SR 3.1.7.1 Individual Rod Position SFCP SFCP SFCP Demand Position SFCP N/A SFCP STET TURKEY POINT - UNITS 3 & 4 3/4 1-22 AMENDMENT NOS. 263 AND 258 Page 4 of 4
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| CCH021 Changes to CCH009-1 Response a CHANNEL CHECK or an ITS 3.1.7 DOC INSERTS ANALOG CHANNEL OPERATIONAL TEST requires performance of a CHANNEL INSERT DOC L05 CALIBRATION for each RPI.
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| (Category 5 - Deletion of Surveillance Requirement) CTS 4.1.3.2.2 requires a CHANNEL CHECK, CHANNEL CALIBRATION, and ANALOG CHANNEL OPERATIONAL TEST for each required analog rod position indicator as specified in Table 4.1-1. ITS 3.1.7 does not contain this Surveillance Requirement (SR) or Table 4.1-1 for the analog rod position indicators.
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| Additionally, ITS SR 3.1.7.1 is added and will require a verification that each rod position indicator (RPI) agrees within 12 steps of the group demand position for the full indicated range CHANNEL of rod travel. This verification will be performed once prior to criticality after each removal of the CALIBRATION reactor head. ITS SR 3.1.7.1 includes a note that the SR is not required to be met for RPI associated with a rod that is not within the alignment limits of limiting condition for operation (LCO) 3.1.4. The CTS is revised to conform to the ISTS. This changes the CTS by deleting surveillances. RPI detectors are excluded from CHANNEL CALIBRATION. OPERABLE The purpose of CTS 4.1.3.2.2 and testing specified in CTS Table 4.1-1 is to ensure that the individual rod position indicators (RPIs) and demand position indicators are capable of assessing OPERABILITY and misalignment of the shutdown and control rods. The Rod Position Indication System is an indication-only system and the RPI and demand position indicators do not function or actuate to mitigate a design basis accident or transient. The acceptance criteria for rod position indication are that rod positions must be known with sufficient accuracy in order to verify the core is operating within the group sequence, overlap, design peaking limits, ejected rod worth, and with minimum SHUTDOWN MARGIN. The rod SRs are positions must also be known in order to verify the alignment limits are preserved. This change is acceptable because the deleted SR is not necessary to verify that the equipment used to meet the LCO can perform their required functions. Other SRs retained in Technical Specifications and proposed ITS SR 3.1.7.1 continue to ensure the necessary quality of the RPIs and demand position indicators is maintained with sufficient accuracy to monitor rod positions. The Channel Check requirement specified in CTS Table 4.1-1 is redundant to CTS 4.1.3.1.1 (ITS SR 3.1.4.1). ITS SR 3.1.4.1 requires that the alignment limits (rod alignment is maintained between analog RPI and group step counter demand position) be verified at a frequency in accordance with the Surveillance Frequency Control Program (SFCP), which is currently every 12 hours. This rod alignment limit surveillance accomplishes the same and Table 4.1-1 verification as required by the Channel Check specified in CTS 4.1.3.2.2. In addition, CTS 4.1.3.1.2 (ITS SR 3.1.4.2) verifies rod freedom of movement (trippability) by moving each rod not fully inserted in the core 10 steps in either direction at a frequency in accordance with the ITS SFCP, which is currently every 18 months. Performance of ITS SR 3.1.4.2 confirms the OPERABILITY of each RPI and demand position indicator by periodically actuating the associated RPI channel and demand position indicator channel eliminating the need for a is calibrated periodic Channel Operational Test. ISTS SR 3.1.7.1 is being adopted, which verifies that each RPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. This SR ensures each RPI is operating correctly. This SR is performed prior to reactor criticality after each removal of the reactor head, as there is the potential for unnecessary plant transients if the SR were performed with the reactor at power. Calibration errors that could impact the capability of an RPI to determine the rod position with sufficient accuracy would be performance of identified during the performance of ITS SR 3.1.7.1 prior to criticality. Therefore, an explicit requirement to perform a Channel Calibration at a frequency in accordance with the SFCP, which is currently 18 months, is unnecessary. RPI detectors are excluded from the CHANNEL CALIBRATION because the RPI detector consists of a stack of inductive coils that are not adjustable.
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| Page 4 of 6
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| CCH021 Changes to CCH009-1 Response ITS 3.1.7 DOC INSERTS in ITS 3.1.4, retaining the RPI CHANNEL CALIBRATION INSERT DOC L05 (continued) Surveillance (ITS SR 3.1.7.1),
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| The combination of the retained SRs, the addition of ITS SR 3.1.7.1, and considering that the RPIs are prominent in the control room and routinely observed by the operators, provides assurance the OPERABILITY of the analog rod position indicators are adequately monitored and maintained. Therefore, the analog rod position indicators (i.e., RPIs and group demand position indicators) continue to be tested in a manner and at a frequency necessary to give adequate confidence, pursuant to the requirements of 10 CFR 50.36(c)(3), that the necessary quality of systems and components is maintained, facility operation will be within safety limits, and that the Rod Position Indication LCO will be met. This change is designated as a less restrictive because Surveillances, which were required in the CTS, will not be required in the ITS.
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| Page 5 of 6
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| Rod Position Indication 3.1.7 CTS SURVEILLANCE REQUIREMENTS RPI detectors are excluded from SURVEILLANCE FREQUENCY CHANNEL CALIBRATION.
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| 4.1.3.2.2 SR 3.1.7.1 ----------------------------- NOTE ------------------------------
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| Not required to be met for [D]RPIs associated with DOC L05 rods that do not meet LCO 3.1.4. 4 1
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| Verify each [D]RPI agrees within [12] steps of the Once prior to Perform CHANNEL group demand position for the [full indicated range] criticality after CALIBRATION of each RPI. of rod travel. each removal of the reactor head Turkey Point Unit 3 and Unit 4 Amendment Nos XXX and YYY Westinghouse STS 3.1.7-4 Rev. 5.0 3
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| JUSTIFICATION FOR DEVIATIONS ITS 3.1.7, ROD POSITION INDICATION
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| : 1. The Improved Standard Technical Specifications (ISTS) contain bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 2. ISTS 3.1.7 ACTION A provides compensatory actions when one rod position indicator is inoperable. Turkey Point Nuclear Generating Station (PTN) Improved Technical Specification (ITS) 3.1.7 provides an additional Required Action that can be taken when one rod position indicator is inoperable. The new Required Action allows the use of an alternate means other than the movable incore detectors to monitor the position of a control or shutdown rod when the analog rod position indication system is inoperable.
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| : 3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| See CH009-1 Response for other
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| : 4. Editorial changes made for enhanced clarity/consistency. changes to the ITS 3.1.7 JFDs
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| : 5. Changes are made to be consistent with the Specification.
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| : 4. ISTS SR 3.1.7.1 has been revised to be consistent with the current licensing basis requirement to perform a CHANNEL CALIBRATION for the analog rod position indicators. The ISTS requirement to verify each RPI agrees within 12 steps of the group demand position for the full indicated range of rod travel prior to criticality after each removal of the reactor vessel head is replaced with the requirement to perform a CHANNEL CALIBRATION of each RPI, except for the RPI detector. Because of the thermal drift characteristics of the PTN RPIs, performing a full range comparison of RPI and demand position before criticality is not useful, as the RPI response will change with RPI temperature. The ITS requires a CHANNEL CALIBRATION of each RPI, which involves calibrating the electronics to known input voltages. This change is consistent with that approved by the NRC in ITS conversions for DC Cook (ADAMS Accession Nos. ML050620034 and ML051530440) and Point Beach (ADAMS Accession Nos. ML012250504.and ML012250387).
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| Rod Position Indication B 3.1.7 BASES LCO LCO 3.1.7 specifies that one [ D] RPI System and one Bank Demand 2 Position Indication System be OPERABLE for each control rod. For the 1 control rod position indicators to be OPERABLE requires meeting the SR 5 of the LCO and the following:
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| 2
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| : a. The [ D] RPI System indicates within 12 steps of the group step counter demand position as required by LCO 3.1.4, " Rod Group a Alignment Limits,"
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| b 2
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| : b. For the [ D] RPI System there are no failed coils, and Position 1 4
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| : c. The Bank Demand Indication System has been calibrated either in 2
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| the fully inserted position or to the [ D] RPI System.
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| The 12 step agreement limit between the Bank Demand Position 1 Indication System and the [ D] RPI System indicates that the Bank 2 Demand Position Indication System is adequately calibrated, and can be used for indication of the measurement of control rod bank position.
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| A deviation of less than the allowable limit, given in LCO 3.1.4, in position indication for a single control rod, ensures high confidence that the position uncertainty of the corresponding control rod group is within the assumed values used in the analysis (that specified control rod group insertion limits).
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| These requirements ensure that control rod position indication during power operation and PHYSICS TESTS is accurate, and that design assumptions are not challenged.
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| OPERABILITY of the position indicator channels ensures that inoperable, misaligned, or mispositioned control rods can be detected. Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.
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| ---------------------------------- Reviewer' s Note ----------------------------------------
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| The bracketed LCO Note is only applicable to plants with an analog rod 6 position indication system.
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| [ The LCO is modified by a Note stating that the RPI system is not 5 2 required to be met OPERABLE for 1 hour following movement of the associated rods. Control and shutdown rod temperature affects the accuracy of the RPI System. Due to changes in the magnetic permeability of the drive shaft as a function of temperature, the indicated position is expected to change with time as the drive shaft temperature changes. The one hour period allows temperature to stabilize following rod movement in order to ensure the indicated position is accurate.]
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7 -3 Rev. 5.0 1
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| Rod Position Indication B 3.1.7 BASES ACTIONS (continued)
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| D.2
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| <7 5 4
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| Reduction of THERMAL POWER to 50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factor limits (Ref. 3). The allowed Completion Time of 8 hours provides an acceptable period of time to verify the rod positions per Required Actions C.1.1 and C.1.2 or reduce power to 50% RTP. 4
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| <7 5 E.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours. The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
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| SURVEILLANCE SR 3.1.7 .1 REQUIREMENTS Verification that the [ D] RPI agrees with the demand position within
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| [ 12] steps ensures that the [ D] RPI is operating correctly. Since the 2
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| [ D] RPI does not display the actual shutdown rod positions between 18 and 210 steps, only points within the indicated ranges are required in comparison.
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| The CHANNEL CALIBRATION is a calibration of the indicating channel of each RPI and verification that the This Surveillance is performed prior to reactor criticality after each 4 channel responds to a measured removal of the reactor head, as there is the potential for unnecessary parameter within the necessary range plant transients if the SR were performed with the reactor at power.
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| and accuracy.
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| The Surveillance is modified by a Note which states it is not required to be met for [ D] RPIs associated with rods that do not meet LCO 3.1.4. If a 2 rod is known to not to be within [ 12] steps of the group demand position, the ACTIONS of LCO 3.1.4 provide the appropriate Actions.
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| The Surveillance is modified by a Note stating that the RPI detectors are excluded from the CHANNEL 4 CALIBRATION because the RPI detectors consist of a stack of inductive coils that are not adjustable.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.1.7 -7 Rev. 5.0 1
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| 3/26/23, 4:06 PM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure Turkey Point ITS Conversion Database - New Logged In As: Christina Long March 26, 2023 Licensee Response/NRC Response/NRC Question Closure NRC Question Link View Question Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 03/24/2023 Date Notification Gregg Ellis Christina Long ID 1712 Added By Craig Harbuck Date Added 3/24/2023 9:35 PM CST Modified By Date Modified Locked No https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1712 1/1
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| 5/20/22, 10:41 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 567 NRC Question CET001 Number Category Editorial ITS Section 3.0 ITS Number 3.0 DOC Number JFD Number JFD Bases Number Page 8 of 64 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question The title on the top of the page is shown as 3.0 LCO APPLICABILITY. Please modify to state: 3.0 LCO Applicability to match STS or provide a JFD.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Caroline Tilton Date Modified Modified By Date Added 5/19/2022 2:23 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=567 1/1
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| 8/12/22, 10:12 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 823 NRC Question CET001 Number Select Licensee Response Application Attachment Attachment 1 - CET001 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response FPL will change the title, LCO APPLICABILITY, on top of page 3/4 0-2 of the ITS 3.0 CTS Markup, to LCO Statement Applicability. In addition, the title, SR APPLICABILITY, on top of page 3/4 0-4 will be changed to SR Applicability. These changes are covered by ITS 3.0 Discussion of Changes (DOC), A01. See Attachment 1
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| - CET001 LAR Markups.
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| Attachments: 1. CET001 LAR Markups
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| ===Response===
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| 6/5/2022 7:05 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 6/5/2022 6:03 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=823 1/1
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| ITS Section 3.0 ITS Applicability A01 3.0 LCO APPLICABILITY A01 LIMITING CONDITIONS FOR OPERATION (Continued)
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| LCO Conditions and Required Actions LCO 3.0.10 3.0.5 Limiting Conditions for Operation including the associated ACTION requirements shall apply to each unit individually unless otherwise indicated as follows: A01 LCO
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| : a. Whenever the Limiting Conditions for Operation refers to systems or components which are shared by both units, the ACTION requirements will apply to both units simultaneously.
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| LCO Conditions and Required Actions A03
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| : b. Whenever the Limiting Conditions for Operation applies to only one unit, this will be identified in the APPLICABILITY section of the specification; and
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| : c. Whenever certain portions of a specification contain operating parameters, Setpoints, etc.,
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| which are different for each unit, this will be identified in parentheses, footnotes or body of the requirement.
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| S LCO 3.0.5 3.0.6 Equipment removed from service or declared inoperable to comply with ACTION requirements may be A01 returned to service under administrative controls solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.1 and 3.0.2 for A08 the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
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| LCO 3.0.6 3.0.7 When a supported system LCO is not met solely due to a support system LCO not being met, the A03 Conditions and ACTIONS associated with this supported system are not required to be entered. Only the support system Required Actions LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system.
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| 5.5.12 In this event, an evaluation shall be performed in accordance with Specification 6.8.4.q, "Safety Function A01 Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONS of the LCO in which the loss of safety function exists are required to be entered.
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| Conditions and Required Actions Required Actions A03 When a support system's ACTION directs a supported system to be declared inoperable or directs entry into the ACTIONS for a supported system, the applicable ACTIONS shall be entered in accordance with LCO 3.0.2. Conditions and Required Actions LCO 3.0.7 INSERT 2 A09 LCO 3.0.9 INSERT 3 L01 TURKEY POINT - UNITS 3 & 4 3/4 0-2 AMENDMENT NOS. 287 AND 281 A01 Page 4 of 11
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| ITS Section 3.0 Applicability A01 ITS 3.0 SR APPLICABILITY A01 SURVEILLANCE REQUIREMENTS (CONTINUED)
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| : b. DELETED
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| : c. DELETED
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| : d. DELETED A01
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| : e. DELETED
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| : f. DELETED SR 3.0.5 4.0.6 Surveillance Requirements shall apply to each unit individually unless otherwise indicated as stated in LCO 3.0.10 Specification 3.0.5 for individual specifications or whenever certain portions of a specification contain A01 surveillance parameters different for each unit, which will be identified in parentheses, footnotes or body of the requirement.
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| A01 TURKEY POINT - UNITS 3 & 4 3/4 0-4 AMENDMENT NOS. 281 AND 275 Page 8 of 11
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| 6/8/22, 12:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 903 NRC Question CET001 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/8/2022 Date Notification Gregg Ellis Christina Long Added By Caroline Tilton Date Added 6/8/2022 9:57 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=903 1/1
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| 5/20/22, 10:41 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 587 NRC Question CET002 Number Category Editorial ITS Section 3.0 ITS Number 3.0 DOC Number JFD Number JFD Bases Number Page Number(s) 9 of 64 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Question The last paragraph under the insert for new LCO 3.0.9 is formatted in a different font.
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| Please correct to be consistent with STS.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Caroline Tilton Date Modified Modified By Date Added 5/19/2022 2:29 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=587 1/1
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| 8/12/22, 10:13 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 827 NRC Question CET002 Number Select Licensee Response Application Attachment 1 Attachment 1 - CET002 LAR Markups.pdf (1MB)
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| Attachment 2 Response FPL will change the font of the last paragraph of ITS 3.0 CTS Markup Insert 3 (for LCO 3.0.9) to Arial 11.
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| Statement See Attachment 1 - CET002 LAR Markups.
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| Attachments
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| : 1. CET002 LAR Markups
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| ===Response===
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| 6/5/2022 7:05 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 6/5/2022 6:05 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=827 1/1
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| A09 INSERT 2 3.0.7 Test Exception LCO 3.1.8 allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.
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| L01 INSERT 3 3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.
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| If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).
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| At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.
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| Font changed to Arial 11 Insert Page 3/4 0-2 Page 5 of 11
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| 6/8/22, 12:30 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 911 NRC Question CET002 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/8/2022 Date Notification Gregg Ellis Christina Long Added By Caroline Tilton Date Added 6/8/2022 10:04 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=911 1/1
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| 5/20/22, 10:40 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 599 NRC Question CET003 Number Category Editorial ITS Section 3.0 ITS Number 3.0 DOC Number JFD Number JFD Bases Number Page Number(s) 10 of 64 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Question The title at the top of the page is missing the 3.0 before SURVEILLANCE REQUIREMENTS to be consistent with STS. Please modify accordingly.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Caroline Tilton Date Modified Modified By Date Added 5/19/2022 2:31 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=599 1/1
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| 8/12/22, 10:13 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 831 NRC Question CET003 Number Select Licensee Response Application Attachment Attachment 1 - CET003 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response FPL will add "3.0" before SURVEILLANCE REQUIREMENTS" on page 3/4.0-3 of the ITS 3.0 CTS Markup.
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| Statement This change is covered by ITS 3.0 Discussion of Change (DOC) A01. See Attachment 1 - CET003 LAR Markups.
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| Attachments
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| : 1. CET003 LAR Markups
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| | |
| ===Response===
| |
| 6/5/2022 7:10 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 6/5/2022 6:08 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=831 1/1
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| ITS Section 3.0 ITS A01 3.0 APPLICABILITY (SR) APPLICABILITY A01 SURVEILLANCE REQUIREMENTS in the Applicability for individual LCOs, SRs specified SR 3.0.1 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 the SR Surveillance Requirement. Failure to perform a Surveillance Requirement within the allowed A01 INSERT 4 specified surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the Frequency OPERABILITY requirements for a Limiting Condition for Operation. Surveillance Requirements do not have to be performed on inoperable equipment. be failure to meet the LCO except as provided in SR 3.0.3 A10 INSERT 5 or variables outside specified limits SR 3.0.2 4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with a maximum M02 allowable extension not to exceed 25% of the surveillance interval. If an ACTION item requires periodic Completion Time performance on a once per . . . basis, the above frequency extension applies to each performance A01 after the initial performance. Exceptions to this Specification are stated in the individual Specifications.
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| SR 3.0.3 4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance LCO with the requirement to declare the Limiting Condition of Operation not met may be delayed, from the A01 time of discovery, up to 24 hours or up to the limit of the specified frequency, whichever is greater. This INSERT 6 delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed L02 for any Surveillance delayed greater than 24 hours and the risk impact shall be managed.
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| LCO If the surveillance is not performed within the delay period, the Limiting Condition of Operation must A01 immediately be declared not met, and the applicable ACTION(s) must be entered.
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| Condition LCO When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting A01 Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be entered. Condition SR 3.0.4 4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when SR 3.0.3 the LCOs Surveillances have been met within their specified frequency, except as provided by A01 Specification 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO Specification 3.0.4.
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| This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| 4.0.5 DELETED
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| : a. DELETED A01 A01 TURKEY POINT - UNITS 3 & 4 3/4 0-3 AMENDMENT NOS. 281 AND 275 Page 6 of 11
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| 6/8/22, 12:30 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 915 NRC Question CET003 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/8/2022 Date Notification Gregg Ellis Christina Long Added By Caroline Tilton Date Added 6/8/2022 10:10 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=915 1/1
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| 5/20/22, 10:40 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 607 NRC Question CET004 Number Category Editorial ITS 3.0 Section ITS 3.0 Number DOC Number JFD Number JFD Bases Number Page 6 of 64 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Page 6, LCO 3.0.3 proposes adding a capital S to ACTIONS in the following premise: [] associated Question ACTION is not provided This proposed change is not consistent with STS and adds a typo to the premise. Please review and modify accordingly.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Caroline Tilton Date Modified Modified By Date 5/19/2022 2:33 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=607 1/1
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| 8/12/22, 10:14 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 835 NRC Question CET004 Number Select Licensee Response Application Attachment 1 Attachment 1 - CET004 LAR Markups.pdf (75KB)
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| Attachment 2 Response FPL will delete the "S" insert added to "ACTION" in the first sentence of in the ITS 3.0 CTS Markup on Statement page 3/4 0-1. See Attachment 1 - CET004 LAR Markup.
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| Attachments
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| : 1. CET004 LAR Markup
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| | |
| ===Response===
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| 6/5/2022 7:15 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 6/5/2022 6:15 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=835 1/1
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| ITS Section 3.0 ITS A01
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| .0 (LCO) 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS A01 3/4.0 APPLICABILITY LIMITING CONDITIONS FOR OPERATION LCO 3.0.1 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as A02 provided in LCO 3.0.2. , LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9 Required Actions of the associated Conditions A01 LCO 3.0.2 3.0.2 Upon discovery of a failure to meet an LCO, the ACTIONS shall be met, except as provided in LCO 3.0.6 5 and LCO 3.0.7. If the LCO is met or is no longer applicable prior to expiration of the specified time 6 A03 interval, completion of the ACTION(S) is not required unless otherwise stated.
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| an LCO Completion Time(s) Required Action(s) and the associated ACTIONS are not met, an LCO 3.0.3 3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION A01 INSERT 1 requirements, within 1 hour action shall be initiated to place the unit, as applicable, in: S MODE 3 7 A04
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| : a. At least HOT STANDBY within the next 6 hours, MODE 4 13 A05
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| : b. At least HOT SHUTDOWN within the following 6 hours, and MODE 5 37
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| : c. At least COLD SHUTDOWN within the subsequent 24 hours.
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| this Specification Exceptions to these requirements are stated in the individual specifications. A01 in accordance with the LCO or S, Where corrective measures are completed that permit operation under the ACTION requirements, the action may be taken in accordance with the specified time limits as measured from the time of failure to A06 meet the Limiting Condition for Operation. completion of the actions required by LCO 3.0.3 is not required.
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| This specification is not applicable in MODES 5 or 6. A07 LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4 LCO 3.0.4 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
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| : a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
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| : b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or A01
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| ( );
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| : c. When an allowance is stated in the individual value, parameter, or other Specification.
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| This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| A01 TURKEY POINT - UNITS 3 & 4 3/4 0-1 AMENDMENT NOS. 287 AND 281 Page 2 of 11
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| 6/8/22, 12:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 927 NRC Question CET004 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/8/2022 Date Notification Gregg Ellis Christina Long Added By Caroline Tilton Date Added 6/8/2022 10:20 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=927 1/1
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| 5/20/22, 10:37 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 651 NRC Question CET005 Number Category Editorial ITS Section 1.0 ITS Number 1.0 DOC Number JFD Number JFD Bases Number Page 19 of 66 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question The MODES table is numbered in ITS as 1-1 in the markup. However, it should be numbered as 1.1-1 since it is contained in ITS 1.1. Please review and update accordingly.
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| Attach File 1 Attach File 2 Issue Date 5/20/2022 Added By Caroline Tilton Date Modified Modified By Date Added 5/20/2022 9:34 AM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=651 1/1
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| 8/12/22, 10:14 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 839 NRC Question CET005 Number Select Licensee Response Application Attachment 1 Attachment 1 - CET005 LAR Markups.pdf (1MB)
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| Attachment 2 Response FPL will add 1 in front of -1 (page 1 of 1) to the MODES Table title insert on page 1-8 of ITS 1.0 CTS Statement Markup. See Attachment 1 - CET005 LAR Markup.
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| Attachments
| |
| : 1. CET005 LAR Markup
| |
| | |
| ===Response===
| |
| 6/5/2022 7:20 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 6/5/2022 6:19 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=839 1/1
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| | |
| ITS Definitions A01 1 1.1 Table 1.1-1 TABLE 1.2 -1 (page 1 of 1) A01 OPERATIONAL MODES A01 REACTOR (a)
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| REACTIVITY % RATED AVERAGE COOLANT THERMAL POWER*
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| TITLE CONDITION, Keff MODE TEMPERATURE
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| : 1. POWER OPERATION 0.99 > 5% 350°F NA o F
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| : 2. STARTUP 0.99 5% 350°F NA
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| : 3. HOT STANDBY < 0.99 0 NA 350°F
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| : 4. HOT SHUTDOWN (b) 0 NA 350°F > Tavg A12
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| < 0.99
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| > 200°F (b)
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| : 5. COLD SHUTDOWN < 0.99 0 NA 200°F LA01
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| : 6. REFUELING** (c) 0.95 NA 0 NA 140°F NA A01 (a) *Excluding decay heat. One or more reactor A01 (c) **Fuel in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed.
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| A09 (b) All reactor vessel head closure bolts fully tensioned.
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| Add proposed ITS Sections 1.2 - Logical Connections A13 1.3 - Completion Times 1.4 - Frequency TURKEY POINT - UNITS 3 & 4 1-8 1.1-X AMENDMENT NOS. 137 AND 132 Page 15 of 17
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| 6/8/22, 12:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 931 NRC Question CET005 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/8/2022 Date Notification Gregg Ellis Christina Long Added By Caroline Tilton Date Added 6/8/2022 10:39 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=931 1/1
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| 8/12/22, 10:15 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 8 NRC Question CLA001 Number Select Licensee Response Application Attachment Attachment 1 - LAR Markup.pdf (117KB) 1 Attachment 2
| |
| Response The punctuation comments identified in the question above have been resolved. In conjunction with Statement updating the ITS markup file, reference to CTS Discussion of Changes (DOCs) were added in the left column of ITS markup pages 5.6-4 and 5.6-5 in accordance with the guidance provided by the NRC entitled, "Expectations for Licensees Responses to Improved Technical Specification (ITS) Conversion License Amendment Request (LAR) and Requests for Additional Information (RAIs)" (NRC ADAMS Accession No. ML22054A166). In this respect, a reference to DOC M01 was added to the following ITS 5.6.6 bullets: b, d, and f.
| |
| Attachment
| |
| : 1. CLA001 LAR Markups
| |
| | |
| ===Response===
| |
| 3/8/2022 12:00 AM Date/Time Closure Statement Question Closure Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 3/8/2022 8:22 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=8 1/1
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| | |
| Reporting Requirements CTS 5.6 5.6 Reporting Requirements 5.6.4 RCS PRESSURE AND TEMPERATURE LIMITS REPORT (continued)
| |
| : 7. The minimum temperature requirements of Appendix G to 10 CFR Part 50 shall be incorporated into the pressure and temperature limit curves.
| |
| : 8. Licensees who have removed two or more capsules should compare for 4
| |
| each surveillance material the measured increase in reference temperature (RTNDT) to the predicted increase in RTNDT; where the predicted increase in RTNDT is based on the mean shift in RTNDT plus the two standard deviation value (2 ) specified in Regulatory Guide 1.99, Revision 2. If the measured value exceeds the predicted value (increase RTNDT + 2 ), the licensee should provide a supplement to the PTLR to demonstrate how the results affect the approved methodology.
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| 5.6.5 Post Accident Monitoring Report 1
| |
| E or I When a report is required by Condition B or F of LCO 3.3.[3], "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the 2 following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.
| |
| [ 5.6.6 Tendon Surveillance Report Any abnormal degradation of the containment structure detected during the tests 1
| |
| required by the Pre-stressed Concrete Containment Tendon Surveillance Program shall be reported to the NRC within 30 days. The report shall include a description of the tendon condition, the condition of the concrete (especially at tendon anchorages), the inspection procedures, the tolerances on cracking, and the corrective action taken. ]
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| 6 2
| |
| 6.9.1.8 5.6.7 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the 6
| |
| Specification 5.5.9, "Steam Generator (SG) Program." The report shall include:
| |
| 6.9.1.8.a 6.9.1.8.a The scope of inspections performed on each SG, 6.9.1.8.b The nondestructive examination techniques utilized for tubes with increased DOC M01 degradation susceptibility; 6.9.1.8.c For each degradation mechanism found:
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| The nondestructive examination techniques utilized; Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 5.6-4 Rev. 5.0 2
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| | |
| Reporting Requirements CTS 5.6 5.6 Reporting Requirements 6
| |
| 5.6.7 Steam Generator Tube Inspection Report (continued)
| |
| : 2. The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;
| |
| : 3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and
| |
| : 4. The number of tubes plugged [or repaired] during the inspection 1 outage.; and 2
| |
| [5. The repair methods utilized and the number of tubes repaired by each 1 repair method.]
| |
| 6.9.1.8.d d. An analysis summary of the tube integrity conditions predicted to exist at the DOC M01 next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results; The number and percentage of tubes plugged [or repaired] to date, and the 1 6.9.1.8.e effective plugging percentage in each SG, 6.9.1.8.f The results of any SG secondary side inspections; and DOC M01 6.9.1.8.g [g. Insert any plant-specific reporting requirements, if applicable.] 1 The primary to secondary leakage rate observed in each SG (if it is not practical to assign the leakage to an individual SG, the entire primary to secondary leakage should be conservatively assumed to be from one SG) during the cycle preceding the inspection which is the subject of the report, The calculated accident induced leakage rate from the portion of the tubes below 18.11 inches from the top of the tubesheet for the most limiting accident in the most limiting SG. In addition, if the calculated accident 4 induced leakage rate from the most limiting accident is less than 1.82 times the maximum operational primary to secondary leakage rate, the report should describe how it was determined, and The results of monitoring for tube axial displacement (slippage). If slippage is discovered, the implications of the discovery and corrective action shall be provided.
| |
| Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 5.6-5 Rev. 5.0 2
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| | |
| Licensee Response/NRC Response/NRC Question Closure Id 20 NRC Question CLA001 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time 11/30/2017 12:00 AM Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
| |
| Question Closure 3/9/2022 Date Notification Clinton Ashley Gregg Ellis Christina Long Added By Clinton Ashley Date Added 3/9/2022 8:51 AM Date Modified Modified By
| |
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| | |
| 8/12/22, 10:15 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 12 NRC Question CLA002 Number Select Licensee Response Application Attachment Attachment 1 - CLA002 LAR Markup.pdf (134KB) 1 Attachment 2
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| Response A new DOC A10 has been added to address the different terms discussed in the above question (attached).
| |
| Statement In addition, CTS markup Page 6-11 is attached, illustrating the change in terms and referencing new DOC A10. Please note that a new DOC A09 was added in response to RAI CLA003.
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| Attachment
| |
| : 1. CLA002 LAR Markups
| |
| | |
| ===Response===
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| 3/8/2022 12:00 AM Date/Time Closure Statement Question Closure Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 3/8/2022 8:36 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=12 1/1
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| | |
| CTS A01 ITS 5.5 ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)
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| : b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational leakage.
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| SG A01
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| : 1. Structural integrity performance criterion: All in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cooldown), all anticipated transients included in the design specification, and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.
| |
| : 2. Accident induced leakage performance criterion: The primary-to-secondary accident induced leakage rate for any design basis accident, other than SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG.
| |
| Leakage is not to exceed 0.60 gpm total through all SGs and 0.20 gpm through any one SG at room temperature conditions.
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| : 3. The operational leakage performance criterion is specified in LCO 3.4.6.2, Reactor Coolant System Operational Leakage.
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| : c. Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.
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| A10 The following alternate tube plugging criteria shall be applied as an alternative to the 40%
| |
| depth based criteria:
| |
| : 1. Tubes with service-induced flaws located greater than 18.11 inches below the top of the tubesheet do not require plugging. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 18.11 inches below the top of the tubesheet shall be plugged upon detection.
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| TURKEY POINT - UNITS 3 & 4 6-11 AMENDMENT NOS. 260 AND 255 Page 11 of 19
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| | |
| DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS CTS Specification 4.0.2 allows extension of an SR Frequency under certain conditions.
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| ITS SR 3.0.3 provides guidance with respect to missed SRs. Section 3.0 contains guidance associated with Limiting Condition for Operation (LCO) Applicability and SR Applicability. The Applicability statements in Section 3.0 are applicable to all LCOs and SRs unless otherwise stated within a specific LCO or SR. The Containment Leakage Rate Testing Program is required per ITS SR 3.6.1.1; therefore, all LCO and SR Applicabilities within Section 3.0 of the Technical Specifications may be applied to this Section 5.5 program. Subsequently, the removal of the CTS 6.8.4.h Specification 4.0.2 exception is appropriate and consistent with the ITS. Given that SR 3.6.1.1 requires inspections and leak testing in accordance with the Containment Leakage Rate Testing Program and Section 3.0 is applicable to this SR, it is not necessary to retain the ITS 5.5.13.e SR 3.0.3 allowance. However, to maintain consistency with the ITS, the SR 3.0.3 allowance is being retained. Since this change is a clarification intended to maintain provisions that would be allowed in the LCO sections of the Technical Specifications, it is considered administrative in nature. This change is designated as administrative because it does not result in a technical change to the CTS.
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| MORE RESTRICTIVE CHANGES M01 The CTS does not include a requirement for the Battery Monitoring and Maintenance Program. The ITS includes a requirement for this program. This changes the CTS by adding the ITS 5.5.14, "Battery Monitoring and Maintenance Program."
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| The Battery Monitoring and Maintenance Program is included to provide for battery restoration and maintenance. The specific wording associated with this program may be found in ITS 5.5.14. The Notice of Availability for TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360," (76FR54510) references the model application and safety evaluation (SE) for plant-specific adoption of TSTF500, Revision 2 (NRC ADAMS Accession No. ML111751792). PTN has verified the applicable information specified in Section 2.2 of the TSTF-500 model application, including applicable Updated Final Safety Analysis Report (UFSAR) information. PTN will update the UFSAR, as necessary, to include any UFSAR information listed in Section 2.2 of the TSTF-500 model application that is not currently reflected in the PTN Unit 3 and Unit 4 UFSAR.
| |
| This change is acceptable because it supports implementation of the requirements of the ITS. This change is designated as more restrictive because it imposes additional programmatic requirements in the Technical Specifications.
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| M02 The CTS does not include a requirement for the Pre-Stressed Concrete Containment Tendon Surveillance Program. The ITS includes a requirement for this program. This changes the CTS by adding the ITS 5.5.4, "Pre-Stressed Concrete Containment Tendon Surveillance Program."
| |
| The Pre-Stressed Concrete Containment Tendon Surveillance Program is included to provide controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity. The specific wording associated with this program may be found in ITS 5.5.4. This change is acceptable because it supports implementation of the requirements of the ITS. This change is designated as more restrictive because it imposes additional programmatic requirements in the Technical Specifications.
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| Turkey Point Unit 3 and Unit 4 Page 3 of 8
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| | |
| A10 CTS 6.8.4.j.c provides an exception to the 40% tube plugging criteria of the Steam Generator (SG) Program. The exception states, in part, the certain criteria "shall" be applied. ISTS 5.5.8.c contains this same exception, but uses the term "may" in lieu of "shall". This changes the CTS by replacing "shall" with the ISTS term "may" in ITS 5.5.6.c.
| |
| The ISTS use of the term "may" is appropriate because the ISTS does not require alternate criteria to be applied when the ISTS requirement to plug all tubes with flaws with a depth of 40% of the nominal tube wall thickness is met. Use of the term "may" does not affect the application of the specification in that the licensee must apply either the aforementioned 40% flaw criterion or meet all of the requirements associated with the alternative plugging criteria. Therefore, this change is designated as administrative because it does not result in a technical change to the CTS.
| |
| | |
| 3/9/22, 10:02 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 24 NRC Question CLA002 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time 11/30/2017 12:00 AM Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 3/9/2022 Date Notification Clinton Ashley Gregg Ellis Christina Long Added By Clinton Ashley Date Added 3/9/2022 9:00 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=24 1/1
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| 8/12/22, 10:18 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 16 NRC Question CLA003 Number Select Licensee Response Application Attachment Attachment 1 - CLA003 LAR Markup.pdf (177KB) 1 Attachment 2
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| Response ITS 5.5.13.f is reinstated. This results in modification of the affected CTS and ITS markup page (attached).
| |
| Statement In addition, DOC A08 is modified (also attached) to only address the adoption of ITS 5.5.13.e (SR 3.0.3 statement). The reinstatement of ITS 5.5.13.f permits the deletion of the CTS statement that Specification 4.0.2 is not applicable to the Containment Leakage Rate Testing Program. DOC A09 has been added to justify the addition of ITS 5.5.13.f in lieu of the statement regarding CTS 4.0.2.
| |
| Attachment
| |
| : 1. CLA003 LAR Markups
| |
| | |
| ===Response===
| |
| 3/8/2022 12:00 AM Date/Time Closure Statement Question Closure Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 3/8/2022 8:42 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=16 1/1
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| | |
| CTS A01 ITS 5.5 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 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.
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| : 3) Overall air lock leakage acceptance criteria is 0.05 La, when pressurized to Pa.
| |
| A09 The provisions of Specification 4.0.2 do not apply to the test frequencies contained within the Containment Leakage Rate Testing Program. A08 Add ITS 5.5.13.e 5.5.11 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).
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| 5.5.6 j. Steam Generator (SG) Program An SG A01 A Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the Steam Generator Program shall include the following:
| |
| SG
| |
| : a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the as found condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The as found condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged to confirm that the performance criteria are being met.
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| TURKEY POINT - UNITS 3 & 4 6-10 AMENDMENT NOS. 260 AND 255 Page 10 of 19
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| | |
| DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS Both footnotes that modify the Frequency of the Unit 3 4th inspection period and the Unit 3 SG inspections are one-time extension that expire after the fall 2021 outage.
| |
| Because the approval of this license amendment request will be after the one-time extensions have expired, the extensions are no longer in effect. This change is designated as administrative because it does not result in technical changes to the CTS.
| |
| A05 CTS 6.8.4.k.d requires, in part, that the Control Room Envelope Habitability Program include measurement, at designated locations, of the Control Room Envelope (CRE) pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation of the CREVS, operating at the flow rate required by SR 4.7.5.d. ITS 5.5.15.d requires, in part, that the Control Room Envelope Habitability Program include measurement, at designated locations, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation of the CREVS, operating at the flow rate required by the Ventilation Filter Test Program (VFTP). The CTS 4.7.5.d flow rate of 1000 +/- 10 cfm is being placed in the new VFTP; therefore, the flow rate value is not changed. This change is designated as administrative because it does not result in technical changes to the CTS.
| |
| A06 CTS 6.8.4.q, Safety Function Determination Program (SFDP) states that this program ensures loss of safety function is detected and appropriate actions taken, and other appropriate actions may be taken as a result of the support system inoperability.
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| ITS 5.5.12 states that other appropriate limitations and remedial or compensatory actions may be taken as a result of the support system inoperability. The changes the CTS by adding additional clarification on what other appropriate action may be taken, limitation, remedial, or compensatory.
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| The addition of the description of the type of action that may be taken is acceptable because it is describing the intent of the CTS SFDP purpose. This change is designated as administrative because it does not result in technical changes to the CTS.
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| A07 The CTS format is to label remedial actions with their associated prescribed period for completion as "ACTION" and "allowed outage time." ITS format is to label these same remedial action and prescribed completion periods as "Condition and Required Action" and "Completion Time." This changes the CTS by providing a new label for the remedial actions and associated period for completion.
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| The change in the labeling of these remedial action requirements is acceptable because it continues to portray the intent of the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.
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| A08 CTS 6.8.4.h specifies the requirements for the Containment Leakage Rate Testing Program. CTS 6.8.4.h states, in part, that Specification 4.0.2 is not applicable to this program. ITS 5.5.13, "Containment Leakage Rate Testing Program," does not contain this statement. Furthermore, ITS 5.5.13.e states, "The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate," which is not stated in CTS 6.8.4.h. This changes the CTS by removing the CTS statement regarding Specification 4.0.2 and adding the allowances of ITS SR 3.0.3 to the Technical Specification Containment Leakage Rate Testing Program.
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| Turkey Point Unit 3 and Unit 4 Page 2 of 8
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| | |
| DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS CTS Specification 4.0.2 allows extension of an SR Frequency under certain conditions.
| |
| ITS SR 3.0.3 provides guidance with respect to missed SRs. Section 3.0 contains guidance associated with Limiting Condition for Operation (LCO) Applicability and SR Applicability. The Applicability statements in Section 3.0 are applicable to all LCOs and SRs unless otherwise stated within a specific LCO or SR. The Containment Leakage Rate Testing Program is required per ITS SR 3.6.1.1; therefore, all LCO and SR Applicabilities within Section 3.0 of the Technical Specifications may be applied to this Section 5.5 program. Subsequently, the removal of the CTS 6.8.4.h Specification 4.0.2 exception is appropriate and consistent with the ITS. Given that SR 3.6.1.1 requires inspections and leak testing in accordance with the Containment Leakage Rate Testing Program and Section 3.0 is applicable to this SR, it is not necessary to retain the ITS 5.5.13.e SR 3.0.3 allowance. However, to maintain consistency with the ITS, the SR 3.0.3 allowance is being retained. Since this change is a clarification intended to maintain provisions that would be allowed in the LCO sections of the Technical Specifications, it is considered administrative in nature. This change is designated as administrative because it does not result in a technical change to the CTS.
| |
| MORE RESTRICTIVE CHANGES M01 The CTS does not include a requirement for the Battery Monitoring and Maintenance Program. The ITS includes a requirement for this program. This changes the CTS by adding the ITS 5.5.14, "Battery Monitoring and Maintenance Program."
| |
| The Battery Monitoring and Maintenance Program is included to provide for battery restoration and maintenance. The specific wording associated with this program may be found in ITS 5.5.14. The Notice of Availability for TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360," (76FR54510) references the model application and safety evaluation (SE) for plant-specific adoption of TSTF500, Revision 2 (NRC ADAMS Accession No. ML111751792). PTN has verified the applicable information specified in Section 2.2 of the TSTF-500 model application, including applicable Updated Final Safety Analysis Report (UFSAR) information. PTN will update the UFSAR, as necessary, to include any UFSAR information listed in Section 2.2 of the TSTF-500 model application that is not currently reflected in the PTN Unit 3 and Unit 4 UFSAR.
| |
| This change is acceptable because it supports implementation of the requirements of the ITS. This change is designated as more restrictive because it imposes additional programmatic requirements in the Technical Specifications.
| |
| M02 The CTS does not include a requirement for the Pre-Stressed Concrete Containment Tendon Surveillance Program. The ITS includes a requirement for this program. This changes the CTS by adding the ITS 5.5.4, "Pre-Stressed Concrete Containment Tendon Surveillance Program."
| |
| The Pre-Stressed Concrete Containment Tendon Surveillance Program is included to provide controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity. The specific wording associated with this program may be found in ITS 5.5.4. This change is acceptable because it supports implementation of the requirements of the ITS. This change is designated as more restrictive because it imposes additional programmatic requirements in the Technical Specifications.
| |
| Turkey Point Unit 3 and Unit 4 Page 3 of 8
| |
| | |
| CTS 6.8.4.h requires the performance of containment leakage rate testing in accordance with 10 CFR 50, Appendix J, Option B, except as modified by NRC approved exemptions.
| |
| CTS 4.0.3 provides time to perform a missed Surveillance when it is discovered that a Surveillance was not performed within its specified frequency. ITS 5.5.13 also requires the performance of containment leakage rate testing in accordance with 10 CFR 50, Appendix J, Option B, except as modified by NRC approved exemptions. ITS 5.5.13.e states that the provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program. This changes the CTS by explicitly adding the statement that the provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.
| |
| This change is acceptable because no changes have been made to the existing requirements.
| |
| The CTS and proposed ITS 5.5.13 continue to require the same testing to be performed. The statement associated with ITS SR 3.0.3 is added consistent with the ISTS presentation to explicitly state that the allowance for a missed Surveillance applies to Frequencies specified in the Containment Leakage Rate Testing Program. Since the change is a clarification to maintain CTS 4.0.3 provisions that are currently applied to the Containment Leakage Rate Testing Program, it is considered administrative in nature. This change is designated as administrative because it does not result in technical changes to the CTS.
| |
| A09 CTS 6.8.4.h states that the provisions of CTS 4.0.2 are not applicable to the Containment Leakage Rate Testing Program. ITS 5.5.13 does not contain a similar statement but instead contains the following:
| |
| Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J.
| |
| The ITS statement is equivalent to the CTS statement that CTS 4.0.2 is not applicable.
| |
| This changes the CTS by adopting the ISTS 5.5.15.f statement in lieu of the CTS 4.0.2 statement.
| |
| CTS 4.0.2 permits a 25% extension of SR Frequencies under certain circumstances.
| |
| CTS 6.8.4.h does not allow this 25% extension to be applied to the test Frequencies associated with the Containment Leakage Rate Testing Program. The aforementioned ISTS statement is equivalent to the CTS restriction in that the Frequencies required by 10 CFR 50, Appendix J, cannot be modified by the Technical Specifications. Therefore, the adoption of ITS 5.5.13.f and omission of the CTS statement associated with the application of CTS 4.0.2 does not result in a technical change to the Technical Specifications. Subsequently, this change is designated as administrative.
| |
| | |
| Programs and Manuals 5.5 5.5 Programs and Manuals 13 5.5.15 Containment Leakage Rate Testing Program (continued) 4
| |
| : e. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.
| |
| : f. Nothing in these Technical Specifications shall be construed to modify the 2
| |
| testing Frequencies required by 10 CFR 50, Appendix J.
| |
| [OPTION A/B Combined]
| |
| : a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J. [Type A][Type B and C] test requirements are in accordance with 10 CFR 50, Appendix J, Option A, as modified by approved exemptions. [Type B and C][Type A] test requirements are in accordance with 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. The 10 CFR 50, Appendix J, Option B test requirements shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September, 1995, as modified by the following exceptions:
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| : 1. The visual examination of containment concrete surfaces intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B testing, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWL, except where relief has been authorized by the NRC.
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| 6
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| : 2. The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR50, Appendix J, Option B, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRC.
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| [ 3. ...]
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| : b. The calculated peak containment internal pressure for the design basis loss of coolant accident, Pa, [45 psig]. The containment design pressure is
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| [50 psig].
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| : c. The maximum allowable containment leakage rate, La, at Pa, shall be [ ]%
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| of containment air weight per day.
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| : d. Leakage rate acceptance criteria are:
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| Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 5.5-17 Rev. 5.0 2
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| | |
| 3/10/22, 1:12 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 28 NRC Question CLA003 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 3/10/2022 Date Notification Clinton Ashley Gregg Ellis Christina Long Added By Clinton Ashley Date Added 3/10/2022 12:11 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=28 1/1
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| 4/26/22, 10:35 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 303 NRC Question CLA004 Number Category Editorial ITS 3.6 Section ITS 3.6.3 Number DOC A07 Number JFD Number JFD Bases Number Page 68 of 382 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch n/a POC Conf Call N
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| Requested NRC ITS 3.6.3 - page 68 of 382 - ITS 3.6.3 DOC A07 states in part, CTS 4.6.1.7.2 requires the Question containment purge and exhaust valve leakage rate to be less than or equal to 0.05 La when pressurized to Pa. It appears that CTS 4.6.1.7.2 does not contain the 0.05 La limit for containment purge and exhaust. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 4/26/2022 Added By Clinton Ashley Date Modified Modified By Date 4/26/2022 9:34 AM Added Notification Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=303 1/1
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| 8/12/22, 10:53 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 351 NRC Question CLA004 Number Select Licensee Response Application Attachment 1 Attachment 1 - CLA004 LAR Markup R1.pdf (663KB)
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| Attachment 2 Response FPL evaluated ITS 3.6.3 DOC A07 and CTS 4.6.1.7.2 and has revised the DOC, as necessary. See revised Statement ITS 3.6.3 DOC A07 in attached CLA004 LAR Markup.
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| | |
| ===Response===
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| 5/3/2022 3:25 PM Date/Time Closure Statement Question Closure Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 5/3/2022 2:26 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=351 1/1
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| | |
| DISCUSSION OF CHANGES ITS 3.6.3, CONTAINMENT ISOLATION VALVES A06 CTS 4.6.1.7.2 requires performance of a leakage rate test for each containment purge supply and exhaust isolation valve in accordance with the Surveillance Frequency Control Program (SFCP). ITS SR 3.6.3.5 requires performance of a leakage rate test for containment purge valves with resilient seals at a Frequency of "In accordance with the Surveillance Frequency Control Program." This changes the CTS by specifying that the leakage rate test is only required to be performed on containment purge valves with resilient seals.
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| The purpose of CTS 4.6.1.7.2 is to verify the leakage rate of each containment purge supply and exhaust isolation valve is within limits. CTS 4.6.1.7.2 does not specify that the SR only applies to containment purge supply and exhaust isolation valves with resilient seals, because each of the purge supply and exhaust isolation valves at PTN has a resilient seal. Specifying within ITS SR 3.6.3.5 that the SR only applies to containment purge valves with resilient seals, aligns the text with the ISTS, and is consistent with the Bases justifying the increased leakage test Frequency for purge valves with resilient seals. This change is designated as administrative, because it does not result in a technical within limit change to the CTS.
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| measured A07 CTS 4.6.1.7.2 requires the containment purge and exhaust valve leakage rate to be less than or equal to 0.05 La when pressurized to Pa. CTS 6.8.4.h provides the requirements for the Containment Leakage Rate Testing Program, and states that the peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is defined here as the containment design pressure of 55 psig. ITS SR 3.6.3.5 requires performance of the containment purge and exhaust valve leakage test but does not include requirement for testing when pressurized to Pa. This changes the CTS by removing duplicate information associated with the containment purge and exhaust leakage rate testing.
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| The removal of these details from CTS 4.6.1.7.2 is acceptable because this information is not necessary to be included in ITS SR 3.6.3.5 to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that the containment purge and exhaust valves leakage is within the associated containment leakage rate limits. ITS SR 3.6.3.5 requires performance of the containment purge and exhaust valve leakage test.
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| ITS 5.5.13, "Containment Leakage Rate Testing Program," requires, in part, that a program establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B. 10 CFR 50, Appendix J, Option B requires that leakage rate tests be conducted under conditions representing design basis loss-of-coolant accident containment peak pressure (Pa). Thus, although not specifically stated in ITS 3.6.3.5, the requirement to perform containment leakage rate testing at Pa is retained in ITS 5.5.13. This change is designated as an administrative change because it does not result in technical changes to the CTS. SR MORE RESTRICTIVE CHANGES None Turkey Point Unit 3 and Unit 4 Page 3 of 8
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| 5/4/22, 3:01 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 371 NRC Question CLA004 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/4/2022 Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Clinton Ashley Date Added 5/4/2022 2:00 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=371 1/1
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| 4/26/22, 10:42 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 307 NRC Question CLA005 Number Category Editorial ITS 3.6 Section ITS 3.6.3 Number DOC Number JFD 1
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| Number JFD Bases Number Page 81 of 382 Number(s)
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| NRC Reviewer Select Supervisor Technical Branch n/a POC Conf Call N
| |
| Requested NRC ITS 3.6.3 - page 81 of 382 - ITS 3.6.3 Condition B, cites JFD 1 for several changes. The cited Question JFD (JFD 1, page 89 of 382) does not appear to correctly address the associated changes under ITS 3.6.3 Condition B. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 4/26/2022 Added By Clinton Ashley Date Modified Modified By Date 4/26/2022 9:39 AM Added Notification Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=307 1/1
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| 8/12/22, 10:54 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 355 NRC Question CLA005 Number Select Licensee Response Application Attachment Attachment 1 - CLA005 LAR Markup.pdf (676KB) 1 Attachment 2
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| Response The changes in ITS 3.6.3 Condition B that are cited as JFD 1 will be revised to reflect JFD 3, which Statement addresses the ISTS changes of deleting the generic bracketed information and replacing with plant specific information. The changes in ITS 3.6.3 Condition B that cite JFD 1 will be changed to reference JFD 3 as shown in the attachment.
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| Attachment
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| : 1. CLA005 LAR Markup
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| | |
| ===Response===
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| 5/3/2022 3:30 PM Date/Time Closure Statement Question Closure Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 5/3/2022 2:28 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=355 1/1
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| | |
| CTS Containment Isolation Valves (Atmospheric, Subatmospheric, Ice Condenser, and Dual) 1 3.6.3 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME B B 4 C. ------------NOTE------------ C.1 Isolate the affected 1 hour 3.6.4 Actions b Only applicable to penetration flow path by and c, 3.6.1.1 Action penetration flow paths use of at least one closed 1 3
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| with two [or more] and de-activated automatic containment isolation valve, closed manual valve, valves. or blind flange.
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| One or more penetration 1 flow paths with two [or 3 more] containment isolation valves inoperable [for reasons other than Condition[s] E 1
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| [and F)). D 3
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| INSERT 2 4
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| D. Two or more penetration D.1 Isolate all but one 4 hours flow paths with one penetration flow path by containment isolation use of at least one closed valve inoperable [for and de-activated automatic reasons other than valve, closed manual valve, Condition[s] E [and F)). or blind flange.
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| D D 3.6.1.7 Action E. [ One or more shield E.1 Restore leakage within 4 hours for shield 4 3 b
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| building bypass leakage limit. building bypass
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| [or purge valve leakage] leakage not within limit.
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| AND 72 24 hours for purge valve leakage ]
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| F. [ One or more F.1 Isolate the affected 24 hours penetration flow paths penetration flow path by with one or more use of at least one [closed 3 containment purge and de-activated automatic valves not within purge valve, closed manual valve, valve leakage limits. or blind flange].
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| AND Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.6.3-6 Rev. 5.0 2
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| | |
| 5/4/22, 3:18 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 375 NRC Question CLA005 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/4/2022 Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Clinton Ashley Date Added 5/4/2022 2:17 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=375 1/1
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| 4/26/22, 10:44 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 311 NRC Question CLA006 Number Category Technical ITS 3.6 Section ITS 3.6.3 Number DOC Number JFD 3
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| Number JFD Bases Number Page 84 of 382 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch n/a POC Conf Call N
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| Requested NRC ITS 3.6.3 - page 84 of 382 - ITS 3.6.3 deletes ISTS SR 3.6.3.2. The cited JFD (JFD 3) appears Question to be incorrect or incomplete based on the description contained in JFD 3, which states in part, that brackets are removed and the proper plant specific information/value is inserted.
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| In addition, it appears that text in the Frequency column associated with ISTS SR 3.6.3.2 should have been deleted but it was not shown as deleted. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 4/26/2022 Added By Clinton Ashley Date Modified Modified By Date 4/26/2022 9:43 AM Added Notification Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=311 1/1
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| 8/12/22, 10:54 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 359 NRC Question CLA006 Number Select Licensee Response Application Attachment Attachment 1 - CLA006 LAR Markup.pdf (700KB) 1 Attachment 2
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| Response The change to ISTS SR 3.6.3.2 that cites JFD 3 will be revised to reflect JFD 5 and the Frequency associated Statement with the Surveillance Frequency Control Program will be marked for deletion as shown in the attachment.
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| Attachment
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| : 1. CLA006 LAR Markup
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| | |
| ===Response===
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| 5/3/2022 3:30 PM Date/Time Closure Statement Question Closure Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 5/3/2022 2:30 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=359 1/1
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| CTS Containment Isolation Valves (Atmospheric, Subatmospheric, Ice Condenser, and Dual) 1 3.6.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY supply and exhaust 3.6.1.7, SR 3.6.3.1 [ Verify each [42] inch purge valve is sealed closed, [ 31 days 3 4.6.1.7.1 except for one purge valve in a penetration flow path while in Condition E of this LCO. OR and deactivated or the associated penetration(s) isolated by flange In accordance with the Surveillance Frequency Control Program ] ]
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| SR 3.6.3.2 [ Verify each [8] inch purge valve is closed, except [ 31 days 3 5
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| when the [8] inch containment purge valves are open for pressure control, ALARA or air quality OR considerations for personnel entry, or for Surveillances that require the valves to be open. In accordance with the Surveillance Frequency Control Program ] ]
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| 5 4.6.1.1.a SR 3.6.3.3 2 -------------------------------NOTE------------------------------
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| DOC L06 Valves and blind flanges in high radiation areas may be verified by use of administrative controls.
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| Verify each containment isolation manual valve and [ 31 days 3 blind flange that is located outside containment and DOC L06 not locked, sealed, or otherwise secured and OR required to be closed during accident conditions is closed, except for containment isolation valves that In accordance are open under administrative controls. with the Surveillance Frequency Control Program ]
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| Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.6.3-8 Rev. 5.0 2
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| 5/4/22, 3:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 379 NRC Question CLA006 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/4/2022 Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Clinton Ashley Date Added 5/4/2022 2:28 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=379 1/1
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| 4/26/22, 10:52 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 315 NRC Question CLA007 Number Category Editorial ITS 3.6 Section ITS 3.6.3 Number DOC Number JFD 6
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| Number JFD Bases Number Page 88 of 382 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch n/a POC Conf Call N
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| Requested NRC ITS 3.6.3 - page 88 of 382 - ITS 3.6.3 deletes ISTS SR 3.6.3.10 and SR 3.6.3.11. The cited Question JFDs (JFD 3, 5, and 6) appear to be incorrect or incomplete based on the descriptions contained in the JFDs (there is no explicit mention of ISTS SR 3.6.3.10 or SR 3.6.3.11 deletion). Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 4/26/2022 Added By Clinton Ashley Date Modified Modified By Date 4/26/2022 9:49 AM Added Notification Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=315 1/1
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| 8/12/22, 10:55 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 363 NRC Question CLA007 Number Select Licensee Response Application Attachment Attachment 1 - CLA007 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response The justification for deletion of ISTS SR 3.6.3.10 and SR 3.6.3.11 will be described in JFD 6 as shown in the Statement attachment. In addition, the cited JFD references associated with the deletion of these Surveillances will be updated to reflect JFD 6 as shown in the attachment.
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| Attachment
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| : 1. CLA007 LAR Markup
| |
| | |
| ===Response===
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| 5/3/2022 3:55 PM Date/Time Closure Statement Question Closure Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 5/3/2022 2:54 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=363 1/1
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| | |
| CTS Containment Isolation Valves (Atmospheric, Subatmospheric, Ice Condenser, and Dual) 1 3.6.3 SURVEILLANCE REQUIREMENTS (continued)
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| SURVEILLANCE FREQUENCY 5
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| SR 3.6.3.10 [ Verify each [ ] inch containment purge valve is [ [18] months 3 6
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| blocked to restrict the valve from opening > [50]%.
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| OR In accordance with the Surveillance Frequency Control Program ] ]
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| SR 3.6.3.11 [ Verify the combined leakage rate for all shield In accordance 6 3 building bypass leakage paths is [La] when with the pressurized to [psig]. Containment Leakage Rate Testing Program ]
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| Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.6.3-11 Rev. 5.0 2
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| | |
| JUSTIFICATION FOR DEVIATIONS ITS 3.6.3, CONTAINMENT ISOLATION VALVES
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| : 1. The type of Containment (Atmospheric, Subatmospheric, Ice Condenser, and Dual) is deleted because it is unnecessary. This information is provided in NUREG-1431, Improved Standard Technical Specification - Westinghouse Plants, Rev. 5.0 (ISTS), to assist in identifying the appropriate Specification to be used as a model for the plant specific Improved Technical Specifications (ITS) conversion but serves no purpose in a plant specific implementation.
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| : 2. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 3. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 4. The ISTS includes NRC approved (75 FR 39991) TSTF-446, "Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP-15791)," (ADAMS Accession No. ML080510164). Florida Power & Light Company (FPL) is not requesting approval to adopt TSTF-446 because FPL has adopted TSTF-505, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b," at Turkey Point Unit 3 and Unit 4 (PTN) (ADAMS Accession No. ML18270A429). Therefore, the ITS includes ACTIONS similar to the 3.6.3 ACTIONS in Revision 3.1 of the ISTS prior to the incorporation of TSTF-446 into the ISTS. TSTF-446's added information is removed, the deleted information is restored, and the proper plant specific information is inserted to reflect the current licensing basis. Additionally, due to the insertion of ACTION C and the deletion of ISTS 3.6.3 ACTIONS B and D (reversing changes made under TSTF-446),
| |
| subsequent ACTIONS have been renumbered.
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| : 5. ISTS Surveillance Requirement (SR) 3.6.3.2 is a bracketed SR. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. Turkey Point Units 3 and Unit 4 have 48-inch purge supply valves and 54-inch purge exhaust valves for containment purge but does not have an 8-inch purge valve. Turkey Point Units 3 and 4 do have 2-inch instrument air bleed valves used for a similar purpose. These 2-inch instrument air bleed valves are containment isolation valves and the requirements and surveillances associated with containment isolation valves apply to these valves. Because the 2-inch instrument air bleed valves requirements are covered by the CIV OPERABILITY, Conditions and Surveillance Requirements this SR is not necessary. Additionally, subsequent Surveillances were renumbered because of the deletion of ISTS SR 3.6.3.2 and other surveillances that are not applicable.
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| , , 3.6.3.10, and 3.6.3.11,
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| : 6. ISTS SR 3.6.3.6 and SR 3.6.3.9 are bracketed SRs. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. the purge supply and Because PTN does not have weight or spring-loaded check valves, these exhaust valves are required to be sealed Surveillances is not required. Additionally, subsequent Surveillances were closed and deactivated renumbered because of the deletion of ISTS SR 3.6.3.6 and SR 3.6.3.9. or the associated penetration isolated by a in the PTN ITS to are ISTS SRs 3.6.3.7 and 3.6.3.8 flange, and the PTN SR 3.6.3.5 and are containment design does SR 3.6.3.6 not include a shield building, Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 5/4/22, 4:11 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 383 NRC Question CLA007 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/4/2022 Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Clinton Ashley Date Added 5/4/2022 3:10 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=383 1/1
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| 6/2/22, 3:05 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 747 NRC Question CLA008 Number Category Technical ITS 5.5 Section ITS 5.5.6 Number DOC L-1 Number JFD Number JFD Bases Number Page 78, 86, 139 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch POC Conf Call N
| |
| Requested NRC ITS 5.5.6 - page 86 of 157: ITS 5.5.6, Steam Generator (SG) Program, provides requirements for SG tube Question inspections. Discussion of Change (DOC) L01 (page 78 of 157) described the changes to the SG tube inspection requirements as consistent with TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections. TSTF-577, Revision 1, Section 3.1.3, Technical Evaluation of Alloy 600TT Tubing Material Inspection Frequency, states, The new inspection period starts [emphasis added] after a 100% inspection of all SG tubes performed in a single outage (past or future). TSTF577, Revision 1, model application Section 2.1, includes a preparers note to provide date [emphasis added] of a 100% SG tube inspection performed during a single refueling outage prior to approval of the amendment. The preparers note in Section 2.1 of the model application also states for plants crediting a past 100%
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| inspection of SG tubes in a single outage to submit a SG Tube Inspection Report meeting the revised TS 5.6.[7] requirements within 30 days after implementation of the license amendment.
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| It appears that DOC L01 did not provide information that would address the preparers note described above. Therefore, the NRC staff requests information regarding whether or not the licensee for Turkey Point (Units 3 & 4 ITS 5.5.6.d.2) is crediting a 100 percent inspection of all SG tubes performed in a single outage before approval of the ITS amendment (e.g., a past inspection) as the initial inspection in the first inspection period. If crediting a past inspection, then please provide the Turkey Point Unit 3 date and Unit 4 date for the past 100 percent inspection of all SGs tubes performed in a single outage, consistent with the preparer's note. In addition, include a discussion about providing a report to meet the revised ITS 5.6.5, Steam Generator Tube Inspection Report requirements (page 139 of 157), consistent with the preparer's note.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/2/2022 Added By Clinton Ashley Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=747 1/2
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| 6/2/22, 3:05 PM Turkey Point ITS Conversion Database Date 6/2/2022 1:53 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=747 2/2
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| 8/12/22, 11:09 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1315 NRC Question CLA008 Number Select Licensee Response Application Attachment Attachment 1 - CLA008 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response The inspection period described in the SG Program, ITS 5.5.6 paragraph d.2, will begin from past SG Statement inspections performed in October 2021 and March 2022 on Turkey Point Unit 3 and Unit 4, respectively.
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| These inspections each consisted of 100 percent inspection of all SG tubes performed in a single outage.
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| Florida Power & Light (FPL) will submit SG Tube Inspection Reports for Turkey Point Unit 3 and Unit 4 that meets the revised ITS 5.6.5 requirements within 30 days after implementation of the ITS license amendment.
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| DOC L01 is revised to include this information. See Attachment 1.
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| Attachment
| |
| : 1. CLA008 LAR Markup
| |
| | |
| ===Response===
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| 6/28/2022 3:55 PM Date/Time Closure Statement Question Closure Date Notification Clinton Ashley Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 6/28/2022 2:54 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1315 1/1
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| | |
| DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS LA04 (Type 3 - Removing Procedural Details for meeting TS Requirements or Reporting Requirements) CTS 4.7.5.c.2 requires that, within 31 days after removal of a carbon sample, the laboratory analysis results are shown to be within limit. ITS 5.5.8.c requires the same analysis to be performed; however, the detail of "within 31 days" after removal of a carbon sample is not included. This changes the CTS by moving these procedural details from the Technical Specifications to the Technical Requirements Manual (TRM).
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| The removal of these details for performing testing activities from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform the testing at the appropriate Frequencies. Also, this change is acceptable because these types of procedural details will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 7 - Relaxation of Surveillance Frequency) CTS 6.8.4.j.d. provides the provisions for SG tube inspections. CTS 6.8.4.j.d.2 requires, in part, each SG at least every 48 effective full power months or at least every other refueling outage (whichever results in more frequent inspections). In addition, the minimum number of tubes inspected at each scheduled inspection shall be the number of tubes in all SGs divided by the number of SG inspection outages scheduled in each inspection period as defined in CTS 6.8.4.j.d.2 parts a, b, and c. ITS 5.5.6.d.2 requires inspection of 100% of the tubes in each SG at least every 54 effective full power months (EFPMs) which defines the inspection period. ITS 5.5.6.d.2 also allows an exemption that if none of the SG tubes have ever experienced cracking other than in regions that are exempt from inspection by alternate repair criteria and the SG inspection was performed with enhanced probes, the inspection period mat be extended to 72 EFPMs and provides requirements for the use of enhanced probes. CTS 6.8.4.j.d.3 requires, in part, that if cracks are found the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indication shall not exceed 24 EFPMs or one refueling outage (whichever results in more frequent inspections). ITS 5.5.6.d.3 requires the additional inspection on each affected and potentially affected SG at the next refueling outage, but may be deferred to the following refueling outage if the 100%
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| inspection of all SGs was performed with enhanced probes as described in paragraph d.2. This changes the CTS by modifying the inspection frequency to a single requirement to inspect 100% of the SG tubes at a maximum frequency of 54 EFPMs and modifying the inspection frequency when crack indications are discovered to the next refueling outage or the following.
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| outage (unless permitted by other requirements of ITS 5.5.6.d.2),
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| Turkey Point Unit 3 and Unit 4 Page 7 of 9
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| DISCUSSION OF CHANGES ITS 5.5, PROGRAMS AND MANUALS The purpose of the inspection frequencies associated with the SG tubes is to ensure appropriate inspections are performed consistent with accepted NRC and industry practice as identified in Nuclear Energy Institute (NEI) 97-06, "Steam Generator Program Guidelines," and its referenced Electric Power Research Institute SG examination guidelines, which establish the content of the SG Program. These guidelines minimize the potential of SG tube failures to support maintaining SG and reactor coolant pressure boundary structural integrity.
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| The proposed changes are consistent with the ISTS and Technical Specification Task Force (TSTF) traveler TSTF-577-A, Revision 1, "Revised Frequencies for Steam The inspection Generator Tube Inspections." PTN Units 3 and 4 SGs contain Alloy 600 thermal treated period described in (TT) tubes. For Alloy 600TT tubing, TSTF-577, which is incorporated in Revision 5 of the SG Program, the ISTS, revised the frequencies related to inspection of the tubes such that both the ITS 5.5.6 paragraph maximum time between inspections and the time to inspect 100 percent of the tubes be d.2, will begin from 54 EFPMs. TSTF-577 also revised the Frequency when crack indications are found in the previous SG inspections any tube to eliminate 24 EFPMs and require the inspection at the next refueling outage performed in or the following. The nuclear industrys Steam Generator Task Force presented a October 2021 and technical basis supporting the 54 EFPM Alloy 600TT inspection interval during the March 2022 on February 13, 2019 (ADAMS Package Accession No. ML19044A416), and February 24, Turkey Point Unit 3 2020 (ADAMS Package Accession No. ML20066E421), public meetings with the NRC and Unit 4, staff.
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| respectively. These outage inspections consisted of 100 As stated in the NRC Safety Evaluation (SE) accompanying TSTF-577-A, proposed percent inspection changes in TSTF-577 are acceptable because they continue to ensure SG tube integrity of all SG tubes and, therefore, protect the public health and safety. In particular, the structural integrity performed in a performance criterion and accident-induced leakage performance criterion will continue single outage. to be met with the proposed revised SG inspection intervals (maximum allowable time Florida Power &
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| Light (FPL) will between SG inspections) and inspection periods (maximum allowable time between submit a SG Tube 100 percent of SG tubes inspections). That considered, the changes to the SG tube Inspection Report inspection frequencies are acceptable.
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| for Turkey Point Unit 3 and Unit 4 that TSTF traveler TSTF-577-A incorporated changes to the Standard Technical meets the revised Specifications (STSs) under the consolidated line item improvement process (CLIIP).
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| ITS 5.6.5 requirements within TSTF-577-A was approved for use by the NRC as documented in the accompanying SE 30 days after dated April 14, 2021 (ADAMS Accession No. ML21098A188, ML21096A274). PTN has implementation of reviewed the NRC SE and concluded that the justification presented in TSTF-577-A and the ITS license the SE prepared by the NRC staff are applicable to PTN and justify this change.
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| amendment. An action request has This change is designated as less restrictive because the maximum inspection been initiated by FPL to track the SG frequencies for the tube inspections was extended beyond the current inspection Tube Inspection periods.
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| Report submittals.
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| L02 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS 6.8.4.e requires performance of the "clear and bright" test, used to establish the acceptability of new fuel oil for use prior to addition to storage tanks. ITS 5.5.10.a.3 requires a determination that the fuel oil has a clear and bright appearance with proper color or that water and sediment content is within limits. This changes the CTS by allowing a "water and sediment content" test to be performed to establish the acceptability of new fuel oil instead of only allowing a "clear and bright" test.
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| Turkey Point Unit 3 and Unit 4 Page 8 of 9
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| 6/29/22, 9:25 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1319 NRC Question CLA008 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/29/2022 Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Clinton Ashley Date Added 6/29/2022 5:28 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1319 1/1
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| 5/19/22, 3:06 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 407 NRC Question JMW001 Number Category Editorial ITS 3.7 Section ITS n/a Number DOC Number JFD Number JFD Bases Number Page 32, 33 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC The title pages for Attachments 15 and 16 appear after ITS 3.7.1 with no information following. These Question attachments are presented later in the document in the appropriate location. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:19 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=407 1/1
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| 8/14/22, 9:13 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 499 NRC Question JMW001 Number Select Licensee Response Application Attachment 1 Attachment 1 - JMW001 LAR Markups.pdf (89KB)
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| Attachment 2 Response FPL will remove the duplicated Attachments 15 and 16 title pages. See attached JMW001 license Statement amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW001 LAR Markups
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| ===Response===
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| 5/30/2022 2:00 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 5/30/2022 1:00 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=499 1/1
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| (from Enclosure 2, Volume 12, ITS Section 3.7, "PLANT SYSTEMS," Page 32 of 456, Revision 1, of the ITS Conversion LAR)
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| ATTACHMENT 15 Relocated/Deleted Current Technical Specifications (CTS) in the Turkey Point Unit 3 and Unit 4 ITS Conversion
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| * CTS 3.7.6 - Snubbers
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| * CTS 3.7.7 - Sealed Source Contamination
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| (from Enclosure 2, Volume 12, ITS Section 3.7, "PLANT SYSTEMS," Page 33 of 456, Revision 1, of the ITS Conversion LAR)
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| ATTACHMENT 16 Improved Standard Technical Specifications (ISTS)
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| Not Adopted in the Turkey Point Unit 3 and Unit 4 ITS Conversion
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| * ISTS 3.7.4 - Atmospheric Dump Valves
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| * ISTS 3.7.12 - Emergency Core Cooling System (ECCS)
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| Pump Room Exhaust Air Cleanup System (PREACS)
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| * ISTS 3.7.13 - Fuel Building Air Cleanup System (FBACS)
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| * ISTS 3.7.14 - Penetration Room Exhaust Air Cleanup System (PREACS)
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| 6/9/22, 12:24 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 943 NRC Question JMW001 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:24 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=943 1/1
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| 5/19/22, 3:09 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 411 NRC Question JMW002 Number Category Editorial ITS Section 3.7 ITS Number 3.7.1 DOC Number A-5 JFD Number JFD Bases Number Page Number(s) 8 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Question ITS 3.7.1 DOC A05 - ACTIONs should have a capital S to make it ACTIONS. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:21 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=411 1/1
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| 8/14/22, 9:14 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 479 NRC Question JMW002 Number Select Licensee Response Application Attachment 1 Attachment 1 - JMW002 LAR Markups.pdf (1MB)
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| Attachment 2 Response FPL will revise ITS 3.7.1, DOC A05, to state "ACTIONS" in lieu of "ACTIONs". See attached JMW002 Statement license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW002 LAR Markups
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| ===Response===
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| 5/26/2022 2:15 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 5/26/2022 1:15 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=479 1/1
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| DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs) number of inoperable MSSVs on any operating SG. ITS 3.7.1, ACTION B, requires a reduction in THERMAL POWER and a reduction in the Power Range Neutron Flux - High reactor trip setpoint consistent with the requirements of ITS Table 3.7.1-1. The Table has been revised slightly to provide the associated maximum allowable power for the number of OPERABLE MSSVs. This changes the CTS by adding an additional explicit statement to reduce THERMAL POWER consistent with ITS Table 3.7.1-1 and by stating the maximum allowable power as a function of OPERABLE, instead of inoperable, MSSVs.
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| The purpose of CTS 3.7.1.1, ACTION a, is to reduce the Power Range Neutron Flux - High Setpoint to within the limits of the safety analyses. Current plant operation dictates that THERMAL POWER is reduced before reducing the setpoints to prevent a reactor trip. Explicitly stating this practice in ITS and stating the maximum power level in terms of OPERABLE instead of inoperable MSSVs does not change how the plant is operated. This change is considered administrative because it does not result in technical changes to the CTS.
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| S A05 CTS 3.7.1.1, ACTIONs a and b, state that with one or more MSSVs inoperable, either restore the inoperable valves to OPERABLE status or reduce the Power Range Neutron Flux - High Setpoints. ITS 3.7.1, ACTION A, does not include the restoration requirement, only the alternate compensatory measure. This changes the CTS by eliminating the explicit statement to restore the MSSV(s) to OPERABLE status.
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| This change is acceptable, because it does not result in a technical change to the Technical Specifications. Restoration of compliance with the LCO is always an option in an ACTION, so eliminating the restoration ACTION from the CTS has no effect. In both the CTS and the ITS, if the inoperable MSSV(s) are not restored, actions are taken that result in reducing reactor power to within the relief capability of the OPERABLE MSSVs within 4 hours. This change is designated as administrative, because it does not result in a technical change to the CTS.
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| A06 CTS 4.7.1.1 requires verification of each required MSSV lift setpoint, and states "The provisions of Specification 4.0.4 are not applicable for entry into MODE 3."
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| ITS Surveillance Requirement (SR) 3.7.1.1 does not contain this statement.
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| However, ITS SR 3.7.1.1 does contain a Note that states, "Only required to be performed in MODES 1 and 2." This changes the CTS by revising presentation of the CTS 4.0.4 exception.
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| The CTS 4.0.4 exception allows entry into MODE 3 to perform CTS Surveillance 4.7.1.1. This exception is not required in ITS SR 3.7.1.1 because the SR Note in the ITS only requires the SR to be performed in MODES 1 and 2; i.e., allows entry into an operation in MODE 3 to perform the SR as explained in ITS Section 1.4, Example 1.4-5. This change is designated as administrative as it results in no technical change to the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 2 of 6
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| 6/9/22, 12:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 947 NRC Question JMW002 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:25 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=947 1/1
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| 5/19/22, 3:23 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 415 NRC Question JMW003 Number Category Editorial ITS Section 3.7 ITS Number 3.7.1 DOC Number L-1 JFD Number JFD Bases Number Page 10 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question ITS 3.7.1 DOC L01 - The second paragraph second sentence refers to Required Action C.2. It appears that it should be referring to B.2. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:24 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=415 1/1
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| 8/14/22, 9:35 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 503 NRC Question JMW003 Number Select Licensee Response Application Attachment Attachment 1 - JMW003 LAR Markups.pdf (691KB) 1 Attachment 2
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| Response FPL will revise the reference to Required Action C.2 in the second paragraph second sentence of ITS 3.7.1, Statement Discussion of Change (DOC) L01, to reference Required Action B.2. ITS Required Action B.2 is associated with reducing the Power Range Neutron Flux - High Setpoint, which, in part, is the subject of DOC L01. See attached JMW003 license amendment request (LAR), Revision 1, markup.
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| Attachment
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| : 1. JMW003 LAR Markups
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| ===Response===
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| 5/30/2022 2:05 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:03 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=503 1/1
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| DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES (MSSVs) ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.7.1.1, ACTION a, states, in part, that with one or more MSSVs inoperable in MODE 1 or 2 with a positive moderator temperature coefficient (MTC), reduce the Power Range Neutron Flux - High Setpoint trip within 4 hours. ITS 3.7.1, ACTION A, requires only a reduction in THERMAL POWER to less than or equal to the Maximum Allowable
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| % RTP specified in Table 3.7.1-1 for the number of OPERABLE MSSVs when one or more MSSVs are inoperable in MODE 2, irrespective of MTC condition. This changes the CTS by only requiring the Power Range Neutron Flux - High Setpoint trip be reduced when in MODE 1 and requiring only a power reduction when one or more MSSVs are inoperable in MODE 2.
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| B.2 The purpose of CTS 3.7.1.1 is to ensure that the MSSVs are capable of relieving Main Steam System pressure. ISTS 3.7.1, Required Action C.2, requires the Power Range Neutron Flux - High trip setpoint to be reduced but is modified by a Note stating that this action is only required in MODE 1. Since this Action is relevant only during MODE 1 operation at PTN, the MTC condition is irrelevant with respect to operation in MODE 2. In MODES 2 and 3, THERMAL POWER is at or below 5% RTP and Reactor Trip System neutron flux trips specified in LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation," other than the Power Range Neutron Flux - High trip, provide the necessary protection, regardless of the MTC condition. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the low probability of a Design Basis Accident (DBA) occurring during the repair period and RTS neutron flux trips other than the power range neutron flux trip continue to provide reactor protection. Additionally, a reactor power reduction is sufficient to limit primary side heat generation such that overpressurization of the secondary side is precluded for any Reactor Coolant System (RCS) heatup event. Furthermore, for this case there is sufficient total steam flow capacity provided by the turbine and remaining OPERABLE MSSVs to preclude overpressurization in the event of an increased reactor power due to reactivity insertion, such as in the event of an uncontrolled rod cluster control assembly bank withdrawal at power. This change is consistent with the ISTS ACTIONS applying presentation differences to support the PTN licensing basis.
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| This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L02 (Category 3 - Relaxation of Completion Time) CTS 3.7.1.1, ACTION a, specifies the compensatory actions when one or more MSSVs are inoperable. The action allows operation to continue provided that within 4 hours, either the inoperable MSSV(s) are restored to OPERABLE status or the Power Range Neutron Turkey Point Unit 3 and Unit 4 Page 4 of 6
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| 6/9/22, 12:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 951 NRC Question JMW003 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:26 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=951 1/1
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| 5/19/22, 3:26 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 419 NRC Question JMW004 Number Category Editorial ITS 3.7 Section ITS 3.7.2 Number DOC Number JFD Number JFD Bases Number Page 49, 50 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC The Bases for 3.7.2 - Actions A.1, B.1 and C.1 reference the completion time of 8 hours as the completion Question time for action A, however in the ITS the Completion time for Action A is 24 hours. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:26 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=419 1/1
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| 8/14/22, 9:18 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 879 NRC Question JMW004 Number Select Licensee Response Application Attachment Attachment 1 - JMW004 LAR Markups.pdf (635KB) 1 Attachment 2
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| Response FPL will revise the Bases of ITS 3.7.2, Required Actions A.1 and B.1, to reference the 24-hour Completion Statement Time of Condition A. The sentence in the Required Action C.1 Bases appropriately states an 8-hour Completion Time, consistent with the ITS markup:
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| "The [8] hour Completion Time is consistent with that allowed in Condition A."
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| However, this statement is not applicable since the Completion Time of CTS 3.7.1.5, ACTION a, and ITS 3.7.2, Required Action A.1, is different (24 hours) than the Completion Time of ACTION C (8 hours).
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| Therefore, this statement is proposed for deletion. Subsequently, the ITS 3.7.2, Required Action C.1, markup reference to Justification for Deviation (JFD) 2 is changed to reference JFD 1. See attached JMW004 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW004 LAR Markups
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| ===Response===
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| 6/7/2022 12:10 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/7/2022 11:08 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=879 1/1
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| MSIVs B 3.7.2 BASES three LCO This LCO requires that [four] MSIVs in the steam lines be OPERABLE. 1 The MSIVs are considered OPERABLE when the isolation times are While the Main Steam Bypass Valves within limits, and they close on an isolation actuation signal.
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| (MSBV) and Main Steam Check Valves (MSCV) support the Main Steam This LCO provides assurance that the MSIVs will perform their design Isolation function, no Technical Specification Limiting Condition for safety function to mitigate the consequences of accidents that could result Operation or Action applies to them. in offsite exposures comparable to the 10 CFR 100 (Ref. 4) limits or the 1 NRC staff approved licensing basis. 10 CFR 50.67 APPLICABILITY The MSIVs must be OPERABLE in MODE 1, and in MODES 2 and 3 except when closed and de-activated, when there is significant mass and energy in the RCS and steam generators. When the MSIVs are closed, they are already performing the safety function.
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| In MODE 4, normally most of the MSIVs are closed, and the steam generator energy is low.
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| In MODE 5 or 6, the steam generators do not contain much energy because their temperature is below the boiling point of water; therefore, the MSIVs are not required for isolation of potential high energy secondary system pipe break s in these MODES.
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| ACTIONS A.1 24 With one MSIV inoperable in MODE 1, action must be tak en to restore OPERABLE status within [8] hours [or in accordance with the Risk Informed Completion Time Program]. Some repairs to the MSIV can be 2 made with the unit hot. The [8] hour Completion Time is reasonable, considering the low probability of an accident occurring during this time period that would require a closure of the MSIVs.
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| 24 The [8] hour Completion Time is greater than that normally allowed for 2 containment isolation valves because the MSIVs are valves that isolate a closed system penetrating containment. These valves differ from other containment isolation valves in that the closed system provides an additional means for containment isolation.
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| B.1 24 If the MSIV cannot be restored to OPERABLE status within [8] hours, the 2 unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in MODE 2 within 6 hours and Condition C would be entered. The Completion Times are reasonable, based on operating experience, to reach MODE 2 and to close the MSIVs in an orderly manner and without challenging unit systems.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.7.2-3 Rev. 5.0 1
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| MSIVs B 3.7.2 BASES ACTIONS (continued)
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| C.1 and C.2 Condition C is modified by a Note indicating that separate Condition entry is allowed for each MSIV.
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| Since the MSIVs are required to be OPERABLE in MODES 2 and 3, the inoperable MSIVs may either be restored to OPERABLE status or closed.
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| When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.
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| 1 The [8] hour Completion Time is consistent with that allowed in 2 Condition A.
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| For inoperable MSIVs that cannot be restored to OPERABLE status within the specified Completion Time, but are closed, the inoperable MSIVs must be verified on a periodic basis to be closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of MSIV status indications available in the control room, and other administrative controls, to ensure that these valves are in the closed position.
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| D.1 and D.2 If the MSIVs cannot be restored to OPERABLE status or are not closed within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed at least in MODE 3 within 6 hours, and in MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.
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| SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies that the closure time of each MSIV is within the limit given in Reference 5 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the INSERVICE TESTING PROGRAM. This SR is normally performed upon returning the unit to operation following a refueling outage. The MSIVs should not be tested at power, since even a part strok e exercise increases the risk of a valve closure when the unit is generating power. As the MSIVs are not tested at power, they are exempt from the ASME Code (Ref. 6), requirements during operation in MODE 1 or 2.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.7.2-4 Rev. 5.0 1
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| 6/22/22, 5:54 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1267 NRC Question JMW004 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/22/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/22/2022 11:33 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1267 1/1
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| 5/19/22, 3:27 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 423 NRC Question JMW005 Number Category Editorial ITS Section 3.7 ITS Number 3.7.2 DOC Number JFD Number JFD Bases Number Page 51 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC In the Bases for SR 3.7.2.2 - The statement The Surveillance Frequency is controlled by the Surveillance Question Frequency Control Program is struck out. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:27 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=423 1/1
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| | |
| 8/14/22, 9:20 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 883 NRC Question JMW005 Number Select Licensee Response Application Attachment Attachment 1 - JMW005 LAR Markups.pdf (662KB) 1 Attachment 2
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| Response FPL will revise the ITS 3.7.2, Surveillance Requirement (SR) 3.7.2.2, Bases to add the statement associated Statement with the Surveillance Frequency Control Program. See attached JMW005 license amendment request (LAR) markup.
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| Attachment
| |
| : 1. JMW005 LAR Markups
| |
| | |
| ===Response===
| |
| 6/7/2022 12:15 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/7/2022 11:12 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=883 1/1
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| | |
| MSIVs B 3.7.2 BASES SURVEILLANCE REQUIREMENTS (continued)
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| The Frequency is in accordance with the INSERVICE TESTING PROGRAM.
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| This test is conducted in MODE 3 with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows a delay of testing until MODE 3, to establish conditions consistent with those under which the acceptance criterion was generated.
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| SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage. [ The Frequency of 2 MSIV testing is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that The Surveillance Frequency these components usually pass the Surveillance when performed at the is controlled under the [18] month Frequency. Therefore, this Frequency is acceptable from a Surveillance Frequency Control Program.
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| reliability standpoint.
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| OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
| |
| | |
| ==10.2 REFERENCES==
| |
| : 1. FSAR, Section [10.3].
| |
| U 14.3.4
| |
| : 2. FSAR, Section [6.2]. 1 2 U
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| 14.2.5
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| : 3. FSAR, Section [15.1.5].
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| U 10 CFR 50.67 1
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| : 4. 10 CFR 100.11.
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| Inservice Testing Program 2
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| : 5. [Technical Requirements Manual.]
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| : 6. ASME Code for Operation and Maintenance of Nuclear Power Plants.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.7.2-5 Rev. 5.0 1
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| | |
| 6/9/22, 12:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 955 NRC Question JMW005 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:28 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=955 1/1
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| | |
| 5/19/22, 3:41 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 427 NRC Question JMW006 Number Category Editorial ITS Section 3.7 ITS Number 3.7.3 DOC Number JFD Number JFD Bases Number Page 68 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question 3.7.3 Bases - LCO first paragraph, first sentence, The R in MFRV is struck out and not replaced with a C. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:28 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=427 1/1
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| | |
| 8/14/22, 9:20 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 775 NRC Question JMW006 Number Select Licensee Response Application Attachment Attachment 1 - JMW006 LAR Markups.pdf (631KB) 1 Attachment 2
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| Response FPL will revise the Limiting Condition for Operation (LCO) Bases of ITS 3.7.3 to insert a "C" for the struck-Statement out "R". See attached JMW006 license amendment request (LAR) markup.
| |
| Attachment
| |
| : 1. JMW006 LAR Markups
| |
| | |
| ===Response===
| |
| 6/3/2022 4:30 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/3/2022 3:29 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=775 1/1
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| | |
| MFIVs and MFRVs [and Associated Bypass Valves] 1 2 C
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| B 3.7.3 BASES BACKGROUND (continued) U C
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| A description of the MFIVs and MFRVs is found in the FSAR, 10.2 Section [10.4.7] (Ref. 1).
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| 2 APPLICABLE The design basis of the MFIVs and MFRVs is established by the C
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| SAFETY analyses for the large SLB. It is also influenced by the accident analysis ANALYSES for the large FWLB. Closure of the MFIVs and associated bypass valves, or MFRVs and associated bypass valves, may also be relied on to C
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| terminate an SLB for core response analysis and excess feedwater event upon the receipt of a steam generator water level - high high signal or a feedwater isolation signal on high steam generator level.
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| Feedwater isolation C
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| Failure of an MFIV, MFRV, or the associated bypass valves to close valves do not have a following an SLB or FWLB can result in additional mass and energy being credited function in the Feedwater Line Break delivered to the steam generators, contributing to cooldown. This failure analysis. also results in additional mass and energy releases following an SLB or FWLB event. C C
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| The MFIVs and MFRVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
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| 1 LCO This LCO ensures that the MFIVs, MFRVs, and their associated bypass valves will isolate MFW flow to the steam generators, following an FWLB or main steam line break . These valves will also isolate the nonsafety related portions from the safety related portions of the system.
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| three three This LCO requires that [four] MFIVs and associated bypass valves and 2 C
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| [four] MFRVs [and associated bypass valves] be OPERABLE. The C
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| MFIVs and MFRVs and the associated bypass valves are considered OPERABLE when isolation times are within limits and they close on an isolation actuation signal.
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| Failure to meet the LCO requirements can result in additional mass and energy being released to containment following an SLB or FWLB inside containment. If a feedwater isolation signal on high steam generator level is relied on to terminate an excess feedwater flow event, failure to meet the LCO may result in the introduction of water into the main steam lines.
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| APPLICABILITY C The MFIVs and MFRVs and the associated bypass valves must be OPERABLE whenever there is significant mass and energy in the Reactor Coolant System and steam generators. This ensures that, in the event of an HELB, a single failure cannot result in the blowdown of more than one steam generator. In MODES 1, 2, [and 3], the MFIVs and 2 C
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| MFRVs and the associated bypass valves are required to be OPERABLE to limit the amount of available fluid that could be added to containment in the case of a secondary system pipe break inside containment. When the valves are closed and de-activated or isolated by a closed manual valve, they are already performing their safety function.
| |
| Westinghouse STS B 3.7.3-2 Rev. 5.0 Turkey Point Unit 3 and Unit 4 Revision XXX
| |
| | |
| 6/9/22, 12:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 959 NRC Question JMW006 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:29 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=959 1/1
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| | |
| 5/19/22, 3:43 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 431 NRC Question JMW007 Number Category Editorial ITS Section 3.7 ITS Number 3.7.3 DOC Number JFD Number JFD Bases Number Page 68 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
| |
| Requested NRC Question 3.7.3 Bases - LCO second paragraph first sentence - the M in MFIV is not struck out, this is inconsistent with the rest of this section. Please evaluate and make necessary corrections.
| |
| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:30 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=431 1/1
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| | |
| 8/14/22, 9:21 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 779 NRC Question JMW007 Number Select Licensee Response Application Attachment Attachment 1 - JMW007 LAR Markups.pdf (71KB) 1 Attachment 2
| |
| Response FPL will revise the Limiting Condition for Operation (LCO) Bases of ITS 3.7.3 to strike out the subject "M".
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| Statement See attached JMW007 license amendment request (LAR) markup.
| |
| Attachment
| |
| : 1. JMW007 LAR Markups
| |
| | |
| ===Response===
| |
| 6/3/2022 4:30 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/3/2022 3:31 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=779 1/1
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| | |
| MFIVs and MFRVs [and Associated Bypass Valves] 1 2 C
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| B 3.7.3 BASES BACKGROUND (continued) U C
| |
| A description of the MFIVs and MFRVs is found in the FSAR, 10.2 Section [10.4.7] (Ref. 1).
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| 2 APPLICABLE The design basis of the MFIVs and MFRVs is established by the C
| |
| SAFETY analyses for the large SLB. It is also influenced by the accident analysis ANALYSES for the large FWLB. Closure of the MFIVs and associated bypass valves, or MFRVs and associated bypass valves, may also be relied on to C
| |
| terminate an SLB for core response analysis and excess feedwater event upon the receipt of a steam generator water level - high high signal or a feedwater isolation signal on high steam generator level.
| |
| Feedwater isolation C
| |
| Failure of an MFIV, MFRV, or the associated bypass valves to close valves do not have a following an SLB or FWLB can result in additional mass and energy being credited function in the Feedwater Line Break delivered to the steam generators, contributing to cooldown. This failure analysis. also results in additional mass and energy releases following an SLB or FWLB event.
| |
| C The MFIVs and MFRVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
| |
| 1 LCO This LCO ensures that the MFIVs, MFRVs, and their associated bypass valves will isolate MFW flow to the steam generators, following an FWLB or main steam line break . These valves will also isolate the nonsafety related portions from the safety related portions of the system.
| |
| three three This LCO requires that [four] MFIVs and associated bypass valves and 2 C
| |
| [four] MFRVs [and associated bypass valves] be OPERABLE. The C
| |
| MFIVs and MFRVs and the associated bypass valves are considered OPERABLE when isolation times are within limits and they close on an isolation actuation signal.
| |
| Failure to meet the LCO requirements can result in additional mass and energy being released to containment following an SLB or FWLB inside containment. If a feedwater isolation signal on high steam generator level is relied on to terminate an excess feedwater flow event, failure to meet the LCO may result in the introduction of water into the main steam lines.
| |
| APPLICABILITY C The MFIVs and MFRVs and the associated bypass valves must be OPERABLE whenever there is significant mass and energy in the Reactor Coolant System and steam generators. This ensures that, in the event of an HELB, a single failure cannot result in the blowdown of more than one steam generator. In MODES 1, 2, [and 3], the MFIVs and 2 C
| |
| MFRVs and the associated bypass valves are required to be OPERABLE to limit the amount of available fluid that could be added to containment in the case of a secondary system pipe break inside containment. When the valves are closed and de-activated or isolated by a closed manual valve, they are already performing their safety function.
| |
| Westinghouse STS B 3.7.3-2 Rev. 5.0 Turkey Point Unit 3 and Unit 4 Revision XXX
| |
| | |
| 6/9/22, 12:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 963 NRC Question JMW007 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:29 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=963 1/1
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| | |
| 5/19/22, 3:46 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 435 NRC Question JMW008 Number Category Editorial ITS Section 3.7 ITS Number 3.7.3 DOC Number JFD Number JFD Bases Number Page 72 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
| |
| Requested NRC ITS Bases for Section 3.7.3 Reference 2 lists In Service Testing Program, it should be Inservice Test Question Program (No space in Inservice). Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:32 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=435 1/1
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| | |
| 8/14/22, 9:21 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 783 NRC Question JMW008 Number Select Licensee Response Application Attachment 1 Attachment 1 - JMW008 LAR Markups.pdf (625KB)
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| Attachment 2 Response FPL will revise the ITS 3.7.3 Bases reference to state "Inservice Testing Program." See attached Statement JMW008 license amendment request (LAR) markup.
| |
| Attachment
| |
| : 1. JMW008 LAR Markups
| |
| | |
| ===Response===
| |
| 6/3/2022 4:30 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/3/2022 3:32 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=783 1/1
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| | |
| MFIVs and MFRVs [and Associated Bypass Valves] 1 2 C
| |
| B 3.7.3 BASES SURVEILLANCE REQUIREMENTS (continued)
| |
| The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
| |
| -----------------------------------REVIEWER S NOTE-----------------------------------
| |
| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
| |
| ------------------------------------------------------------------------------------------------ ]
| |
| U REFERENCES 1. FSAR, Section [10.4.7]. 1 2 10.2 Inservice
| |
| : 2. [Technical Requirements Manual.] 2 In Service Testing Program
| |
| : 3. ASME Code for Operation and Maintenance of Nuclear Power Plants.
| |
| Westinghouse STS B 3.7.3-6 Rev. 5.0 Turkey Point Unit 3 and Unit 4 Revision XXX
| |
| | |
| 6/13/22, 1:50 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1135 NRC Question JMW008 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/13/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/13/2022 12:22 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1135 1/1
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| | |
| 5/19/22, 3:53 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 439 NRC Question JMW009 Number Category Editorial ITS Section 3.7 ITS Number 3.7.4 DOC Number JFD Number JFD Bases Number Page 90 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
| |
| Requested NRC In the Bases for SR 3.7.4.1 - The statement The Surveillance Frequency is controlled by the Surveillance Question Frequency Control Program is struck out. Please evaluate and make necessary corrections.
| |
| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:33 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=439 1/1
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| | |
| 8/14/22, 9:22 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 787 NRC Question JMW009 Number Select Licensee Response Application Attachment Attachment 1 - JMW009 LAR Markups.pdf (629KB) 1 Attachment 2
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| Response FPL will revise the ITS 3.7.4, Surveillance Requirement (SR) 3.7.4.1, Bases to add the statement associated Statement with the Surveillance Frequency Control Program. See attached JMW009 license amendment request (LAR) markup.
| |
| Attachment
| |
| : 1. JMW009 LAR Markups
| |
| | |
| ===Response===
| |
| 6/3/2022 4:35 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/3/2022 3:34 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=787 1/1
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| | |
| Secondary Specific Activity 4 1 B 3.7.18 BASES 4
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| SURVEILLANCE SR 3.7.18.1 1 REQUIREMENTS This SR verifies that the secondary specific activity is within the limits of the accident analysis. A gamma isotopic analysis of the secondary coolant, which determines DOSE EQUIVALENT I-131, confirms the validity of the safety analysis assumptions as to the source terms in post accident releases. It also serves to identify and trend any unusual isotopic concentrations that might indicate changes in reactor coolant The Surveillance Frequency activity or LEAKAGE. [ The 31 day Frequency is based on the detection 2 is controlled under the of increasing trends of the level of DOSE EQUIVALENT I-131, and allows Surveillance Frequency for appropriate action to be tak en to maintain levels below the LCO limit.
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| Control Program.
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| 3 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
| |
| -----------------------------------REVIEWER S NOTE-----------------------------------
| |
| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
| |
| ------------------------------------------------------------------------------------------------ ]
| |
| 10 CFR 50.67 REFERENCES 1. 10 CFR 100.11. 3 14
| |
| : 2. FSAR, Chapter [15] . 1 2 U
| |
| Turkey Point Unit 3 and Unit 4 4 Revision XXX 3 1 Westinghouse STS B 3.7.18-3 Rev. 5.0
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| | |
| 6/9/22, 12:30 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 967 NRC Question JMW009 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:30 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=967 1/1
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| | |
| 5/19/22, 3:54 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 443 NRC Question JMW010 Number Category Editorial ITS Section 3.7 ITS Number 3.7.5 DOC Number LA-1 JFD Number JFD Bases Number Page 100 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
| |
| Requested NRC Question LA01 - states in part ITS LCO 3.7.5 states Two AFW trains and three AFW steam supplies shall be OPERABLE.
| |
| This quote should read: ITS LCO 3.7.5 states Two AFW trains and three steam generator steam supplies shall be OPERABLE Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:35 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=443 1/1
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| | |
| 8/14/22, 9:22 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 791 NRC Question JMW010 Number Select Licensee Response Application Attachment Attachment 1 - JMW010 LAR Markups.pdf (691KB) 1 Attachment 2
| |
| Response FPL will revise ITS 3.7.5, Discussion of Change (DOC) LA01 to correctly quote the ITS 3.7.5 Limiting Statement Condition for Operation (LCO). See attached JMW010 license amendment request (LAR) markup.
| |
| Attachment
| |
| : 1. JMW010 LAR Markups
| |
| | |
| ===Response===
| |
| 6/3/2022 4:35 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/3/2022 3:37 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=791 1/1
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| | |
| DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.7.1.2 requires two independent auxiliary feedwater trains including 3 steam supply flowpaths, 3 pumps (changed to 2 under DOC L01) and associated discharge water flowpaths shall be OPERABLE. The CTS LCO also contains footnotes further describing specifics that are required in each AFW train. ITS LCO 3.7.5 states "Two AFW trains and three AFW steam steam generator supplies shall be OPERABLE. The ITS does not include design details, components and associated flow paths that comprise an OPERABLE AFW train.
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| This changes the CTS by moving the description of the AFW independence, trains, and components required for OPERABILITY to the Bases.
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| The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS retains all necessary requirements in the LCO to ensure OPERABILITY for the AFW trains and specific details, such as, system composition, independence, etc., are located in the Bases. Also, this change is acceptable because the removed information will be controlled in the ITS Bases.
| |
| Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program directs the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
| |
| LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.7.1.2.1.a.1) and CTS 4.7.1.2.1.a.2) state, in part, to verify equipment performance, "by control panel indication and visual observation of equipment". ITS 3.7.5 does not include this guidance on how to verify equipment performed as required. This changes the CTS by removing procedural details for meeting TS requirements.
| |
| The removal of these details for performing surveillance requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements to verify that the steam turbine-driven pumps and the auxiliary feedwater valves operate as required. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program directs the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
| |
| LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.7.1.2 states, in part, that two independent auxiliary feedwater trains including 3 pumps shall be Turkey Point Unit 3 and Unit 4 Page 2 of 5
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| 6/9/22, 12:30 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 971 NRC Question JMW010 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
| |
| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:32 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=971 1/1
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| | |
| 5/19/22, 4:13 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 447 NRC Question JMW011 Number Category Technical ITS 3.7 Section ITS 3.7.5 Number DOC L-4 Number JFD Number JFD Bases Number Page 103 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
| |
| Requested NRC L04 states This changes the CTS by requiring the pump to start, instead of just receiving a start signal, and Question allowing the SR to only be required to be performed in MODE 1 The portion of this statement referring to the requirement for the pump to start, and not just receive a signal is a more restrictive change. Please update the Discussion of Changes.
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| Attach File 1
| |
| Attach File 2
| |
| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:36 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=447 1/1
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| | |
| 8/3/22, 5:36 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1407 NRC Question JMW011 Number Select Licensee Response Application Attachment 1
| |
| Attachment 2
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| Response The change to require an auxiliary feedwater (AFW) pump start instead of only receiving a start signal is Statement necessary to ensure the entire start sequence is included. However, since all AFW pumps at PTN are turbine driven pumps, the AFW pump cannot be started until adequate steam pressure is available in the steam generators; therefore, the proposed Note to ITS SR 3.7.5.4 is also added. The addition of the Note is a less restrictive change because SR performance is delayed until after the unit enters MODES 2 and 3 instead of requiring the SR to be performed prior to entering MODE 3. The SR 3.7.5.4 requirement to verify AFW pump start in conjunction with the delay in SR performance until after entry into MODE 2 and 3 represents a less restrictive change in the aggregate. Therefore, FPL has determined no change is required to the ITS 3.7.5 Discussion of Changes.
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| ===Response===
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| 7/1/2022 12:25 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/1/2022 11:25 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1407 1/1
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| 7/15/22, 1:46 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1602 NRC Question JMW011 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/15/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/15/2022 12:45 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1602 1/1
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| 5/19/22, 4:18 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 451 NRC Question JMW012 Number Category Editorial ITS Section 3.7 ITS Number 3.7.6 DOC Number JFD Number JFD Bases Number Page Number(s) 145 NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question In ITS 3.7.6, the AND between Required Action A.1 and A.2 should be underlined.
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| Please evaluate and make necessary corrections Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:37 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=451 1/1
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| 8/14/22, 9:25 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 795 NRC Question JMW012 Number Select Licensee Response Application Attachment 1 Attachment 1 - JMW012 LAR Markups.pdf (67KB)
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| Attachment 2 Response FPL will revise ITS 3.7.6 to underline the "AND" between Required Actions A.1 and A.2. See attached Statement JMW012 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW012 LAR Markups
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| | |
| ===Response===
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| 6/5/2022 6:35 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Craig Harbuck Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/5/2022 5:35 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=795 1/1
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| CTS CST 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST)
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| System 3.7.1.3 LCO 3.7.6 The CST shall be OPERABLE. 1 Applicability APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal. 2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 1
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| A. CST inoperable. A.1 Verify by administrative 4 hours 3
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| System availability means OPERABILITY of backup water supply. AND Once per 12 hours thereafter AND System A.2 Restore CST to 7 days 1 OPERABLE status.
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| INSERT 1 1 Action B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND 12 B.2 Be in MODE 4, without [24] hours 4 reliance on steam 1 generator for heat removal.
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| INSERT 2 Westinghouse STS 3.7.6-1 Rev. 5.0 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY
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| 6/9/22, 12:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 975 NRC Question JMW012 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:33 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=975 1/1
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| 5/19/22, 4:19 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 455 NRC Question JMW013 Number Category Editorial ITS Section 3.7 ITS Number 3.7.6 DOC Number JFD Number JFD Bases Number Page Number(s) 145 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Question In ITS 3.7.6, the AND between the Completion Times in Condition A should be underlined. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:39 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=455 1/1
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| 8/14/22, 9:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 859 NRC Question JMW013 Number Select Licensee Response Application Attachment 1 Attachment 1 - JMW013 LAR Markups.pdf (67KB)
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| Attachment 2 Response FPL will revise ITS 3.7.6 to underline the "AND" between Completion Times in Condition A. See attached Statement JMW013 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW013 LAR Markups
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| | |
| ===Response===
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| 6/6/2022 11:00 AM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/6/2022 9:59 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=859 1/1
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| CTS CST 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST)
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| System 3.7.1.3 LCO 3.7.6 The CST shall be OPERABLE. 1 Applicability APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal. 2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 1
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| A. CST inoperable. A.1 Verify by administrative 4 hours 3
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| System availability means OPERABILITY of backup water supply. AND Once per 12 hours thereafter AND System A.2 Restore CST to 7 days 1 OPERABLE status.
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| INSERT 1 1 Action B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND 12 B.2 Be in MODE 4, without [24] hours 4 reliance on steam 1 generator for heat removal.
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| INSERT 2 Westinghouse STS 3.7.6-1 Rev. 5.0 2 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY
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| 6/9/22, 12:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 979 NRC Question JMW013 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:33 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=979 1/1
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| 5/19/22, 4:21 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 459 NRC Question JMW014 Number Category Editorial ITS 3.7 Section ITS 3.7.6 Number DOC Number JFD Number JFD Bases Number Page 153 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC In the Bases for Actions A.1 and A.2, a sentence reads must include verification that the flow paths from Question the backup water supply to the AFW pumps are availability. availability in this sentence should be available. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:40 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=459 1/1
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| 8/3/22, 5:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 799 NRC Question JMW014 Number Select Licensee Response Application Attachment Attachment 1 - JMW014 LAR Markups.pdf (674KB) 1 Attachment 2
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| Response FPL will revise Required Actions A.1 and A.2 ITS 3.7.6 Bases to insert "available" in lieu of "availability".
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| Statement See attached JMW014 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW014 LAR Markups
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| | |
| ===Response===
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| 6/5/2022 6:40 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/5/2022 5:41 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=799 1/1
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| CST B 3.7.6 BASES APPLICABLE SAFETY ANALYSES (continued)
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| These are not usually the limiting failures in terms of consequences for these events.
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| A nonlimiting event considered in CST inventory determinations is a break in either the main feedwater or AFW line near where the two join.
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| This break has the potential for dumping condensate until terminated by operator action, since the Emergency Feedwater Actuation System would not detect a difference in pressure between the steam generators for this break location. This loss of condensate inventory is partially compensated for by the retention of steam generator inventory.
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| The CST satisfies Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii).
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| LCO 18 hours To satisfy accident analysis assumptions, the CST must contain sufficient cooling water to remove decay heat for [30 minutes] following a reactor 2 trip from 102% RTP, and then to cool down the RCS to RHR entry 1 conditions, assuming a coincident loss of offsite power and the most adverse single failure. In doing this, it must retain sufficient water to ensure adequate net positive suction head for the AFW pumps during cooldown, as well as account for any losses from the steam driven AFW pump turbine, or before isolating AFW to a brok en line.
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| The CST level required is equivalent to a usable volume of
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| [110,000 gallons], which is based on holding the unit in MODE 3 for
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| [2] hours, followed by a cooldown to RHR entry conditions at [75]°F/hour. 1 This basis is established in Reference 4 and exceeds the volume required by the accident analysis. INSERT 3 (s)
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| System The OPERABILITY of the CST is determined by maintaining the tank 1 level at or above the minimum required level.
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| APPLICABILITY In MODES 1, 2, and 3, and in MODE 4, when steam generator is being relied upon for heat removal, the CST is required to be OPERABLE. 1 4, System In MODE 5 or 6, the CST is not required because the AFW System is not 1 required. System ACTIONS A.1 and A.2 System availability If the CST is not OPERABLE, the OPERABILITY of the backup supply 1 5 should be verified by administrative means within 4 hours and once every Availability 12 hours thereafter. OPERABILITY of the backup feedwater supply must 5 available include verification that the flow paths from the backup water supply to availability the AFW pumps are OPERABLE, and that the backup supply has the 5 System required volume of water available. The CST must be restored to 1 OPERABLE status within 7 days, because the backup supply may be Westinghouse STS B 3.7.6-2 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 6/9/22, 12:33 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 983 NRC Question JMW014 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:34 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=983 1/1
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| 5/19/22, 4:24 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 463 NRC Question JMW015 Number Category Editorial ITS 3.7 Section ITS 3.7.6 Number DOC Number JFD Number JFD Bases Number Page 156 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Insert 4 in the Bases for Section 3.7.6 reads in part remedial actions if the CST system is not OPERABLE Question due to indicated volume < 210,000 gallons with the opposite Unit in MODE 1, 2, or 3. Evaluate if this statement should say the opposite Unit not in MODE 1,2,3, and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:42 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=463 1/1
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| 8/14/22, 9:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1311 NRC Question JMW015 Number Select Licensee Response Application Attachment Attachment 1 - JMW015 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response FPL will revise ITS 3.7.6 Bases Insert 4 to indicate that the Condensate Storage Tank (CST) < 210,000 Statement gallon value is only applicable when the opposite unit is not in MODES 1, 2, or 3. See attached JMW015 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW015 LAR Markups
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| | |
| ===Response===
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| 6/28/2022 1:30 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/28/2022 12:28 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1311 1/1
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| ITS 3.7.6 1
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| IN S E R T 4 System and unit Condition A provides remedial actions if the CST system is not OPERABLE due to indicated water volume (level) < 420,000 gallons with the opposite Unit in MODE 1, 2, or 3; remedial actions if the CST system is not OPERABLE due to indicated volume < 210,000 gallons with the opposite Unit in MODE 1, 2, or 3; and remedial actions if the CST system is not OPERABLE with the opposite unit not in MODE 1, 2, or 3. If the opposite unit is in MODE 1, 2, or 3 the Condition is applicable to both units. A backup, non-safety source of water is the demineralized water storage tank (DWST). The DWST is a 500,000 gallon, non-safety related source of demineralized water that is considered part of the primary mak eup demineralized water system.
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| 1 IN S E R T 5 This condition is modified by a Note stating that this condition is not applicable during a dual unit shut down.
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| C.1 and C.2 If the CST cannot be restored to OPERABLE status within the associated Completion Time, the units must be placed in a MODE in which the LCO does not apply. To achieve this status, the units must be placed in at least MODE 3 within 12 hours, and in MODE 4, within 18 hours. The allowed Completion Times allow for the orderly shutdown of one unit at a time and not jeopardize the stability of the electrical grid by imposing a dual unit shutdown.
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| This condition is modified by a Note stating that this condition is only applicable during a dual unit shut down.
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| 1 IN S E R T 6 when the opposite unit is also in MODE 1, 2, or 3. A minimum indicated volume of 210,000 gallons is maintained for each unit in MODE 1, 2 or 3 so with both units in MODE 1, 2, or 3, 420,000 gallons indicated water volume is required. This volume provides margin over the analysis minimum required volume and includes an allowance for instrument indication uncertainties and for water deemed unusable because of vortex formation and the configuration of the discharge line.
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| Insert Page B 3.7.6-3a
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| 6/29/22, 11:33 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1331 NRC Question JMW015 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/29/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/29/2022 10:32 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1331 1/1
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| 5/19/22, 4:26 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 467 NRC Question JMW016 Number Category Technical ITS 3.7 Section ITS 3.7.7 Number DOC Number JFD Number JFD Bases Number Page 165 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC CTS SR 4.7.2.c states - In accordance with the Surveillance Frequency Control Program during shutdown, Question by verifying that ITS SRs 3.7.7.2 and 3.7.7.3 do not include the statement during shutdown and the difference is not identified in the DOCs. Provide justification for this change.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:44 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=467 1/1
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| 8/14/22, 9:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 887 NRC Question JMW016 Number Select Licensee Response Application Attachment Attachment 1 - JMW016 LAR Markups.pdf (2MB) 1 Attachment 2
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| Response FPL will add a new Discussion of Change (DOC) L05 to address the removal of the "during shutdown" Statement restriction. The "during shutdown" phrase in CTS SR 4.7.2.c will also be struck and reference to DOC L05 added to the associated CTS markup page. See attached JMW016 license amendment request (LAR) markup. Proposed DOC L05 is included below.
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| (Category 8 - Deletion of Surveillance Requirement Shutdown Performance Requirements)
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| CTS 4.7.2.c requires testing of specified Component Cooling Water (CCW) equipment in accordance with the Surveillance Frequency Control Program "during shutdown." ITS SRs 3.7.7.2 and 3.7.7.3 do not contain a MODE restriction related to when this testing may be performed. This changes the CTS by removing the restriction on surveillance performance during specific MODES. The purpose of CTS 4.7.2.c is to demonstrate that, upon receipt of an associated actuation signal, each CCW automatic valve in the flow path servicing safety related equipment can actuate to its correct position and each CCW pump can automatically start, which also verifies required interlocks are OPERABLE. The control of unit conditions appropriate to perform the test is an issue for procedures and scheduling and has been determined by the NRC to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, removal of this specific restriction is consistent with the vast majority of other Technical Specification Surveillances that do not dictate unit conditions for the Surveillance. The proposed change is acceptable because it does not change the method of test or frequency of the affected surveillances. The proposed change only deletes the requirement to perform this testing during shutdown conditions. In addition, allowing this testing to be performed either at refueling, shutdown, or at power does not affect the applicable safety analysis conclusions and allows shutdown activities to be planned which will aid to reduce risk and increase equipment availability during shutdowns. Thus, the proposed change will continue to provide adequate assurance the required components are routinely tested to ensure system OPERABILITY while providing some additional flexibility in planning and scheduling the required testing. In addition, due to system designs that allow for safe testing at power, the proposed change will not adversely affect the safe operation of the plant. The proposed change is designated as less restrictive because the Surveillance may be performed during plant conditions other than shutdown.
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| Attachment
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| : 1. JMW016 LAR Markups
| |
| | |
| ===Response===
| |
| 6/7/2022 12:30 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/7/2022 11:27 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=887 1/2
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| 8/14/22, 9:27 PM Turkey Point ITS Conversion Database https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=887 2/2
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| | |
| ITS A01 ITS 3.7.7 SURVEILLANCE REQUIREMENTS (Continued)
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| Add proposed SR 3.7.7.1 Note A04 SR 3.7.7.1 b. 1) In accordance with the Surveillance Frequency Control Program verify that each valve (manual, power-operated, or automatic) servicing safety-related equipment A05 that is not locked, sealed, or otherwise secured in position is in its correct in the flowpath position.
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| LA02
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| : 2) In accordance with the Surveillance Frequency Control Program verify by a L05 performance test the heat exchanger surveillance curves.*
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| A05
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| : c. In accordance with the Surveillance Frequency Control Program during shutdown, by verifying that: that is not locked, sealed, or otherwise in the flowpath secured in position L03 SR 3.7.7.2 1) Each automatic valve servicing safety-related equipment actuates to its correct position on a SI test signal, and an actual or simulated actuation L04 SR 3.7.7.3 2) Each Component Cooling Water System pump starts automatically on a SI test signal.
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| SR 3.7.7.3 3) Interlocks required for CCW operability are OPERABLE.
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| A06 LA02
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| *Technical specification 4.7.2.b.2 is not applicable for entry into MODE 4 or MODE 3, provided that:
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| : 1) Surveillance 4.7.2.b.2 is performed no later than 72 hours after reaching a Reactor Coolant System Tavg of 547°F, and
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| : 2) MODE 2 shall not be entered prior to satisfactory performance of this surveillance.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-15 AMENDMENT NOS. 263 AND 258 Page 2 of 2
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| DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER SYSTEM (CCS)
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| This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.
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| L04 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
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| CTS 4.7.2.c.1 and CTS 4.7.2.c.2 require verifying that each automatic valve servicing safety-related equipment and each CCW system pump starts automatically on a SI test signal. ITS SR 3.7.7.2 and ITS SR 3.7.7.3 specify that the signal may be from either an "actual" or simulated (i.e., test) signal. This changes the CTS by explicitly allowing the use of either an actual or simulated signal for the test.
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| The purpose of CTS 4.7.2.c.1 and CTS 4.7.2.c.2 is to ensure that the automatic valves servicing safety related equipment and CCW system pumps operate correctly upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its specified safety functions. Equipment cannot discriminate between an "actual,"
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| "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. The change also allows a simulated signal to be used, if necessary. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.
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| L05 (Category 8 - Deletion of Surveillance Requirement Shutdown Performance Requirements) CTS 4.7.2.c requires testing of specified Component Cooling Water (CCW) equipment in accordance with the Surveillance Frequency Control Program "during shutdown." ITS SRs 3.7.7.2 and 3.7.7.3 do not contain a MODE restriction related to when this testing may be performed. This changes the CTS by removing the restriction on surveillance performance during specific MODES.
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| The purpose of CTS 4.7.2.c is to demonstrate that, upon receipt of an associated actuation signal, each CCW automatic valve in the flow path servicing safety related equipment can actuate to its correct position and each CCW pump can automatically start, which also verifies required interlocks are OPERABLE. The control of unit conditions appropriate to perform the test is an issue for procedures and scheduling and has been determined by the NRC to be unnecessary as a Technical Specification restriction. As indicated in Generic Letter 91-04, removal of this specific restriction is consistent with the vast majority of other Technical Specification Surveillances that do not dictate unit conditions for the Surveillance. The proposed change is acceptable because it does not change the method of test or frequency of the affected surveillances. The proposed change only deletes the requirement to perform this testing during shutdown conditions. In addition, allowing this testing to be performed either at refueling, shutdown, or at power does not affect the applicable safety analysis conclusions and allows shutdown activities to be planned which will aid to reduce risk and increase equipment availability during shutdowns. Thus, the proposed change will continue to provide adequate assurance the required components are routinely tested to ensure system OPERABILITY while providing some additional flexibility in planning and scheduling the required testing. In addition, due to system designs that allow for safe testing at power, the proposed change will not adversely affect the safe operation of the plant. The proposed change is designated as less restrictive because the Surveillance may be performed during plant conditions other than shutdown.
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| Turkey Point Unit 3 and Unit 4 Page 7 of 7
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| 6/16/22, 1:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1167 NRC Question JMW016 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/16/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/16/2022 10:11 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1167 1/1
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| 5/19/22, 4:27 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 471 NRC Question JMW017 Number Category Editorial ITS 3.7 Section ITS 3.7.7 Number DOC LA-2 Number JFD Number JFD Bases Number Page 169 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC DOC LA02 for ITS 3.7.7 - The last sentence states This change is designated as a less restrictive removal of Question detail change because a backup nitrogen supply is being removed from the Technical Specifications.
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| Backup nitrogen supply seems to be unrelated to this change. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
| |
| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:45 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=471 1/1
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| 8/14/22, 9:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 803 NRC Question JMW017 Number Select Licensee Response Application Attachment Attachment 1 - JMW017 LAR Markups.pdf (693KB) 1 Attachment 2
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| Response FPL will revise ITS 3.7.7, Discussion of Change (DOC) LA02, replacing reference to the backup nitrogen Statement supply with the appropriate description associated with the removal of the Component Cooling Water (CCW) System heat exchanger performance test surveillances. Other editorial changes are also incorporated. See attached JMW017 license amendment request (LAR) markup.
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| Attachment
| |
| : 1. JMW017 LAR Markups
| |
| | |
| ===Response===
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| 6/5/2022 6:45 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/5/2022 5:45 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=803 1/1
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| DISCUSSION OF CHANGES CCW ITS 3.7.7, COMPONENT COOLING WATER SYSTEM (CCS) controlled by the Technical Specification Bases Control Program in Chapter 5.
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| This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA02 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 4.7.2.a requires verifying that two [CCW] heat exchangers and one [CCW] pump are capable of removing design basis heat loads at a frequency in accordance with the Surveillance Frequency Control Program. CTS 4.7.2.b.2) requires verifying by a performance test the heat exchanger surveillance curves at a frequency in accordance with the Surveillance Frequency Control Program. A footnote modifies the performance of CTS 4.7.2.b.2) stating that technical specification 4.7.2.b.2 is not applicable for entry into MODE 4 or MODE 3, provided that: 1) Surveillance 4.7.2.b.2 is performed no later than 72 hours after reaching a Reactor Coolant System Tavg of 547°F, and 2) MODE 2 shall not be entered prior to satisfactory performance of this surveillance. ITS 3.7.7 does not contain these surveillance requirements.
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| This changes the CTS by removing the CCW heat exchanger performance test surveillances.
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| The removal the of the CCW heat exchanger performance test surveillances from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health and safety. The requirements to maintain the CCW heat exchanger performance is relocated to the Technical Requirements Manual (TRM). The CCW heat exchanger performance test surveillances are surveillances performed to determine when a CCW heat exchanger requires cleaning to ensure the combination of any two CCW heat exchangers are adequate to remove the analyzed heat load and can be adequately controlled in the TRM. Changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a backup nitrogen supply is being removed from the Technical Specifications. the CCW heat exchanger performance test surveillances are LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.7.2 states that the Component Cooling Water System (CCW) shall be OPERABLE with: a. Three CCW pumps, and b. Two CCW heat exchangers. In addition, CTS 3.7.2 Action
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| : a. requires that with only two CCW pumps with independent power supplies OPERABLE to restore the inoperable CCW pump to OPERABLE status within 30 days. ITS 3.7.7 states that two CCW trains shall be OPERABLE. This changes the CTS by reducing the number of CCW pumps required to be OPERABLE from three to two and eliminating the associated action requirement to restore a single CCW pump to OPERABLE status within 30 days.
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| The purpose of CTS 3.7.2 is to provide the lowest functional capability or performance levels of equipment required for safe operation of the facility and the Turkey Point Unit 3 and Unit 4 Page 4 of 7
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| 6/9/22, 12:34 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 987 NRC Question JMW017 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:39 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=987 1/1
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| 5/19/22, 4:28 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 475 NRC Question JMW018 Number Category Editorial ITS Section 3.7 ITS 3.7.7 Number DOC Number JFD Number JFD Bases Number Page 184 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Bases 3.7.7 action A.1 states action must be taken to restore a required heat exchanger OPERABLE state Question within This statement seems to be missing some words. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:47 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=475 1/1
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| 8/14/22, 9:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 807 NRC Question JMW018 Number Select Licensee Response Application Attachment Attachment 1 - JMW018 LAR Markups.pdf (627KB) 1 Attachment 2
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| Response FPL will revise the Bases of ITS 3.7.7, Required Action A.1, by adding the term "to" prior to the term Statement "OPERABLE". See attached JMW018 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW018 LAR Markups
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| | |
| ===Response===
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| 6/5/2022 6:50 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/5/2022 5:49 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=807 1/1
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| CCW System B 3.7.7 BASES 1
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| ACTIONS A.1 Required Action A.1 is modified by a Note indicating that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"
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| be entered if an inoperable CCW train results in an inoperable RHR loop. 1 This is an exception to LCO 3.0.6 and ensures the proper actions are tak en for these components. to one or more CCW trains a required heat exchanger are inoperable due to required heat exchanger If one CCW train is inoperable, action must be tak en to restore 1
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| OPERABLE status within 72 hours [or in accordance with the Risk
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| . The 1 hour Completion Time Informed Completion Time Program]. In this Condition, the remaining to restore a required CCW heat exchanger to OPERABLE status OPERABLE CCW train is adequate to perform the heat removal function. 1 is consistent with other The 72 hour Completion Time is reasonable, based on the redundant Completion Times established capabilities afforded by the OPERABLE train, and the low probability of a for loss of a safety function and ensures that the plant will not DBA occurring during this period.
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| operate for long periods outside INSERT 5 1 of the safety analyses.
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| C B.1 and B.2 3 a require heat exchanger or one If the CCW train cannot be restored to OPERABLE status within the 1 associated Completion Time, the unit must be placed in a MODE in which overall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 4 within 12 hours.
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| Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.
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| C Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is 3 not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.
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| However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| Westinghouse STS B 3.7.7-3 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 6/9/22, 12:36 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 991 NRC Question JMW018 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:40 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=991 1/1
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| 5/19/22, 4:29 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 479 NRC Question JMW019 Number Category Editorial ITS Section 3.7 ITS Number 3.7.7 DOC Number JFD Number JFD Bases Number Page 184 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question Bases 3.7.7 Actions C.1 and C.2, the text bubble to be added says a require heat exchanger or one, it should say required. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:48 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=479 1/1
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| 8/14/22, 9:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 811 NRC Question JMW019 Number Select Licensee Response Application Attachment Attachment 1 - JMW019 LAR Markups.pdf (628KB) 1 Attachment 2
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| Response FPL will revise the Bases text bubble of ITS 3.7.7, Required Actions C.1 and C.2, to state "required" in lieu Statement of "require". See attached JMW019 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW019 LAR Markups
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| | |
| ===Response===
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| 6/5/2022 6:50 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/5/2022 5:52 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=811 1/1
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| CCW System B 3.7.7 BASES 1
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| ACTIONS A.1 Required Action A.1 is modified by a Note indicating that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"
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| be entered if an inoperable CCW train results in an inoperable RHR loop. 1 This is an exception to LCO 3.0.6 and ensures the proper actions are tak en for these components.
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| one or more CCW trains a required heat exchanger are inoperable due to required heat exchanger If one CCW train is inoperable, action must be tak en to restore 1
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| OPERABLE status within 72 hours [or in accordance with the Risk
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| . The 1 hour Completion Time Informed Completion Time Program]. In this Condition, the remaining to restore a required CCW heat exchanger to OPERABLE status OPERABLE CCW train is adequate to perform the heat removal function. 1 is consistent with other The 72 hour Completion Time is reasonable, based on the redundant Completion Times established capabilities afforded by the OPERABLE train, and the low probability of a for loss of a safety function and ensures that the plant will not DBA occurring during this period.
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| operate for long periods outside INSERT 5 1 of the safety analyses.
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| C B.1 and B.2 3 a require heat exchanger or one If the CCW train cannot be restored to OPERABLE status within the 1 associated Completion Time, the unit must be placed in a MODE in which required overall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 4 within 12 hours.
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| Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.
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| C Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is 3 not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.
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| However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| Westinghouse STS B 3.7.7-3 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 6/9/22, 12:37 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 995 NRC Question JMW019 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:40 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=995 1/1
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| 5/19/22, 4:31 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 483 NRC Question JMW020 Number Category Technical ITS 3.7 Section ITS 3.7.7 Number DOC LA-1 Number JFD Number JFD Bases Number Page 168, 169 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC CCW independence and operability requirements should be specifically addressed in ITS 3.7.7 LA01 (See Question ICW 3.7.8 LA01 ITS LCO 3.7.8 requires two ICW trains to be OPERABLE but does not define the components the associated flow path and independence that comprise an OPERABLE ICW train... This changes the CTS by moving the description of an OPERABLE ICW train to the Bases.).
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| The Bases should also specify that CCW train OPERABILITY requires a CCW pump with an independent power supply. (See Bases statement in LCO section of ITS 3.7.8 ICW An ICW pump with an independent power supply). Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:50 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=483 1/1
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| 8/14/22, 9:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 891 NRC Question JMW020 Number Select Licensee Response Application Attachment Attachment 1 - JMW020 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response ITS 3.7.7, Discussion of Change (DOC) LA01, discusses the details of the requirements CTS Limiting Statement Condition for Operation (LCO) 3.7.2.a and b requirements proposed for relocation to the ITS Bases, which do not include an explicit requirement that each Component Cooling Water (CCW) pump be powered from an independent power supply. It is noted that CTS 3.7.2, Action b, discusses pumps with independent power supplies. Therefore, ITS 3.7.7, DOC LA01, and the associated CTS 3.7.2 markup will be revised consistent with the CTS 3.7.3 markup and DOC LA01 of ITS 3.7.8 to include specific discussion of power supply independence. See attached JMW020 license amendment request (LAR) markup.
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| FPL has evaluated the Bases of ITS 3.7.7 and has determined that CCW train/pump independency (including an independent power supply) is sufficiently provided in the LCO section of the ITS 3.7.7 Bases markup, along with stating the components that are required to constitute train OPERABILITY. The ITS 3.7.7 Bases text is maintained as consistent with the ISTS Bases as practical while ensuring an equivalent understanding. The ITS 3.7.7 LCO Bases states, in part (emphasis added):
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| "The CCW trains are independent of each other to the degree that each has separate controls and power supplies and the operation of one does not depend on the other. In the event of a DBA, one CCW train is required to provide the minimum heat removal capability assumed in the safety analysis for the systems to which it supplies cooling water. To ensure this requirement is met, two trains of CCW must be OPERABLE.
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| At least one CCW train will operate assuming the worst case single active failure occurs coincident with a loss of offsite power.
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| CCW train is considered OPERABLE when:
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| : a. An independent pump and associated surge tank are OPERABLE;
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| : b. Two common heat exchangers are OPERABLE; and
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| : c. The associated piping, valves, and instrumentation and controls required to perform the safety related function are OPERABLE."
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| In addition, the Background section of ITS 3.7.7 Bases states, "Each safety related train is powered from a separate bus." Please note that the LCO section of the ITS 3.7.8 Bases does not explicitly describe Intake Cooling Water (ICW) pumps with independent power supplies. Therefore, the LCO section of the ITS 3.7.8 Bases markup includes additional text, which is unnecessary in the ITS 3.7.7 Bases.
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| Also note that the ITS presentation provides details related to electrical separation as discussed in the Bases of ITS 3.8.9, "Distribution Systems - Operating," and clarified specifically for CCW pumps in ITS 3.7.7 Bases as explained above.
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| Based on the information provided herein, sufficient information is included in the ITS 3.7.7 LCO Bases and the ITS 3.8.9 Bases to ensure an understanding of the OPERABILITY requirements for the CCW trains, including the information that CCW pumps must be powered from independent power supplies. Therefore, no change is proposed to the LCO section of the ITS 3.7.7 Bases.
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| Attachment
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| : 1. JMW020 LAR Markups
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| | |
| ===Response===
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| 6/7/2022 12:35 PM Date/Time Closure Statement Question https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=891 1/2
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| 8/14/22, 9:29 PM Turkey Point ITS Conversion Database Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/7/2022 11:36 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=891 2/2
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| ITS A01 ITS 3.7.7 PLANT SYSTEMS (CCW) 3/4.7.2 COMPONENT COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION A02 Two trains LCO 3.7.7 3.7.2 The Component Cooling Water System (CCW) shall be OPERABLE with:
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| Two L01
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| : a. Three CCW pumps, and LA01
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| : b. Two CCW heat exchangers.
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| Applicability APPLICABILITY: MODES 1, 2, 3, and 4.
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| ACTION:
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| Required Action B.1 NOTE: Enter applicable ACTIONS of LCO 3.4.1.3, "Reactor Coolant System - Hot Shutdown," for residual heat Note removal loops made inoperable by CCW. L01
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| : a. With only two CCW pumps with independent power supplies OPERABLE, restore the inoperable CCW pump to OPERABLE status within 30 days or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
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| LA01 Action B b. With only one CCW pump OPERABLE or with two CCW pumps OPERABLE but not from independent power supplies, restore two pumps from independent power supplies to OPERABLE status within 72 hours or in accordance with the Risk Informed Completion Time Program, or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following Action C 30 hours. Add proposed Required Action C.2 and associated Note L02 one required inoperable Action A c. With less than two CCW heat exchangers OPERABLE, restore two heat exchangers to OPERABLE status within 1 hour or be in HOT STANDBY within the next 6 hours and in COLD Action C SHUTDOWN within the following 30 hours.
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| Add proposed Required Action C.2 and associated Note L02 Add proposed ACTION D SURVEILLANCE REQUIREMENTS A03 4.7.2 The Component Cooling Water System (CCW) shall be demonstrated OPERABLE:
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| LA02
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| : a. In accordance with the Surveillance Frequency Control Program, by verifying that two heat exchangers and one pump are capable of removing design basis heat loads.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-14 AMENDMENT NOS. 287 AND 281 Page 1 of 2
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| DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER SYSTEM (CCS)
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| This change is designated as administrative because it does not result in technical changes to the CTS.
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| A06 CTS 4.7.2.c.2) requires verification that each CCW System pump starts automatically on a SI test signal. CTS 4.7.2.c.3) requires verification that the interlocks required for CCW OPERABILITY are OPERABLE. ITS SR 3.7.7.3 requires verification that each CCW pump starts automatically on an actual or simulated actuation signal. This changes the CTS by removing the duplicative requirement to verify that the interlocks required for OPERABILITY are OPERABLE, aligning those interlocks to the requirement to verify the CCW pumps start automatically on a SI test signal.
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| The purpose of CTS 4.7.2.c.3) is to verify the interlocks required for system OPERABILITY are OPERABLE. The associated interlock is the starting of the C CCW pump automatic start on an SI test signal when either CCW pump A or B breaker is racked out and the C CCW pump power supply is aligned to the racked out pump's power supply. The C CCW pump is interlocked with the A and B CCW pump such that the C CCW pump can only start automatically on an SI signal when aligned to replace either the A or B CCW pump. Because both of the CTS surveillances are associated with the automatic starting of the CCW pumps on an SI signal, the duplicative surveillance is being deleted. This change is acceptable because the test requirements and frequency regarding the CCW pumps remain the same. This change is designated as administrative because it does not result in technical changes to the CTS.
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| MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS CTS 3.7.2, Action b, states that with only one CCW pump None OPERABLE or with two CCW pumps OPERABLE, but not from independent power supplies, restore two pumps from REMOVED DETAIL CHANGES independent power supplies to OPERABLE status.
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| LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.2 requires the Component Cooling Water System (CCW) to be OPERABLE with: a. Three CCW pumps, and b. Two CCW heat exchangers (Changed to two CCW pumps by DOC L01). ITS LCO 3.7.7 requires two CCW trains to be OPERABLE but does not define the components and the associated flow path that comprise an OPERABLE CCW train. This changes the CTS by moving the description of the CCW trains to the Bases. , independence, The removal of these details which are related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS still retains the requirement for both CCW trains to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are Turkey Point Unit 3 and Unit 4 Page 3 of 7
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| 6/22/22, 5:56 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1271 NRC Question JMW020 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/22/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/22/2022 11:40 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1271 1/1
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| 5/19/22, 4:34 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 487 NRC Question JMW021 Number Category Technical ITS 3.7 Section ITS 3.7.8 Number DOC A-5 Number JFD Number JFD Bases Number Page 198, 214 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC A05 removes CTS SR 4.7.3.b.2, however the bases do not include a description of this SR being included in Question another SR. Include in the Bases for SR 3.7.8.3 that the interlocks are tested during this SR (Similar to statement in Insert 7 from ITS SR 3.7.7.3 Bases Testing the automatic starting of the swing CCW pump includes testing this interlock). Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 1:55 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=487 1/1
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| 8/14/22, 9:30 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 895 NRC Question JMW021 Number Select Licensee Response Application Attachment Attachment 1 - JMW021 LAR Markups.pdf (627KB) 1 Attachment 2
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| Response FPL will revise the ITS Surveillance Requirement (SR) 3.7.8.3 Bases markup to include a statement Statement associated with the Intake Cooling Water (ICW) pump interlocks, similar to that included in the ITS SR 3.7.7.3 Bases. See attached JMW021 license amendment request (LAR) markup.
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| ===Response===
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| 6/7/2022 12:40 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/7/2022 11:38 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=895 1/1
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| ICW System SWS 1 B 3.7.8 BASES SURVEILLANCE REQUIREMENTS (continued)
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| SR 3.7.8.3 This SR verifies proper automatic operation of the SWS pumps on an ICW System 1 actual or simulated actuation signal. The SWS is a normally operating system that cannot be fully actuated as part of normal testing during power normal operation. [ The [18] month Frequency is based on the need to The ICW swing pump (C perform this Surveillance under the conditions that apply during a unit pump) is interlocked to prevent starting if ICW pumps A and B outage and the potential for an unplanned transient if the Surveillance are aligned for starting. For a were performed with the reactor at power. Operating experience has start signal to initiate starting shown that these components usually pass the Surveillance when 2 the swing pump on a LOOP or performed at the [18] month Frequency. Therefore, the Frequency is SI signal, the supply breaker for the ICW pump, associated acceptable from a reliability standpoint.
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| with the AC electrical power distribution train to which it is OR aligned, must be open and racked out. Testing the automatic starting of the swing The Surveillance Frequency is controlled under the Surveillance ICW pump includes testing this Frequency Control Program.
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| interlock.
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| U
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| | |
| ==9.6 REFERENCES==
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| : 1. FSAR, Section [9.2.1]. 1 2 Chapter 6.0 U
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| : 2. FSAR, Section [6.2]. 1 2 U 9.3
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| : 3. FSAR, Section [5.4.7]. 1 2
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| : 4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.
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| Westinghouse STS B 3.7.8-5 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 6/9/22, 12:38 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 999 NRC Question JMW021 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:42 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=999 1/1
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| 5/19/22, 4:35 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 491 NRC Question JMW022 Number Category Editorial ITS Section 3.7 ITS 3.7.8 Number DOC L-1 Number JFD Number JFD Bases Number Page 204 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC In the markup for ITS 3.7.8 Condition B, DOC L01 is referenced in the left margin, but does not appear Question related to this change. Confirm that this should not be L02. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 1:57 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=491 1/1
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| 8/14/22, 9:30 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 815 NRC Question JMW022 Number Select Licensee Response Application Attachment Attachment 1 - JMW022 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response FPL will revise the markup for ITS 3.7.8, Condition B, to reference Discussion of Change (DOC) L02 in lieu Statement of DOC L01. See attached JMW022 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW022 LAR Markups
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| | |
| ===Response===
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| 6/5/2022 6:55 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/5/2022 5:57 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=815 1/1
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| ICW System CTS SWS 1 3.7.8 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME Action b, Action c B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A not AND 4 met.
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| B.2 --------------NOTE--------------
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| LCO 3.0.4.a is not applicable when entering DOC L02 MODE 4.
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| DOC L01 -------------------------------------
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| Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.3.a SR 3.7.8.1 -------------------------------NOTE------------------------------
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| ICW Isolation of SWS flow to individual components does 1 not render the SWS inoperable.
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| ICW Verify each SWS manual, power operated, and [ 31 days 1 automatic valve in the flow path servicing safety 3 related equipment, that is not locked, sealed, or OR otherwise secured in position, is in the correct position. In accordance with the Surveillance Frequency Control Program ] 3 Westinghouse STS 3.7.8-2 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY
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| 6/9/22, 12:39 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1003 NRC Question JMW022 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:43 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1003 1/1
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| 5/19/22, 4:36 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 495 NRC Question JMW023 Number Category Editorial ITS 3.7 Section ITS 3.7.9 Number DOC A-2 Number JFD Number JFD Bases Number Page 221 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.7.9 A02 - states in part ITS 3.7.9 Condition B, (be in MODE 3 in 6 hours) is modified Question by a Note that states "Condition B only applies to one Unit during a dual Unit shutdown." ITS 3.7.9 Condition C (be in MODE 3 in 12 hours) is modified by two Notes: 1) "Condition C only applies when a dual Unit shutdown is required", and 2) "Only one Unit can enter Condition C."
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| The ITS condition B note states Not applicable when a dual unit shutdown is required. Condition C is modified by only one note that states Only applicable when a dual unit shutdown is required. Correct A02 with the appropriate notes.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:00 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=495 1/1
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| 8/14/22, 9:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 507 NRC Question JMW023 Number Select Licensee Response Application Attachment Attachment 1 - JMW023 LAR Markups.pdf (664KB) 1 Attachment 2
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| Response FPL will revise ITS 3.7.9, Discussion of Change (DOC) A02, to state the Notes as worded in the proposed Statement ITS 3.7.9 markup. See attached JMW023 license amendment request (LAR), Revision 1, markup.
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| Attachment
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| : 1. JMW023 LAR Markups
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| | |
| ===Response===
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| 5/30/2022 2:05 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:05 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=507 1/1
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| DISCUSSION OF CHANGES ITS 3.7.9, ULTIMATE HEAT SINK (UHS)
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| ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable, because they do not result in technical changes to the CTS.
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| A02 The CTS 3.7.4 ACTION, states, in part, with the requirements of the above specification (UHS temperature limitation) not satisfied to be in at least HOT STANDBY within Not applicable when a 12 hours and in COLD SHUTDOWN within the following 30 hours. The CTS 3.7.4 dual unit shutdown is required a Note that states "Only further states that This ACTION shall be applicable to both units simultaneously. In applicable when a dual addition, CTS Bases states that that when an ACTION statement requires a dual unit unit shutdown is required.
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| shutdown, the time to be in HOT STANDBY is 12 hours. This is to allow the orderly shutdown of one unit at a time and NOT jeopardize the stability of the electrical grid by imposing a dual unit shutdown. ITS 3.7.9 Condition B, (be in MODE 3 in 6 hours) is modified by a Note that states "Condition B only applies to one Unit during a dual Unit shutdown." ITS 3.7.9 Condition C (be in MODE 3 in 12 hours) is modified by two Notes:
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| : 1) "Condition C only applies when a dual Unit shutdown is required", and 2) "Only one Unit can enter Condition C." This modifies the CTS to clarify what Completion Times should be followed for an inoperable UHS.
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| The purpose of the CTS 3.7.4 ACTION is to ensure prompt Action is taken to restore the inoperable UHS or shutdown the unit when the UHS cannot be restored to an OPERABLE status within the specified Completion Times. The UHS temperature requirements ensure that sufficient cooling capacity is available either: (1) To provide normal cooldown of the facility, or (2) To mitigate the effects of accident conditions within acceptable limits. The Notes described above conservatively allow only one unit in a dual unit shutdown event to apply the 12-hour Completion Time to reach MODE 3. This change is intended to provide clarity with respect to the different CTS Completion Times which depend on the UHS. Because the new Notes clarify that only one unit can apply the 12-hours to be in MODE 3 consistent with the CTS ACTION as discussed in the CTS Bases, this change is considered Administrative as no technical changes are being made to the CTS.
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| A03 CTS 3.7.4 Action states, in part, that this Action shall be applicable to both units simultaneously. ITS 3.7.9 does not include this statement. This changes the CTS by removing duplicative information.
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| The purpose of the CTS Action statement is to ensure application of this Action to both units. CTS 3.0.5 (ITS 3.0.10) states that Limiting Conditions for Operation (LCOs) including the associated ACTION requirements shall apply to each unit individually unless otherwise indicated as follows: a. whenever the Limiting Conditions for Operation refers to systems or components which are shared by both units, the ACTION requirements will apply to both units simultaneously; b. whenever the Limiting Conditions for Operation applies to only one unit, this will be identified in the APPLICABILITY section of the specification; and c. whenever certain portions of a specification contain Turkey Point Unit 3 and Unit 4 Page 1 of 3
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| 6/13/22, 1:54 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1139 NRC Question JMW023 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/13/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/13/2022 12:31 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1139 1/1
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| 5/19/22, 4:38 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 499 NRC Question Number JMW024 Category Editorial ITS Section 3.7 ITS Number 3.7.9 DOC Number JFD Number JFD Bases Number Page Number(s) 226 NRC Reviewer Supervisor Victor Cusumano Technical Branch POC Add Name Conf Call Requested N NRC Question In ITS 3.7.9 - The OR in Condition B should be underlined.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:01 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=499 1/1
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| 8/14/22, 9:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 511 NRC Question JMW024 Number Select Licensee Response Application Attachment Attachment 1 - JMW024 LAR Markups.pdf (149KB) 1 Attachment 2
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| Response FPL will revise the "OR" logical connector in the ITS 3.7.9, Condition B, markup with an underline. See Statement attached JMW024 license amendment request (LAR), Revision 1, markup.
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| Attachment
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| : 1. JMW024 LAR Markups
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| | |
| ===Response===
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| 5/30/2022 2:10 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 5/30/2022 1:07 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=511 1/1
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| CTS UHS 3.7.9 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME B INSERT 1 B C. [ Required Action C.1 Be in MODE 3. 6 hours 3 1 5 and associated Completion Time of AND 7
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| Condition A or B not B 3
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| met. C.2 --------------NOTE--------------
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| LCO 3.0.4.a is not OR ] applicable when entering 1 MODE 4.
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| UHS inoperable [for ------------------------------------- 1 reasons other than Condition A or B] . Be in MODE 4. 12 hours 5 INSERT 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 [. t o [562] ft [mean sea [ [24] hours level] .
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| OR In accordance 1 with the Surveillance Frequency Control Program ] ]
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| 1 SR 3.7.9.2 [ Verify average water temperature of UHS is [ 24 hours 6
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| [90] °F. 1 104 OR In accordance with the Surveillance Frequency Control Program ] ] 1 Westinghouse STS 3.7.9-2 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY
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| 6/9/22, 12:40 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1007 NRC Question JMW024 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:44 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1007 1/1
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| 5/19/22, 4:40 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 503 NRC Question Number JMW025 Category Editorial ITS Section 3.7 ITS Number 3.7.9 DOC Number JFD Number JFD Bases Number Page Number(s) 227 NRC Reviewer Supervisor Victor Cusumano Technical Branch POC Add Name Conf Call Requested N NRC Question In ITS 3.7.9 - The OR in INSERT 2 for Condition C should be underlined.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:02 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=503 1/1
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| 8/14/22, 9:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 515 NRC Question JMW025 Number Select Licensee Response Application Attachment Attachment 1 - JMW025 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response FPL will revise the "OR" logical connector in ITS 3.7.9, Insert 2, Condition C, with an underline. See Statement attached JMW025 LAR markup. Note that "applicable" is misspelled in Insert 1 and in the Condition Note of Insert 2 of the ITS 3.7.9 markup; this is also corrected in the attached JMW025 license amendment request (LAR), Revision 1, markup.
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| Attachment
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| : 1. JMW025 LAR Markups
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| | |
| ===Response===
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| 5/30/2022 2:10 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:09 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=515 1/1
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| 1 INSERT 1 applicable
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| ----------------NOTE-------------
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| Action Not appliable when a dual unit shutdown is required.
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| 1 INSERT 2 CONDITION REQUIRED ACTION COMPLETION TIME Action C. ------------NOTE----------- C.1 Be in MODE 3. 12 hours Only appliable when a dual unit shutdown is AND required.
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| -------------------------------- C.2 --------------NOTE--------------
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| Required Action LCO 3.0.4.a is not and associated applicable when entering DOC L01 Completion Time not MODE 4.
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| met. -------------------------------------
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| OR Be in MODE 4. 18 hours UHS inoperable for reasons other than Condition A.
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| Insert Page 3.7.9-2
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| 6/9/22, 12:40 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1011 NRC Question JMW025 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:45 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1011 1/1
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| 5/19/22, 4:41 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 507 NRC Question JMW026 Number Category Editorial ITS Section 3.7 ITS Number 3.7.10 DOC A-2 Number JFD Number JFD Bases Number Page 246 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC The CTS 3.7.5 markup for the LCO indicates that A02 is applicable, however A02 does not describe this Question change, as A02 referring to ITS ACTION F. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:04 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=507 1/1
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| 8/3/22, 5:34 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 899 NRC Question JMW026 Number Select Licensee Response Application Attachment Attachment 1 - JMW026 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response CTS 3.7.5 provides both control room emergency filtration (recirculation) and control room cooling Statement requirements in one Specification. ITS separates the requirements based on safety function. ITS 3.7.10 contains the requirements for the emergency filtration function while ITS 3.7.11 contains the requirements for the control room cooling function. ITS 3.7.10, Discussion of Change (DOC) A02, will be replaced with a new DOC A02 similar to ITS 3.7.11, DOC A02, to describe this change. In addition, ITS 3.7.11, DOC A02, will be revised to more concisely describe that the ITS separates the CTS requirements based on safety function. Current DOC A02 will be revised and renumbered as DOC A04 to accurately reflect ITS 3.7.10, ACTION I, instead of ACTION F. Reference to DOC A02 on CTS Page 3/4 7-20 will be changed to DOC A04. In addition, the CTS reference associated with Insert 3 of the ITS 3.7.10 markup will be revised to reference DOC A04. See attached JMW026 license amendment request (LAR) markup.
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| Attachment
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| : 1. JMW026 LAR Markups
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| ===Response===
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| 6/7/2022 12:40 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/7/2022 11:41 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=899 1/1
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| ITS A01 ITS 3.7.10 PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued)
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| ACTION C b. With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary during MODES 1, 2, 3 or 4, immediately initiate action to implement mitigating actions.
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| Within 24 hours, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits, and CRE occupants are protected from smok e hazards, and restore CRE boundary to OPERABLE status within 90 days.
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| ACTION D& Condition Note With the above requirements not met, be in at least HOT STANDBY within the next 6 hours for L01 ACTION E & Condition Note one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| MODE 4 6 A03 With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE ACTION J boundary during MODES 5, 6 or during the movement of irradiated fuel assemblies, immediately suspend all movement of irradiated fuel.
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| A04 Add proposed ACTION I A02 SURVEILLANCE REQUIREMENTS 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:
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| See ITS a. In accordance with the Surveillance Frequency Control Program by verifying that the control room 3.7.11 air temperature is less than or equal to 120 F;
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| : b. In accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at SR 3.7.10.1 least 15 minutes**;
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| : c. In accordance with the Surveillance Frequency Control Program or (1) after 720 hours of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, See ITS or (3) following exposure of the filters to effluents from painting, fire, or chemical release in any 5.5.8 ventilation zone communicating with the system that may have an adverse effect on the functional SR 3.7.10.2 capability of the system, or (4) after complete or partial replacement of a filter bank by:
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| **As the mitigation actions of TS 3.7.5 Action a.5 include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room and TS LA02 4.7.5.c, d and f.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-20 AMENDMENT NOS. 275 AND 270 Page 3 of 4
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| ITS 3.7.10 CTS INSERT 2 3 E. ------------NOTES----------- E.1 Be in MODE 3. 12 hours Only applicable when a dual unit shutdown is AND required.
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| ACTIONs a.1, a.3, -------------------------------- E.2 -------------NOTE----------------
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| a.4, a.6, a.7, & b Required Action and LCO 3.0.4.a is not associated Completion applicable when entering Time of Condition A, B, MODE 4.
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| or C not met. -------------------------------------
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| Be in MODE 4. 18 hours 1
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| INSERT 3 G. Two CREV trains G.1 Place one CREVS train in Immediately DOC M01 inoperable due to normal recirculation mode.
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| outside air intake isolated.
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| H. Two CREVS trains H.1 Place compensatory 24 hours ACTION a.5 inoperable in MODE 1, filtration unit in service.
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| 2, 3, or 4 for reasons other than Condition C or G.
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| DOC A02 I. Two or more control I.1 Enter LCO 3.0.3. Immediately room AHUs inoperable A04 in MODE 1, 2, 3, or 4.
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| OR Required Action and associated Completion Time of Condition G or H not met.
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| Insert Page 3.7.10-2
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| The purpose of CTS 3.7.5 is to provide CTS 3.7.5 requires control room the Control Room emergency filtration Emergency DISCUSSION OF CHANGES (recirculation) and Ventilation System ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) control room cooling (CREVS) to be requirements and OPERABLE and includes heating, explicitly lists the ventilation, and air components ADMINISTRATIVE CHANGES conditioning (HVAC) required to meet the units. Each HVAC Limiting Condition unit consists of a for Operation A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current condenser cooling (LCO). ITS LCO Technical Specifications (CTS) to the plant specific Improved Technical unit and an AHU.
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| 3.7.10 requires two Specifications (ITS), certain changes (wording preferences, editorial changes, ITS separates the CREVS trains and reformatting, revised numbering, etc.) are made to obtain consistency with requirements based three control room on safety function.
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| air handling units NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse ITS 3.7.10 contains (AHUs) to be Plants" (ISTS). the requirements for OPERABLE. ITS the emergency LCO 3.7.11 requires filtration function two Control Room These changes are designated as administrative changes and are acceptable while ITS 3.7.11 Emergency Air because they do not result in technical changes to the CTS. contains the Temperature requirements for the Control System control room cooling (CREATCS) trains A02 ISTS 3.7.10, ACTION F, requires entry into Limiting Condition for Operation function. Since the to be OPERABLE. (LCO) 3.0.3 when both Control Room Emergency Ventilation System (CREVS) AHUs support both This changes the trains are inoperable for reasons other than an inoperable Control Room the filtration function CTS by providing and the cooling separate Envelope (CRE) boundary in Modes 1, 2, 3, or 4. CTS 3.7.5, ACTION a.5, function, the AHUs Specifications for requires the compensatory filtration unit to be placed in service under these are required to the CREVS and the conditions, but does not include an Action if the compensatory filtration unit is not support CREATCS. OPERABILITY of capable of being placed in service. In addition, CTS 3.7.5 does not contain an CREVS and Action associated with two or more Air Filtration Units being inoperable. Either of CREATCS.
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| these conditions would require entry into LCO 3.0.3. This changes the CTS by Additionally, ITS adding Action (ITS ACTION H) requiring entry into LCO 3.0.3 when either of LCO 3.7.10 requires two CREVS trains these conditions exist. and three control room AHUs to be When the compensatory filtration unit cannot be placed in service when both OPERABLE with the details of the CREVS trains are inoperable for reasons other than an inoperable CRE components required boundary, or with two or more AHUs inoperable, the CREVS can no longer for a CREVS train to provide its specified safety function. Because the CTS does not contain an be OPERABLE, which includes the Action associated with these conditions, entry into LCO 3.0.3 would be required control room envelop by default; therefore, the adoption of ITS 3.7.10, ACTION H, simply provides and the common clarity for the operators. This change is designated as an administrative change CREVS filter train, described in the ITS and is acceptable because the change does not result in technical changes to 3.7.10 Bases (refer the CTS. to ITS 3.7.10, DOC LA01).
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| A03 The CTS 3.7.5, ACTION b, states, in part, that with the above requirements This change (CREVS Actions) not satisfied to be in at least HOT STANDBY within the next represents a change 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within in presentation of the existing the following 30 hours. In addition, CTS Bases states that that when an ACTION requirements and is statement requires a dual unit shutdown, the time to be in HOT STANDBY is designated as 12 hours. This is to allow the orderly shutdown of one unit at a time without administrative because no technical jeopardizing the stability of the electrical grid by imposing a simultaneous dual changes are being unit shutdown. ITS 3.7.10, Condition D (be in MODE 3 in 6 hours), is modified by made to the CTS.
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| a Note that states that Condition D is not applicable when a dual unit shutdown is required. Proposed ITS 3.7.10, Condition E (be in MODE 3 in 12 hours), is added and modified by a Note stating that Condition E is only applicable when a dual unit shutdown is required. This modifies the CTS to clarify what Completion Times should be followed when requirements are not met.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 7
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| A04 CTS 3.7.5, Action a.5, requires, in part, immediately initiating action to DISCUSSION OF CHANGES place the compensatory ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) filtration unit in service and verifying proper operation within 24 hours but The purpose of the CTS 3.7.4, ACTION b, is to ensure prompt Action is taken to does not include an restore the CREVS to an OPERABLE status within the specified Completion action if the Times. The Notes described above conservatively allow only one unit in a dual compensatory filtration unit is not unit shutdown event to apply the 12-hour Completion Time to reach MODE 3.
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| capable of being This change is intended to provide clarity with respect to the different CTS placed in service. In Completion Times which depend on the CREVS. The described Notes and addition, CTS 3.7.5 does not contain an addition of proposed Condition E is consistent with the CTS in that the 12-hour action associated Completion Time is only applicable during dual unit shutdown conditions. This with two or more change is considered Administrative as no technical changes are being made to inoperable control room AHUs. ITS the CTS.
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| 3.7.10, ACTION I, requires entry into LCO 3.0.3 when the Required Action and MORE RESTRICTIVE CHANGES associated Completion Time of M01 CTS 3.7.5 Action a.4, one recirculation damper inoperable and a.6, an inoperable Condition H cannot be met (i.e.,
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| damper in the normal outside air intake require, in part, to place the CREVS in compensatory filter the recirculation mode. ITS 3.7.10 ACTION G requires that with two CREVS cannot be placed and trains inoperable due to normal outside air intake isolated to immediately place verified in service one CREVS train in the recirculation mode. This changes the CTS by replacing within 24 hours) and when two or more specific action requirements associated with an inoperable recirculation or intake control room AHUs damper in the CREVS with a requirement to place the CREVS in the recirculation are inoperable in mode if both CREVS trains are inoperable due to normal outside air intake MODE 1, 2, 3, or 4.
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| This changes the isolated.
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| CTS by adding an explicit Action The purpose of the CTS actions is to ensure the control room envelop boundary requiring entry into LCO 3.0.3 when and filtration function are maintained when redundant isolation or actuation either of the capability is lost on the CREVS. The CREVS design includes dual dampers on conditions described the normal intake, the emergency intake, and the recirculation ducting to ensure herein exist. When CTS 3.7.5 Action a.5 these penetrations are isolated and proper actuation in the event of an accident cannot be met in requiring control room habitability. The required dampers are powered and MODES 1, 2, 3, or 4 actuated from redundant trains. When one required damper in the normal air or with two or more control room AHUs intake duct is closed both intake radiation monitors are isolated unable to detect inoperable in MODES an increase in external radiation levels, potentially preventing CREVS actuation 1, 2, 3, or 4, entry when needed. An appropriate action for this level of degradation is to declare into CTS 3.0.3 would be required because both CREVS intake radiation monitors inoperable causing the CREVS to be there are no actions placed in the recirculation mode in accordance with LCO 3.3.4, "Control Room associated with these Emergency Ventilation System (CREVS) Actuation Instrumentation." This conditions.
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| Therefore, the change is acceptable because actions retained in the ITS continue to ensure adoption of ITS redundant capability is restored or the safety related function is performed.
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| 3.7.10, ACTION I, These remedial actions are consistent with safe operation under the specified provides clarity for Condition, considering the OPERABLE status of the redundant dampers and the when entry into LCO 3.0.3 is required. low probability of a DBA occurring during this condition. This change is This change is designated as more restrictive because the CREVS will be placed in the designated as an recirculation mode sooner in ITS (immediately) than in CTS (7 days).
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| administrative change and is acceptable because the change does not RELOCATED SPECIFICATIONS result in technical changes to the CTS.
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| None Turkey Point Unit 3 and Unit 4 Page 2 of 7
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| The purpose of CTS 3.7.5 is to provide control room emergency filtration (recirculation) and DISCUSSION OF CHANGES control room ITS 3.7.11, CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL cooling SYSTEM (CREATCS) requirements and includes heating, ventilation, and air conditioning ADMINISTRATIVE CHANGES (HVAC) units.
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| Each HVAC unit consists of a A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current condenser cooling Technical Specifications (CTS) to the plant specific Improved Technical unit and an AHU. Specifications (ITS), certain changes (wording preferences, editorial changes, ITS separates the requirements reformatting, revised numbering, etc.) are made to obtain consistency with based on safety NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse function. ITS Plants" (ISTS).
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| 3.7.10 contains the requirements for the emergency These changes are designated as administrative changes and are acceptable filtration function because they do not result in technical changes to the CTS.
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| while ITS 3.7.11 contains the requirements for A02 CTS 3.7.5 requires, in part, that the Control Room Emergency Ventilation System the control room shall be OPERABLE* with: a. Three air handling units, and b. Two condensing cooling function.
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| Since the AHUs units. ITS Limiting Condition for Operation (LCO) 3.7.11 states that two Control support both the Room Emergency Air Temperature Control System (CREATCS) trains shall be filtration function OPERABLE. This changes the CTS by providing a separate LCO for the and the cooling function, the AHUs CREATCS.
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| are required to support CTS 3.7.5 includes requirements for both the Control Room Emergency OPERABILITY of CREVS and Ventilation System (CREVS) and for the CREATCS. ITS 3.7.10 contains the CREATCS. ITS requirements for the CREVS while ITS 3.7.11 contains the requirements for the LCO 3.7.11 CREATCS. CTS 3.7.5 requires two condensing units to be OPERABLE for requires two of control room temperature and humidity control; this requirement is retained in three CREATCS trains (i.e., HVAC ITS 3.7.11. All other components listed in CTS 3.7.5 will be governed by units), with each ITS 3.7.10, CREVS. This change is designated as Administrative because no CREATCS train technical changes are being made to the CTS.
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| consisting of a condenser cooling unit and an AHU, A03 CTS 3.7.5 does not provide any actions to take if two CREATCS trains are to be OPERABLE inoperable. ITS 3.7.11, Condition E and Required Action E.1, provide Action for for control room temperature and two inoperable CREATCS trains when in MODES 5 or 6, or during the movement humidity control. of irradiated fuel assemblies. ITS 3.7.11, Condition F and Required Action F.1, As such, two provide Action for two inoperable CREATCS trains when in MODES 1, 2, 3, or 4.
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| condensing units and two AHUs are This changes the CTS by explicitly providing action to be taken when two required to meet CREATCS trains are inoperable.
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| ITS LCO 3.7.11.
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| Other components listed in CTS 3.7.5, CTS 3.7.5 does not provide any actions to be taken if two CREATCS trains are including the inoperable. CTS 3.0.3 states (applicable in MODES 1, 2, 3, or 4), in part, that requirement to when an LCO is not met, except as provided in the associated ACTION maintain three AHUs OPERABLE requirements, within 1 hour action shall be initiated to place the unit, as for the control applicable, in the listed conditions within the specified times. ITS 3.7.11, room emergency Condition F states that if two CREATCS trains are inoperable to immediately filtration function, enter LCO 3.0.3 (also applicable in MODES 1, 2, 3, or 4), providing similar are retained in ITS 3.7.10, CREVS. direction and in CTS. ITS 3.7.11, Condition E, requires the suspension of the This change movement of irradiated fuel assemblies when operating in MODES 5 or 6, or represents a during the movement of irradiated fuel assemblies. This Action is the same as change in presentation of the CTS 3.7.5, ACTION a.2, for one inoperable CREATCS train. Therefore, the existing requirements and is designated as administrative because no Turkey Point Unit 3 and Unit 4 Page 1 of 4 technical changes are being made to the CTS.
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| 7/25/22, 2:57 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1650 NRC Question JMW026 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/25/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/25/2022 1:56 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1650 1/1
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| 5/19/22, 4:42 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 511 NRC Question JMW027 Number Category Technical ITS 3.7 Section ITS 3.7.10 Number DOC Number JFD Number JFD Bases Number Page 246 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC The change in the CTS LCO from the Control Room Emergency Ventilation System shall be OPERABLE to Question Two CREVS trains does not appear to have a DOC (See ITS 3.7.11 DOC A02 for reference ). Provide a justification for this change.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:05 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=511 1/1
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| 8/11/22, 10:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1307 NRC Question JMW027 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response CREVS components and share a common filter unit. In addition, separate air handling units (AHUs) support Statement control room air flow during the CREVS emergency recirculation mode of operation. As such, ITS LCO 3.7.10 requires, in part, two CREVS trains to be OPERABLE. The details of what is required for a CREVS train to be OPERABLE are described in the ITS 3.7.10 Bases. ITS 3.7.10 Bases state that each CREVS train is considered OPERABLE when the individual components necessary to limit control room envelop occupant exposure are OPERABLE, which includes the common high efficiency particulate air (HEPA) filter and charcoal adsorber unit.
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| ITS 3.7.10, Discussion of Change (DOC) A02, has been revised in response to NRC request for additional information (RAI) JMW026 and describes the change from "the Control Room Emergency Ventilation System shall be OPERABLE" to "Two CREVS trains shall be OPERABLE," as a presentation change of the existing requirements and does not result in technical changes to the CTS. Please refer to FPL Response and associated attachment to RAI JMW026.
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| ===Response===
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| 6/28/2022 10:15 AM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/28/2022 9:16 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1307 1/1
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| 7/1/22, 10:52 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1335 NRC Question JMW027 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/29/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/29/2022 10:50 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1335 1/1
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| 5/19/22, 4:44 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 515 NRC Question JMW028 Number Category Editorial ITS Section 3.7 ITS Number 3.7.10 DOC Number A-2 JFD Number JFD Bases Number Page Number(s) 250 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Question DOC A02 references ACTION H in 2 places, however ACTION H does not seem applicable to this change. Verify the correct ACTION is referenced.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:07 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=515 1/1
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| 8/14/22, 9:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 519 NRC Question JMW028 Number Select Licensee Response Application Attachment Attachment 1 - JMW028 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response FPL will revise the two references to ACTION H to correctly reference ACTION I in ITS 3.7.10, Discussion of Statement Change (DOC) A02. ACTION I addresses the conditions where entry into Limiting Condition for Operation (LCO) 3.0.3 would be necessary which is the subject of DOC A02. See attached JMW028 license amendment request (LAR), Revision 1, markups.
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| ==Attachment:==
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| : 1. JMW028 LAR Markups
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| ===Response===
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| 5/30/2022 2:15 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:13 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=519 1/1
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| DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
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| ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS).
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 ISTS 3.7.10, ACTION F, requires entry into Limiting Condition for Operation (LCO) 3.0.3 when both Control Room Emergency Ventilation System (CREVS) trains are inoperable for reasons other than an inoperable Control Room Envelope (CRE) boundary in Modes 1, 2, 3, or 4. CTS 3.7.5, ACTION a.5, requires the compensatory filtration unit to be placed in service under these conditions, but does not include an Action if the compensatory filtration unit is not capable of being placed in service. In addition, CTS 3.7.5 does not contain an Action associated with two or more Air Filtration Units being inoperable. Either of these conditions would require entry into LCO 3.0.3. This changes the CTS by adding Action (ITS ACTION H) requiring entry into LCO 3.0.3 when either of these conditions exist.
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| ACTION I When the compensatory filtration unit cannot be placed in service when both CREVS trains are inoperable for reasons other than an inoperable CRE boundary, or with two or more AHUs inoperable, the CREVS can no longer provide its specified safety function. Because the CTS does not contain an Action associated with these conditions, entry into LCO 3.0.3 would be required by default; therefore, the adoption of ITS 3.7.10, ACTION H, simply provides clarity for the operators. This change is designated as an administrative change and is acceptable because the change does not result in technical changes to the CTS.
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| A03 The CTS 3.7.5, ACTION b, states, in part, that with the above requirements (CREVS Actions) not satisfied to be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours. In addition, CTS Bases states that that when an ACTION statement requires a dual unit shutdown, the time to be in HOT STANDBY is 12 hours. This is to allow the orderly shutdown of one unit at a time without jeopardizing the stability of the electrical grid by imposing a simultaneous dual unit shutdown. ITS 3.7.10, Condition D (be in MODE 3 in 6 hours), is modified by a Note that states that Condition D is not applicable when a dual unit shutdown is required. Proposed ITS 3.7.10, Condition E (be in MODE 3 in 12 hours), is added and modified by a Note stating that Condition E is only applicable when a dual unit shutdown is required. This modifies the CTS to clarify what Completion Times should be followed when requirements are not met.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 7
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| 6/9/22, 12:41 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1015 NRC Question JMW028 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:48 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1015 1/1
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| 5/19/22, 4:46 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 519 NRC Question JMW029 Number Category Editorial ITS 3.7 Section ITS 3.7.10 Number DOC A-2 Number JFD Number JFD Bases Number Page 250 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC DOC A02 states in part CTS 3.7.5 does not contain an Action associated with two or more Air Filtration Question Units being inoperable. Verify that Air Filtration Units is the correct term to be used here as it is inconsistent with the rest of the subsection.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:08 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=519 1/1
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| 8/14/22, 9:33 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 523 NRC Question JMW029 Number Select Licensee Response Application Attachment Attachment 1 - JMW029 LAR Markups.pdf (661KB) 1 Attachment 2
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| Response FPL will revise the reference to "Air Filtration Units" in ITS 3.7.10, Discussion of Change (DOC) A02, to Statement refer to "Air Handling Units" (or AHUs), consistent with the component title used in CTS 3.7.5 and ITS 3.7.10. See attached JMW029 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW029 LAR Markups
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| ===Response===
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| 5/30/2022 2:15 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:15 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=523 1/1
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| DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
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| ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS).
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 ISTS 3.7.10, ACTION F, requires entry into Limiting Condition for Operation (LCO) 3.0.3 when both Control Room Emergency Ventilation System (CREVS) trains are inoperable for reasons other than an inoperable Control Room Envelope (CRE) boundary in Modes 1, 2, 3, or 4. CTS 3.7.5, ACTION a.5, requires the compensatory filtration unit to be placed in service under these conditions, but does not include an Action if the compensatory filtration unit is not capable of being placed in service. In addition, CTS 3.7.5 does not contain an Action associated with two or more Air Filtration Units being inoperable. Either of these conditions would require entry into LCO 3.0.3. This changes the CTS by adding Action (ITS ACTION H) requiring entry into LCO 3.0.3 when either of these conditions exist. Air Handling Units (AHUs)
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| When the compensatory filtration unit cannot be placed in service when both CREVS trains are inoperable for reasons other than an inoperable CRE boundary, or with two or more AHUs inoperable, the CREVS can no longer provide its specified safety function. Because the CTS does not contain an Action associated with these conditions, entry into LCO 3.0.3 would be required by default; therefore, the adoption of ITS 3.7.10, ACTION H, simply provides clarity for the operators. This change is designated as an administrative change and is acceptable because the change does not result in technical changes to the CTS.
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| A03 The CTS 3.7.5, ACTION b, states, in part, that with the above requirements (CREVS Actions) not satisfied to be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours. In addition, CTS Bases states that that when an ACTION statement requires a dual unit shutdown, the time to be in HOT STANDBY is 12 hours. This is to allow the orderly shutdown of one unit at a time without jeopardizing the stability of the electrical grid by imposing a simultaneous dual unit shutdown. ITS 3.7.10, Condition D (be in MODE 3 in 6 hours), is modified by a Note that states that Condition D is not applicable when a dual unit shutdown is required. Proposed ITS 3.7.10, Condition E (be in MODE 3 in 12 hours), is added and modified by a Note stating that Condition E is only applicable when a dual unit shutdown is required. This modifies the CTS to clarify what Completion Times should be followed when requirements are not met.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 7
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| 6/9/22, 12:42 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1019 NRC Question JMW029 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:49 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1019 1/1
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| 5/19/22, 4:51 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 523 NRC Question JMW030 Number Category Editorial ITS Section 3.7 ITS Number 3.7.10 DOC Number L-4 JFD Number JFD Bases Number Page 255 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question L04 states in part ITS SR 3.7.10.3 requires verification that each CREVS train actuates and additional states, except for dampers Please revise the typo additional to additionally.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:10 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=523 1/1
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| 8/14/22, 9:39 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 527 NRC Question JMW030 Number Select Licensee Response Application Attachment Attachment 1 - JMW030 LAR Markups.pdf (690KB) 1 Attachment 2
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| Response FPL will revise the term "additional" to "additionally", associated with ITS 3.7.10, Discussion of Change Statement (DOC) L04. See attached JMW030 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW030 LAR Markups
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| ===Response===
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| 5/30/2022 2:20 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:18 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=527 1/1
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| DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
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| The purpose of CTS SR is to ensure that each CREVS train actuates (switches to the recirculation mode) upon receipt of an actuation signal. This change is acceptable because it has been determined that the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its specified safety functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.
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| L04 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
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| CTS 4.7.5.e requires verification that on a containment isolation signal the system automatically isolates the control room and switches into a recirculation mode of operation. ITS SR 3.7.10.3 requires verification that each CREVS train actuates and additional states, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position. This changes the CTS by not requiring dampers and valves locked, sealed, or otherwise secured in position to be tested. additionally The purpose of the CTS SR is to provide assurance that the dampers and valves required to actuate in event of a DBA isolate the control room and shift the CREVS into the recirculation mode. This change is acceptable because it has been determined that the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform the specified safety functions. Dampers and valves secured in the actuated position are not required to be tested to automatically actuate because, in the event of a DBA, the components are already in the required position and secured to prevent changing from the required position. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.
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| L05 (Category 4 - Relaxation of Required Action) CTS 3.7.5 Action a.4, one recirculation damper inoperable; a.6 , an inoperable damper in the normal outside air intake; a.7, an inoperable damper in the emergency outside air intake provide actions when a required damper is inoperable. ITS 3.7.10 ACTIONS do not include specific actions for inoperable required dampers. This changes the CTS by removing specific action requirements associated with an inoperable damper in the CREVS.
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| The purpose of the CTS actions is to ensure the control room envelop boundary and filtration function are maintained when redundant isolation or actuation capability is lost on the CREVS. The CREVS design includes dual dampers on the normal intake, the emergency intake, and the recirculation ducting to ensure these penetrations are isolated and proper actuation in the event of accident requiring control room habitability. The required dampers are powered and actuated from redundant trains. Therefore, when one required damper in an air duct is inoperable, appropriate action for that level of degradation is to declare the CREVS train associated with the inoperable damper inoperable. Additionally, closing and de-activating either valve in the required safety function position ensures the safety function is performed and restores the LCO. CTS 4.7.5.e Turkey Point Unit 3 and Unit 4 Page 6 of 7
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| 6/9/22, 3:18 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1027 NRC Question JMW030 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:52 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1027 1/1
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| 5/20/22, 11:01 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 527 NRC Question JMW031 Number Category Editorial ITS Section 3.7 ITS Number 3.7.10 DOC Number JFD Number JFD Bases Number Page 259 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC ITS 3.7.10 Insert 1 (ITS Condition A) is listed as ACTION a.3 from CTS in the left margin. Verify that this Question is the correct reference, as it appears the correct reference should be CTS ACTION a.1.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:11 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=527 1/1
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| 8/14/22, 9:40 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 531 NRC Question JMW031 Number Select Licensee Response Application Attachment Attachment 1 - JMW031 LAR Markups.pdf (702KB) 1 Attachment 2
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| Response FPL will revise the reference to ACTION a.3 in ITS 3.7.10, Insert 1, to reference ACTION a.1. Insert 1 Statement contains remedial action when one Control Room Emergency Ventilation System (CREVS) air handling unit is inoperable, which is the condition addressed by CTS 3.7.5, ACTION a.1. CTS 3.7.5, ACTION a.1, states, in part, "With one air handling unit inoperable" See attached JMW031 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW031 LAR Markups
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| ===Response===
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| 5/30/2022 2:20 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:20 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=531 1/1
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| ITS 3.7.10 CTS INSERT 1 3 a.1 ACTION a.3 A. One control room AHU A.1 Restore control room AHU 7 days inoperable. to OPERABLE status.
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| Insert Page 3.7.10-1
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| 6/9/22, 3:18 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1031 NRC Question JMW031 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:53 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1031 1/1
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| 5/20/22, 11:01 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 531 NRC Question JMW032 Number Category Editorial ITS 3.7 Section ITS 3.7.10 Number DOC Number JFD Number JFD Bases Number Page 258, 267 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Insert 1 for the ITS 3.7.10 Bases states in part The AHUs and condensing units are part of the overall Question system but not included in the OPERABILITY requirements for CREVS. The LCO for ITS 3.7.10 states Three AHUs shall be operable Please evaluate this apparent inconsistency and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:13 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=531 1/1
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| 8/14/22, 9:40 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1111 NRC Question JMW032 Number Select Licensee Response Application Attachment Attachment 1 - JMW032 LAR Markups.pdf (759KB) 1 Attachment 2
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| Response FPL will revise Insert 1 of the ITS 3.7.10 Bases to remove the implication that the air handling units (AHUs)
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| Statement are not required for Control Room Emergency Ventilation System (CREVS) OPERABILITY and to add a clarifying statement that the AHUs also support the OPERABILITY requirements of ITS 3.7.11, "Control Room Emergency Air Temperature Control System (CREATCS)." For further clarity, reference to the air conditioning condensing units is removed from the CREVS ITS 3.7.10 Bases as these are governed by ITS 3.7.11.
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| This also necessitates a change to Insert 1 of the ITS 3.7.11 Bases to clarify that AHU OPERABILITY also supports the OPERABILITY requirements of ITS 3.7.10. These changes remain covered by Justification for Deviation (JFD) 1: Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| In addition, grammatical and editorial changes are made to Insert 1 of the 3.7.10 Bases, the Background section of ITS 3.7.11 Bases, and Insert 1 of the ITS 3.7.11 Bases. See attached JMW032 license amendment request (LAR), Revision 1, markup.
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| Attachment
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| : 1. JMW032 LAR Markup
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| ===Response===
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| 6/10/2022 1:00 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/10/2022 11:59 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1111 1/1
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| ITS 3.7.10 is a subsystem of the Control Building INSERT 1 1 Ventilation System and The CREVS consists of the following components:
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| : a. Air handling units (AHUs) ,
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| b
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| : b. Condensing (air conditioning (A/C)) units c
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| : c. Recirculation fans ,
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| d
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| : d. Recirculation dampers ,
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| e
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| : e. Recirculation filter unit ,
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| f
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| : f. Normal outside air intake dampers , and
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| : g. Emergency outside air intake dampers .
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| The AHUs and condensing units are part of the overall system but not included in the OPERABILITY requirements for CREVS. OPERABILITY of the cooling function of the AHUs and condensing units is covered in LCO 3.7.11, "Control Room Emergency Air Temperature The AHUs also support the OPERABILITY requirements of LCO 3.7.11, "Control Room Control System (CREATCS)." Emergency Air Temperature Control System (CREATCS)." Refer to LCO 3.7.11 for AHU requirements associated with CREATCS.
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| Units 3 and 4 share a common control room envelope (CRE). The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the units during normal and accident conditions. This area encompasses the main control room area, control room offices, rack area, kitchen, lavatory, and mechanical equipment room located below the control room which contains the CREVS equipment. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations, and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the radiological dose consequence analyses and that CRE occupants are protected from hazardous chemicals and smoke. The CRE and its boundary are defined in Control Room Envelope Habitability Program.
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| During normal operation, fresh makeup air is admitted to this system through an intake louver and two dampers in series located in the west wall of the control building. This system maintains a positive pressure in the CRE greater than that in the cable spreading room in order to prevent smoke from a hypothesized fire in the cable spreading room from entering the control room. All control room penetrations are designed for leak tightness. Since the control room is maintained at slightly more than atmospheric pressure, the infiltration of contaminated air into the control room is negligible.
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| Two radiation monitors located in the normal air intake ducting continuously monitor for radiation in the incoming air. In the unlikely event of a maximum hypothetical accident (MHA), the control room ventilation will automatically be placed in a recirculation mode.
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| INSERT Page B 3.7.10-1a
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| ITS 3.7.10 recirculation 1
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| INSERT 1 (continued)
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| The control room emergency mode is initiated by a containment Phase A signal, a high radiation signal from the containment air radiation monitors (R-11 and R-12), the manual initiation from a test switch, or a high radiation signal from the redundant monitors in the control room normal air intake. Following initiation, all exhaust fans shut off, and the redundant series exhaust isolation dampers close. Redundant normal air intake isolation dampers in series close. Redundant parallel emergency air intake dampers open. Likewise, the recirculation air path opens. A single air supply fan is energized to move the appropriate mixture of recirculation control room air and fresh outdoor air through the HEPA and charcoal filter system.
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| INSERT Page B 3.7.10-1b
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| CREATCS B 3.7.11 B 3.7 PLANT SYSTEMS B 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS)
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| BASES BACKGROUND The CREATCS provides temperature control for the control room following isolation of the control room.
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| three air conditioning units The CREATCS consists of two independent and redundant trains that provide cooling and heating of recirculated control room air. Each train INSERT 1 consists of heating coils, cooling coils, instrumentation, and controls to 1 the Control Building provide for control room temperature control. The CREATCS is a Ventilation System subsystem providing air temperature control for the control room.
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| of CREVS s air conditioning unit The CREATCS is an emergency system, parts of which may also operate 1 120ºF during normal unit operations. A single train will provide the required CRAC temperature control to maintain the control room between [70]° and [85]°. 2 The CREATCS operation in maintaining the control room temperature is U 9.9 1 2 discussed in the FSAR, Section [6.4] (Ref. 1).
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| APPLICABLE The design basis of the CREATCS is to maintain the control room SAFETY temperature for 30 days of continuous occupancy.
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| ANALYSES units The CREATCS components are arranged in redundant, safety related 120ºF trains. During emergency operation, the CREATCS maintains the 1 temperature between [70]° and [85]°. A single active failure of a 2 component of the CREATCS, with a loss of offsite power, does not impair the ability of the system to perform its design function. Redundant detectors and controls are provided for control room temperature control.
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| The CREATCS is designed in accordance with Seismic Category I requirements. The CREATCS is capable of removing sensible and latent heat loads from the control room, which include consideration of equipment heat loads and personnel occupancy requirements, to ensure equipment OPERABILITY.
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| The CREATCS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).
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| LCO Two independent and redundant trains of the CREATCS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disabling the other train. Total system failure could result in the equipment operating temperature exceeding limits in the event of an accident.
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| Westinghouse STS B 3.7.11-1 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| ITS 3.7.11 1
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| INSERT 1 The control room is maintained at the personnel comfort level of (70 + 10)°F. Protective equipment inside the room is designed to operate within design tolerance over this temperature range and will perform its protective function in an ambient of 120°F and 95% relative humidity (i.e., there will be no loss-of-function in an ambient temperature of 120°F).
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| AHU (AHU)
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| Each air conditioning unit consists of a condensing unit, an air handling unit, instrumentation, and controls to provide for control room temperature control. All three control room air condition (CRAC) units (air handling unit and condensing unit) are powered by swing power sources, each of which can be powered by the emergency diesel generators. One CRAC unit is powered by MCC 3D, one unit by MCC 4D, and the third unit is powered via a transfer switch which automatically transfers between MCCs 3B and 4B. This configuration precludes the loss of more than one CRAC unit for any postulated single failure. Control room equipment is designed to operate in an environment of 120°F and 95% relative humidity. If two of three units were inoperative, the third would maintain the environment within these limits.
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| The AHUs also support the OPERABILITY requirements of LCO 3.7.10, "Control Room inoperable Emergency Ventilation System (CREVS)." Refer to LCO 3.7.10 for AHU requirements associated with CREVS.
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| INSERT B 3.7.11-1
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| 6/16/22, 1:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1179 NRC Question JMW032 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/16/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/16/2022 10:39 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1179 1/1
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| 5/20/22, 11:10 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 535 NRC Question JMW033 Number Category Editorial ITS Section 3.7 ITS Number 3.7.10 DOC Number JFD Number JFD Bases Number Page 276 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC The Bases for ITS 3.7.10 Actions F states An alternative to Required Action D.1 is to immediately Question Action D.1 referenced here should be Action F.1.1. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:14 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=535 1/1
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| 8/14/22, 9:41 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 535 NRC Question JMW033 Number Select Licensee Response Application Attachment Attachment 1 - JMW033 LAR Markups.pdf (629KB) 1 Attachment 2
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| Response FPL will revise the ITS 3.7.10 ACTION F Bases to refer to Required Action F.1.1 as suggested above.
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| Statement ACTION F requires the CREVS to be placed in the emergency mode of operation (Required Action F.1.1) or, as an alternative, the suspension of the movement of irradiated fuel assemblies (Required Action F.1.2).
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| See attached JMW033 license amendment request (LAR),
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| Revision 1, markups.
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| Attachment
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| : 1. JMW033 LAR Markups
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| | |
| ===Response===
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| 5/30/2022 2:25 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:27 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=535 1/1
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| V CREFS 1 B 3.7.10 BASES ACTIONS (continued) 1 (AFW) stated in Reference 5, the steam turbine driven auxiliary feedwater pump 1 must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.
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| D.2 Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is 1
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| not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.
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| However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power INSERT 5 conditions in an orderly manner and without challenging unit systems.
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| D.1 and D.2 4 F.1.1, F.1.2, and F.2
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| [In MODE 5 or 6, or] during movement of [recently] irradiated fuel 2 V
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| assemblies, if the inoperable CREFS train cannot be restored to OPERABLE status within the required Completion Time, action must be 1 V
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| taken to immediately place the OPERABLE CREFS train in the emergency mode. This action ensures that the remaining train is with two recirculation OPERABLE 4 OPERABLE, that no failures preventing automatic actuation will occur, AHUs in service and that any active failure would be readily detected.
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| F.1.1 An alternative to Required Action D.1 is to immediately suspend activities 1 that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.
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| [Required Action D.1 is modified by a Note indicating to place the system 2 INSERT 6 in the toxic gas protection mode if automatic transfer to the toxic gas protection mode is inoperable. ]
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| INSERT 7 Westinghouse STS B 3.7.10-6 Rev. 5.0 1
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| Turkey Point Unit 3 and Unit 4 Revision XXX
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| 6/9/22, 3:20 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1035 NRC Question JMW033 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:58 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1035 1/1
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| 5/20/22, 11:10 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 539 NRC Question JMW034 Number Category Editorial ITS Section 3.7 ITS Number 3.7.10 DOC Number JFD Number JFD Bases Number Page Number(s) 278 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Question Insert 7 in the Bases is not labeled with an Action. It appears that this should be labeled I.1. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:15 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=539 1/1
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| 8/14/22, 9:41 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 539 NRC Question JMW034 Number Select Licensee Response Application Attachment Attachment 1 - JMW034 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response FPL will revise Insert 7 of the ITS 3.7.10 Bases to add label "I.1". ITS 3.7.10, Required Action I.1, is Statement associated with entry into Limiting Condition for Operation (LCO) 3.0.3, which is the subject of ITS 3.7.10 Bases Insert 7. See attached JMW034 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW034 LAR Markups
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| ===Response===
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| 5/30/2022 2:30 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:29 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=539 1/1
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| ITS 3.7.10 1
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| INSERT 6 (cont.)
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| H.1 With both CREVS trains inoperable for reasons other than an inoperable CRE boundary (e.g.,
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| the common filter unit is inoperable, two recirculation fans are inoperable, or required dampers are inoperable and not secured in the accident position) or the normal outside air intake flowpath is isolated, the compensatory filtration unit is required to be placed in service within 24 hours. This remedial action ensures control room occupant radiological exposures will not exceed limits. The 24-hour allowance to place the compensatory filtration unit in service is reasonable based on the low probability of a DBA occurring during this time period.
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| The compensatory filtration unit is designed as a manual, safety-related, Seismic Class I backup to the installed system with the same functional and operational capabilities as the installed CREVS filter unit. The requirements for the compensatory filtration unit are located in the Technical Requirements Manual.
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| 4 INSERT 7 I.1 If two or more AHUs are inoperable, the CREVS can no longer provide its specified safety function. Additionally, if the Required Action of Condition G or H cannot be performed within the required Completion Time, no additional time is justified for continued operation. Therefore, LCO 3.0.3 must be entered immediately.
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| INSERT Page B 3.7.10-6b
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| 6/9/22, 3:19 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1039 NRC Question JMW034 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:58 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1039 1/1
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| 5/20/22, 11:11 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 543 NRC Question JMW035 Number Category Editorial ITS Section 3.7 ITS Number 3.7.10 DOC Number JFD Number JFD Bases Number Page Number(s) 279 NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question I.1 in the Bases is not correctly labeled, it appears this should be J.1, as J.1 is missing from the Bases.
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| Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:16 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=543 1/1
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| 8/14/22, 9:42 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 543 NRC Question JMW035 Number Select Licensee Response Application Attachment Attachment 1 - JMW035 LAR Markups.pdf (634KB) 1 Attachment 2
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| Response FPL will revise the ITS 3.7.10 Bases markup (page 279 of 456) to change label I.1 to J.1. Required Action Statement J.1 requires the suspension of movement of irradiated fuel assemblies, which is the subject of the aforementioned ITS 3.7.10 Bases paragraph. See attached JMW035 license amendment request (LAR),
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| Revision 1, markups.
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| Attachment
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| : 1. JMW035 LAR Markups
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| | |
| ===Response===
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| 5/30/2022 2:40 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:40 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=543 1/1
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| V CREFS 1 B 3.7.10 BASES ACTIONS (continued)
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| J.1 E.1 4 I.1 or more Control Room [In MODE 5 or 6, or] during movement of [recently] irradiated fuel 2 AHUs inoperable or with assemblies, with two CREFS trains inoperable or with one or more 4
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| CREVS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.
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| INSERT 8 F.1 4 If both CREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e., Condition B), the CREFS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.
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| SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Operation [with the heaters on] for 15 continuous minutes demonstrates OPERABILITY of the 3 system. Periodic operation ensures that [heater failure,] blockage, fan or motor failure, or excessive vibration can be detected for corrective action.
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| [ The 31 day Frequency is based on the reliability of the equipment and 3 the two train redundancy.
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| OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the 2 Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| Westinghouse STS B 3.7.10-7 Rev. 5.0 1
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| Turkey Point Unit 3 and Unit 4 Revision XXX
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| 6/9/22, 3:20 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1043 NRC Question JMW035 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 9:59 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1043 1/1
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| 5/20/22, 11:28 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 547 NRC Question JMW036 Number Category Editorial ITS 3.7 Section ITS 3.7.10 Number DOC Number JFD Number JFD Bases Number Page 282 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC The Bases for SR 3.7.10.4 references Condition B: "When unfiltered air inleakage is greater than the Question assumed flow rate, Condition B must be entered." Verify this reference is correct as the correct reference appears to be Condition C. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:18 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=547 1/1
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| 8/14/22, 9:42 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 547 NRC Question JMW036 Number Select Licensee Response Application Attachment Attachment 1 - JMW036 LAR Markups.pdf (627KB) 1 Attachment 2
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| Response FPL will revise the ITS 3.7.10 Bases for Surveillance Requirement (SR) 3.7.10.4 to reference Condition C in Statement lieu of Condition B. Condition C is associated with a degraded Control Room Envelope (CRE) boundary, which is tested as required by SR 3.7.10.4. See attached JMW036 license amendment request (LAR),
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| Revision 1, markups.
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| Attachment
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| : 1. JMW036 LAR Markups
| |
| | |
| ===Response===
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| 5/30/2022 2:45 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:43 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=547 1/1
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| V CREFS 1 B 3.7.10 BASES SURVEILLANCE REQUIREMENTS (continued)
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| SR 3.7.10.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.
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| The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than [5 rem whole body or its equivalent to any 3
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| part of the body] [5 rem TEDE] and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air C C.3 inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to 4 OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants 2 following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 6) which endorses, with 1 exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 7). These 3
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| C.2 compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also 4 be used as compensatory measures to restore OPERABILITY (Ref. 8). 1 Options for restoring the CRE boundary to OPERABLE status include 4 changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.
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| REFERENCES 1. FSAR, Section [9.4].
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| : 2. FSAR, Chapter [15].
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| : 3. FSAR, Section [6.4]. 1
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| : 4. FSAR, Section [9.5]
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| : 5. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes 1 to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.
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| Westinghouse STS B 3.7.10-9 Rev. 5.0 1
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| Turkey Point Unit 3 and Unit 4 Revision XXX
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| 6/9/22, 3:21 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1047 NRC Question JMW036 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:00 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1047 1/1
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| 5/20/22, 11:29 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 551 NRC Question JMW037 Number Category Editorial ITS Section 3.7 ITS Number 3.7.11 DOC Number JFD Number JFD Bases Number Page Number(s) 298 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Question In the 3.7.11 ITS markup, Required Action A.1, the t in to is struck out. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:19 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=551 1/1
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| 8/14/22, 9:44 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 551 NRC Question JMW037 Number Select Licensee Response Application Attachment Attachment 1 - JMW037 LAR Markups.pdf (628KB) 1 Attachment 2
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| Response FPL will revise the ITS 3.7.11, Required Action A.1, markup to remove the unnecessary strike out. See Statement attached JMW037 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW037 LAR Markups
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| ===Response===
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| 5/30/2022 2:45 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 5/30/2022 1:45 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=551 1/1
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| CREATCS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS)
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| LCO 3.7.11 Two CREATCS trains shall be OPERABLE.
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| APPLICABILITY: MODES 1, 2, 3, 4, [5, and 6], 1 During movement of [recently] irradiated fuel assemblies.
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| ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME required to Action a.2 A. One CREATCS train A.1 Restore CREATCS train to 30 days 3 inoperable. OPERABLE status.
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| B. Required Action and B.1 Be in MODE 3. 6 hours Action a.2 associated Completion Time of Condition A not AND met in MODE 1, 2, 3, or 4. B.2 --------------NOTE--------------
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| ---------------NOTE------------ LCO 3.0.4.a is not Not applicable when a dual 2 applicable when entering unit shutdown is required.
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| ------------------------------------ MODE 4.
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| Be in MODE 4. 12 hours 2 INSERT 1 D
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| C. Required Action and C.1 Place OPERABLE Immediately Action a.2 associated Completion CREATCS train in Time of Condition A not operation.
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| met [in MODE 5 or 6, or] 1 during movement of OR
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| [recently] irradiated fuel 1 assemblies. C.2 Suspend movement of Immediately
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| [recently] irradiated fuel 1 assemblies.
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| Westinghouse STS 3.7.11-1 Rev. 5.0 3 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY
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| 6/9/22, 3:23 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1051 NRC Question JMW037 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:01 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1051 1/1
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| 5/20/22, 11:29 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 555 NRC Question JMW038 Number Category Editorial ITS Section 3.7 ITS Number 3.7.11 DOC Number JFD Number JFD Bases Number Page Number(s) 298 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call Requested N NRC Question The OR between Required Actions D.1 and D.2 should be underlined. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:20 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=555 1/1
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| 8/14/22, 9:44 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 555 NRC Question JMW038 Number Select Licensee Response Application Attachment Attachment 1 - JMW038 LAR Markups.pdf (68KB) 1 Attachment 2
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| Response FPL will revise ITS 3.7.11 to include an underline of the "OR" logical connector between Required Actions Statement D.1 and D.2. See attached JMW038 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW038 LAR Markups
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| ===Response===
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| 5/30/2022 2:50 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:50 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=555 1/1
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| CREATCS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS)
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| LCO 3.7.11 Two CREATCS trains shall be OPERABLE.
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| APPLICABILITY: MODES 1, 2, 3, 4, [5, and 6], 1 During movement of [recently] irradiated fuel assemblies.
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| ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME required Action a.2 A. One CREATCS train A.1 Restore CREATCS train to 30 days 3 inoperable. OPERABLE status.
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| B. Required Action and B.1 Be in MODE 3. 6 hours Action a.2 associated Completion Time of Condition A not AND met in MODE 1, 2, 3, or 4. B.2 --------------NOTE--------------
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| ---------------NOTE------------ LCO 3.0.4.a is not Not applicable when a dual 2 applicable when entering unit shutdown is required.
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| ------------------------------------ MODE 4.
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| Be in MODE 4. 12 hours 2 INSERT 1 D
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| C. Required Action and C.1 Place OPERABLE Immediately Action a.2 associated Completion CREATCS train in Time of Condition A not operation.
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| met [in MODE 5 or 6, or] 1 during movement of OR
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| [recently] irradiated fuel 1 assemblies. C.2 Suspend movement of Immediately
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| [recently] irradiated fuel 1 assemblies.
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| Westinghouse STS 3.7.11-1 Rev. 5.0 3 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY
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| 6/9/22, 3:24 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1055 NRC Question JMW038 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:01 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1055 1/1
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| 5/20/22, 11:30 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 559 NRC Question JMW039 Number Category Editorial ITS 3.7 Section ITS 3.7.11 Number DOC Number JFD Number JFD Bases Number Page 305 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC The text bubble to be inserted in the Bases for Actions B.1 and B.2 states When a dual unit shutdown is Question required, Condition E is applicable. Condition E referenced should be Condition C. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:22 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=559 1/1
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| 8/14/22, 9:45 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 559 NRC Question JMW039 Number Select Licensee Response Application Attachment Attachment 1 - JMW039 LAR Markups.pdf (626KB) 1 Attachment 2
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| Response FPL will revise the ITS 3.7.11 Bases text insert for Required Actions B.1 and B.2 to reference Condition C Statement with respect to discussion associated with a dual unit shutdown, consistent with the Required Actions associated with Condition C. See attached JMW039 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW039 LAR Markups
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| ===Response===
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| 5/30/2022 2:55 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:58 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=559 1/1
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| CREATCS B 3.7.11 BASES LCO (continued)
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| The CREATCS is considered to be OPERABLE when the individual components necessary to maintain the control room temperature are OPERABLE in both trains. These components include the heating and 1 cooling coils and associated temperature control instrumentation. In addition, the CREATCS must be operable to the extent that air circulation can be maintained.
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| APPLICABILITY In MODES 1, 2, 3, 4, [5, and 6,] and during movement of [recently] 2 irradiated fuel assemblies, the CREATCS must be OPERABLE to ensure that the control room temperature will not exceed equipment operational requirements following isolation of the control room. [The CREATCS is only required to be OPERABLE during fuel handling involving handling 2
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| recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days), due to radioactive decay.]
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| [In MODE 5 or 6,] CREATCS may not be required for those facilities that 2 1 do not require automatic control room isolation.
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| ACTIONS A.1 With one CREATCS train inoperable, action must be taken to restore OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREATCS train is adequate to maintain the control room temperature within limits. However, the overall reliability is reduced because a single failure in the OPERABLE CREATCS train could result in loss of CREATCS function. The 30-day Completion Time is based on the low probability of an event requiring control room isolation, the consideration that the remaining train can provide the required protection, and that alternate safety or non-safety related cooling means are available.
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| B.1 and B.2 Condition B is modified by a Note stating that Condition B is not In MODE 1, 2, 3, or 4, if the inoperable CREATCS train cannot be applicable when a dual unit restored to OPERABLE status within the required Completion Time, the shutdown is required. Since both units share the same Control unit must be placed in a MODE in which the overall plant risk is reduced.
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| Room, both units can be affected by CREATCS inoperabilities, To achieve this status, the unit must be placed in at least MODE 3 within which may require a shutdown of 6 hours, and in MODE 4 within 12 hours.
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| both units. When a dual unit 1 shutdown is required, Condition E is applicable. Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant C risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As Westinghouse STS B 3.7.11-2 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 6/9/22, 3:25 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1059 NRC Question JMW039 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:02 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1059 1/1
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| 5/20/22, 11:31 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 563 NRC Question JMW040 Number Category Editorial ITS Section 3.7 ITS Number 3.7.11 DOC Number JFD Number JFD Bases Number Page 307 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Insert 2 in the Bases states Required Action E.2 is modified by a Note that states that LCO 3.0.4.a is not Question applicable Action E.2 referenced should be C.2. Please evaluate and make necessary corrections Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:23 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=563 1/1
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| 8/14/22, 9:45 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 563 NRC Question JMW040 Number Select Licensee Response Application Attachment Attachment 1 - JMW040 LAR Markups.pdf (659KB) 1 Attachment 2
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| Response FPL will revise Insert 2 of the ITS 3.7.11 Bases to reference Required Action C.2, which contains the Note Statement stating the Limiting Condition for Operation (LCO) 3.0.4.a is not applicable. See attached JMW040 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW040 LAR Markups
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| ===Response===
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| 5/30/2022 3:00 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 1:59 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=563 1/1
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| ITS 3.7.11 1
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| INSERT 2 C.1 and C.2 Condition C is modified by a Note stating that Condition C is only applicable when a dual unit shutdown is required. Since both units share the same Control Room, both units can be affected by CREATCS inoperabilities. Condition B is applicable if only one unit is required to shut down.
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| In MODE 1, 2, 3, or 4, if the inoperable CREATCS is not restored to OPERABLE status within the required Completion Time the units must be placed in a MODE in which the overall plant risk is reduced. To achieve this status, the second unit must be placed in at least MODE 3 within 12 hours, and in MODE 4 within 18 hours. The extra 6 hours is to facilitate a sequential dual unit shutdown.
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| Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.
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| C.2 Required Action E.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
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| INSERT B 3.7.11-3
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| 6/9/22, 3:25 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1063 NRC Question JMW040 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:03 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1063 1/1
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| 5/20/22, 11:31 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 571 NRC Question JMW041 Number Category Technical ITS 3.7 Section ITS 3.7.12 Number DOC A-2 Number JFD Number JFD Bases Number Page 315 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.7.11 DOC A02 - states in part With the top of the storage racks at 33 feet, maintaining a fuel storage Question pool level 56'-10" maintains 23 ft of water over the irradiated assemblies seating in the storage racks. It appears that the ITS requirement of 23 ft is 10 less than the CTS requirement of 56'-10".
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| Revise the discussion of changes to reflect that this is a less restrictive change.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:24 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=571 1/1
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| 8/3/22, 5:49 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1467 NRC Question JMW041 Number Select Licensee Response Application Attachment Attachment 1 - JMW041 LAR Markups.pdf (800KB) 1 Attachment 2
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| Response FPL will remove the proposed administrative change related to the level of water over the irradiated Statement assemblies seating in the storage racks in favor of maintaining the current licensing basis of a storage pool level of 56 ft 10 inches elevation. A water level at an elevation of 56 ft. 10 in. is equivalent to 25 feet of water above the top of the fuel storage racks in the storage pool and supports the fuel handling accident analysis assumption of at least 23 feet of water above a damaged fuel assembly. Maintaining the current value of 56 ft 10 inches elevation eliminates the need for a less restrictive change.
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| ITS 3.7.12, Discussion of Change (DOC) A02 is deleted and DOC A03 is renumbered as DOC A02. The CTS, ITS, and ITS Bases markups are also revised accordingly. Justification for Deviation (JFD) 6 is added to support the ITS Bases changes necessary to describe the current licensing basis. See Attachment 1 -
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| JMW041 LAR Markups.
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| Attachment
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| : 1. JMW041 LAR Markups
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| ===Response===
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| 7/6/2022 1:15 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/6/2022 12:12 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1467 1/1
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| ITS A01 ITS 3.7.12 REFUELING OPERATIONS 3/4.9.11 WATER LEVEL STORAGE POOL LIMITING CONDITION FOR OPERATION 23 ft over the top of irradiated fuel assemblies seated in the storage racks A02 LCO 3.7.12 3.9.11 The water level shall be maintained greater than or equal to elevation 56 - 10 the spent fuel storage pool.*
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| undelete During Movement of irradiated fuel assemblies in the fuel storage pool.
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| undelete L01 Applicability APPLICABILITY: Whenever irradiated fuel assemblies are in the storage pool.
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| ACTION:
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| irradiated L01 ACTION A a. With the requirements of the above specification not satisfied, suspend all movement of fuel assemblies and crane operations with loads in the fuel storage areas. A03 L02 immediately ACTION A.1 b. The provisions of Specification 3.0.3 are not applicable.
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| Note 2
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| SURVEILLANCE REQUIREMENTS SR 3.7.12.1 4.9.11 The water level in the storage pool shall be determined to be at least its minimum required depth in L01 accordance with the Surveillance Frequency Control Program when irradiated fuel assemblies are in the fuel storage pool.
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| 3/4.9.12 DELETED TURKEY POINT - UNITS 3 & 4 3/4 9-11 AMENDMENT NOS. 279 AND 274
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| DISCUSSION OF CHANGES ITS 3.7.12, FUEL STORAGE POOL WATER LEVEL ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).
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| These changes are designated as administrative changes and are acceptable, because they do not result in technical changes to the CTS.
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| A02 CTS 3.9.11 requires that the water shall be maintained greater than or equal to elevation 56 - 10 in the spent fuel storage pool. ITS LCO 3.7.12 requires that the fuel storage pool water level shall be 23 ft over the top of irradiated fuel assemblies seated in the storage racks. This changes the CTS by presenting the required water level an elevation above the irradiated fuel assemblies instead of a plant elevation.
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| The purpose of CTS 3.9.11 is to ensure the minimum water level in the fuel storage pool meets the assumptions of the fuel handling accident. The fuel handling accident assumption for the spent fuel storage pool water level is a minimum pool water depth above damaged fuel of 23 feet (ADAMS Accession No ML11000666). With the top of the storage racks at 33 feet, maintaining a fuel storage pool level 56'-10" maintains 23 ft of water over the irradiated assemblies seating in the storage racks. This change is acceptable because the water level ensures the assumptions of the accident analysis are met. The change is considered administrative because no technical changes are being made to the CTS.
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| A03 CTS 3.9.11 ACTION states, in part, that with the requirements of the Specification not satisfied, to suspend all movement of fuel assemblies.
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| 2 ITS 3.7.12 Required Action A.1 requires the immediate suspension of movement of irradiated fuel assemblies in the spent fuel pool. This changes the CTS by explicitly specifying that the compensatory action to suspend all movement of fuel assemblies requires an immediate response, not to preclude movement of a fuel assembly to a safe position.
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| The purpose of the CTS 3.9.11 ACTION a is to preclude a fuel handling accident from occurring. The current action does not specify a time; however, it implies that the action is immediate. This change is acceptable because it only provides clarification that the compensatory action requires an immediate response. This change is designated as administrative because it does not result in a technical change to the CTS.
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| MORE RESTRICTIVE CHANGES None Turkey Point Unit 3 and Unit 4 Page 1 of 3
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| CTS Fuel Storage Pool Water Level 3.7.15 1 12 3.7 PLANT SYSTEMS 1
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| 12 3.7.15 Fuel Storage Pool Water Level 56 ft 10 inches elevation 12 3.9.11 LCO 3.7.15 The fuel . to oo t 23 ft over the top of irradiated 1 fuel assemblies seated in the storage racks. 2 Applicability APPLICABILITY: During movement of irradiated fuel assemblies in the fuel storage pool.
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| ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION a A. Fuel storage pool water A.1 --------------NOTE--------------
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| ACTION b Note level not within limit. LCO 3.0.3 is not applicable.
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| Suspend movement of Immediately irradiated fuel assemblies in the fuel storage pool.
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| SURVEILLANCE REQUIREMENTS 56 ft 10 inches SURVEILLANCE elevation FREQUENCY 12 1 3 SR 4.9.11 SR 3.7.15. 1 Verify the to oo t 23 ft [ 7 days above the top of the irradiated fuel assemblies 2 seated in the storage racks. OR In accordance with the Surveillance Frequency Control Program ] 3 Turkey Point Unit 3 and Unit 4 12 Amendment Nos. XXX and YYY Westinghouse STS 3.7.15-1 Rev. 5.0 2 1
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| Fuel Storage Pool Water Level 1
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| B 3.7.15 12 B 3.7 PLANT SYSTEMS 12 2
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| B 3.7.15 Fuel Storage Pool Water Level BASES BACKGROUND The minimum water level in the fuel storage pool meets the assumptions of iodine decontamination factors following a fuel handling accident. The specified water level shields and minimizes the general area dose when the storage racks are filled to their maximum capacity. The water also provides shielding during the movement of spent fuel.
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| U A general description of the fuel storage pool design is given in the FSAR, 2 9.5.2 Section [9.1.2] (Ref. 1). A description of the Spent Fuel Pool Cooling and Cleanup System is given in the FSAR, Section [9.1.3] (Ref. 2). The 9.5.3 2 3 U
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| assumptions of the fuel handling accident are given in the FSAR, 14.2.1 Section [15.7.4] (Ref. 3).
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| APPLICABLE The minimum water level in the fuel storage pool meets the SAFETY 183 assumptions of the fuel handling accident described in Regulatory 2 ANALYSES Guide 1.25 (Ref. 4). The resultant 2 hour thyroid dose per person at the exclusion area boundary is a small fraction of the 10 CFR 100 (Ref. 5) 50.67 limits.
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| According to Reference 4, there is 23 ft of water between the top of the the minimum storage pool level at damaged fuel bundle and the fuel pool surface during a fuel handling an elevation of 56 ft accident. With 23 ft of water, the assumptions of Reference 4 can be 10 inches ensures used directly. In practice, this LCO preserves this assumption for the bulk that at least 23 ft of of the fuel in the storage racks. In the case of a single bundle dropped water remains above the damaged and lying horizontally on top of the spent fuel racks, however, there may 6 fuel assembly. The be < 23 ft of water above the top of the fuel bundle and the surface, indicated by the width of the bundle. To offset this small nonconservatism, the analysis assumes that all fuel rods fail, although analysis shows that only the first few rows fail from a hypothetical maximum drop.
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| The fuel storage pool water level satisfies Criteria 2 and 3 of 56 ft 10 inches 10 CFR 50.36(c)(2)(ii). elevation LCO The fuel to oo t to 23 ft over the top of irradiated fuel assemblies seated in the storage racks. The specified water level preserves the assumptions of the fuel handling accident analysis (Ref. 3). As such, it is the minimum required for fuel storage and movement within the fuel storage pool.
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| equates to 25 feet above the top of the spent fuel storage racks and Turkey Point Unit 3 and Unit 4 12 Revision XXX Westinghouse STS B 3.7.15-1 Rev. 5.0 2 1
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| JUSTIFICATION FOR DEVIATIONS ITS 3.7.12 BASES, FUEL STORAGE POOL WATER LEVEL
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| : 1. Improved Standard Technical Specification (ISTS) B 3.7.15, "Fuel Storage Pool Water Level" has been renumbered as Improved Technical Specifications (ITS) B 3.7.12, "Fuel Storage Pool Water Level."
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| : 2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 3. The ISTS Bases contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
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| : 5. ITS 3.7.12 Bases references SR 3.6.9.1 as verifying canal water level. Canal water level is verified by SR 3.9.2.1.
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| : 6. Information is added to the ITS 3.7.12 Bases associated with the current licensing basis minimum storage pool level based on a plant elevation of 56 ft 10 inches. A water level at a plant elevation of 56 ft 10 inches is equivalent to 25 feet of water above the top of the fuel storage racks in the storage pool and ensures the fuel handling accident analysis assumption of 23 feet of water above a damaged fuel assembly is maintained.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 7/11/22, 12:49 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1526 NRC Question JMW041 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/11/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/11/2022 11:20 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1526 1/1
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| 5/20/22, 11:32 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 575 NRC Question JMW042 Number Category Editorial ITS 3.7 Section ITS 3.7.13 Number DOC Number JFD Number JFD Bases Number Page 338 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Bases Background section for ITS 3.7.13 states: Prior to movement of an assembly, it is necessary to Question perform SR 3.7.14.1. Verify this SR reference is correct. The Bases for subsection 3.7.14 has a similar statement but references SR 3.7.13.1.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:26 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=575 1/1
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| 8/14/22, 9:46 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 567 NRC Question JMW042 Number Select Licensee Response Application Attachment Attachment 1 - JMW042 LAR Markup EA.pdf (72KB) 1 Attachment 2
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| Response ITS B 3.7.13 Background, last paragraph, last sentence, markup reference to SR 3.7.14.1 will be changed Statement to reference SR 3.7.13.1. See Attachment 1 - JMW042 LAR Markups.
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| Attachment
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| : 1. JMW042 LAR Markups
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| ===Response===
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| 5/30/2022 3:00 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 5/30/2022 2:01 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=567 1/1
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| [Fuel Storage Pool Boron Concentration] 1 B 3.7.16 2 13 B 3.7 PLANT SYSTEMS B 3.7.16 [ Fuel Storage Pool Boron Concentration ] 2 1 13 BASES BACKGROUND In the Maximum Density Rack (MDR) [(Refs. 1 and 2)] design, the spent fuel storage pool is divided into two separate and distinct regions which, for the purpose of criticality considerations, are considered as separate pools. [Region 1], with [336] storage positions, is designed to accommodate new fuel with a maximum enrichment of [4.65] wt% U-235, or spent fuel regardless of the discharge fuel burnup. [Region 2], with 3
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| [2670] storage positions, is designed to accommodate fuel of various initial enrichments which have accumulated minimum burnups within the acceptable domain according to Figure [3.7.17-1], in the accompanying LCO. Fuel assemblies not meeting the criteria of Figure [3.7.17-1] shall be stored in accordance with paragraph 4.3.1.1 in Section 4.3, Fuel Storage. INSERT 1 3 The water in the spent fuel storage pool normally contains soluble boron, which results in large subcriticality margins under actual operating conditions. However, the NRC guidelines, based upon the accident condition in which all soluble poison is assumed to have been lost, specify that the limiting keff of 0.95 be evaluated in the absence of soluble boron. Hence, the design of both regions is based on the use of unborated water, which maintains each region in a subcritical condition during normal operation with the regions fully loaded. The double /ANS-8.1-1983 1
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| contingency principle discussed in ANSI N-16.1-1975 and the April 1978 3
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| NRC letter (Ref. 3) allows credit for soluble boron under other abnormal or accident conditions, since only a single accident need be considered at one time. For example, the most severe accident scenario is associated with the movement of fuel from [Region 1 to Region 2], and accidental misloading of a fuel assembly in [Region 2]. This could potentially 3 increase the criticality of [Region 2]. To mitigate these postulated criticality related accidents, boron is dissolved in the pool water. Safe operation of the MDR with no movement of assemblies may therefore be 13 achieved by controlling the location of each assembly in accordance with 14 LCO 3.7.17, "Spent Fuel Assembly Storage." Prior to movement of an assembly, it is necessary to perform SR 3.7.16.1. 3 APPLICABLE Most accident conditions do not result in an increase in the activity of SAFETY either of the two regions. Examples of these accident conditions are the ANALYSES loss of cooling (reactivity increase with decreasing water density) and the dropping of a fuel assembly on the top of the rack. However, accidents 3 can be postulated that could increase the reactivity. This increase in reactivity is unacceptable with unborated water in the storage pool. Thus, for these accident occurrences, the presence of soluble boron in the Turkey Point Unit 3 and Unit 4 13 Revision XXX 2 Westinghouse STS B 3.7.16-1 Rev. 5.0 3
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| 6/9/22, 3:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1067 NRC Question JMW042 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:05 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1067 1/1
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| 5/20/22, 11:38 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 579 NRC Question JMW043 Number Category Editorial ITS Section 3.7 ITS Number 3.7.14 DOC Number JFD Number JFD Bases Number Page 348 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC The CTS markup has an insert in the LCO that states: Insert CTS Specification 5.5.1.e and 5.5.1.3. There Question is no 5.5.1.e in CTS, this should be 5.5.1.1.e. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:27 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=579 1/1
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| 8/14/22, 9:47 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 571 NRC Question JMW043 Number Select Licensee Response Application Attachment Attachment 1 - JMW043 LAR Markup EA.pdf (160KB) 1 Attachment 2
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| Response ITS 3.7.14 CTS markup 3.9.14 Insert statement will be changed to reference 5.5.1.1.e. In addition, Statement Discussion of Change (DOC) A02 contains a typo in the first sentence; the first word "CST" will be changed to "CTS." See Attachment 1 - JMW043 LAR Markups.
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| Attachment
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| : 1. JMW043 LAR Markups
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| ===Response===
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| 5/30/2022 3:00 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 2:03 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=571 1/1
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| ITS ITS 3.7.14 A01 REFUELING OPERATIONS 3/4.9.14 SPENT FUEL STORAGE LIMITING CONDITION FOR OPERATION LCO 3.7.14 3.9.14 The following conditions shall apply to spent fuel storage:
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| : a. The minimum boron concentration in the Spent Fuel Pit shall be 2300 ppm. See ITS 3.7.13
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| : b. The combination of initial enrichment, burnup, and cooling time of each fuel assembly stored in A02 the Spent Fuel Pit shall be in accordance with Specification 5.5.1. the following:
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| Insert CTS Specification 5.5.1.e and 5.5.1.3 Applicability APPLICABILITY: At all times when fuel is stored in the Spent Fuel Pit.
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| 5.5.1.1.e See ITS ACTION: 3.7.13
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| : a. With boron concentration in the Spent Fuel Pit less than 2300 ppm, suspend movement of spent fuel in the Spent Fuel Pit and initiate action to restore boron concentration to 2300 ppm or greater.
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| ACTION A b. With condition b not satisfied, suspend movement of additional fuel assemblies into the Spent Fuel Pit and restore the spent fuel storage configuration to within the specified conditions.
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| ACTION A.1 c. The provisions of Specification 3.0.3 are not applicable.
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| Note SURVEI LLANCE REQUIREMENTS 4.9.14.1 The boron concentration of the Spent Fuel Pit shall be verified to be 2300 ppm or greater in See ITS accordance with the Surveillance Frequency Control Program. 3.7.13 4.9.14.2 A representative sample of inservice Metamic inserts shall be visually inspected in accordance with the Metamic Surveillance Program described in UFSAR Section 16.2. The surveillance program LA01 ensures that the performance requirements of Metamic are met over the surveillance interval.
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| Add proposed SR 3.7.14.1 M01 TURKEY POINT - UNITS 3 & 4 3/4 9-13 AMENDMENT NOS. 263 AND 258
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| DISCUSSION OF CHANGES ITS 3.7.14, SPENT FUEL STORAGE ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).
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| These changes are designated as administrative changes and are acceptable CTS because they do not result in technical changes to the CTS.
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| A02 CST 3.9.14 LCO states "The combination of initial enrichment, burnup, and cooling time of each fuel assembly stored in the Spent Fuel Pit shall be in accordance with Specification 5.5.1." ITS 3.7.14 Limiting Condition for Operation (LCO) states something similar; however, instead of referencing the sections from the Design Features Section (ITS 4.0), the applicable Section is being moved to ITS 3.7.14, including a portion that is added to the LCO, and the associated Tables and Figures. This changes the CTS by moving the items referenced in the Design Features Section of CTS to ITS Section 3.7.14.
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| The purpose of the CTS is to ensure there is proper loading of fuel in the fuel storage racks. Whether the requirements for doing so are in the Design Features or in the Plant Systems section of Technical Specifications will not impact accomplishing this goal. Thus, moving the requirements from the one section of Technical Specifications to another will continue to ensure the fuel loading requirements are met and that appropriate action is taken if not. These changes are designated as administrative because the changes do not result in technical changes to the CTS.
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| MORE RESTRICTIVE CHANGES M01 ITS Surveillance Requirement (SR) 3.7.14.1 verifies by administrative means the fuel assemblies stored in Regions I and II are stored in accordance with the requirements of Figures 3.7.14-1 through Figure 3.7.14-3 and Tables 3.7.14-1 through 3.7.14.3 with credited for burnup and cooling time taken in determining acceptable placement locations for spent fuel in the two-region spent fuel racks.
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| The CTS do not contain this SR. This changes the CTS by adding a new SR to Technical Specifications.
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| The purpose of the ITS SR is to verify by administrative means that the fuel in the fuel storage pool is in accordance with the requirements contained in the figures and tables in the Technical Specifications. While the CTS did not explicitly contain a requirement to perform this verification, these requirements were verified per the figure and tables that were located in the Design Features section of Technical Specifications. This change is designated as more restrictive because an SR is being added to the ITS that was not in the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 2
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| 6/9/22, 3:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1071 NRC Question JMW043 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:06 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1071 1/1
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| 5/20/22, 11:39 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 583 NRC Question JMW044 Number Category Editorial ITS Section 3.7 ITS 3.7.14 Number DOC Number JFD Number JFD Bases Number Page 373 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC In the LCO section of the Bases, a text bubble to be inserted states: through 3.7.14-3 and Tables 3.7.14-1 Question through 3.7.14.4. Table 3.7.14.4 should be Table 3.7.14-4. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:29 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=583 1/1
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| 8/14/22, 9:47 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 575 NRC Question JMW044 Number Select Licensee Response Application Attachment 1 Attachment 1 - JMW044 LAR Markup EA.pdf (72KB)
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| Attachment 2 Response The reference to Table 3.7.14.4 in the ITS B 3.7.14 LCO Section Insert will be changed to replace Statement "3.7.14.4" with "3.7.14-4." See Attachment 1 - JMW044 LAR Markups.
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| Attachment
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| : 1. JMW044 LAR Markups
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| ===Response===
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| 5/30/2022 3:05 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 5/30/2022 2:05 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=575 1/1
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| [Spent Fuel Pool Storage] 1 B 3.7.17 2 14 BASES APPLICABLE The hypothetical accidents can only take place during or as a result of 2
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| SAFETY the movement of an assembly (Ref. 4). For these accident occurrences, 3 ANALYSES 13 the presence of soluble boron in the spent fuel storage pool (controlled by LCO 3.7.16, "Fuel Storage Pool Boron Concentration") prevents criticality 3 in both regions. By closely controlling the movement of each assembly and by checking the location of each assembly after movement, the time period for potential accidents may be limited to a small fraction of the total operating time. During the remaining time period with no potential for accidents, the operation may be under the auspices of the accompanying LCO.
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| The configuration of fuel assemblies in the fuel storage pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
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| 2 LCO The restrictions on the placement of fuel assemblies within the spent fuel storage pool, in accordance with Figure 3.7.17-1, in the accompanying LCO, 14 1.0 3 through 3.7.14-3 and Tables ensures the keff of the spent fuel storage pool will always remain < 0.95, 3.7.14-1 through 3.7.14.4 assuming the pool to be flooded with unborated water. Fuel assemblies 3.7.14-4 not meeting the criteria of Figure [3.7.17-1] shall be stored in accordance 3 INSERT 2 with Specification 4.3.1.1 in Section 4.3.
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| Region I or Region II APPLICABILITY This LCO applies whenever any fuel assembly is stored in [Region 2] of 3 1 spent the fuel storage pool. 3 ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.
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| When the configuration of fuel assemblies stored in [Region 2] the spent fuel storage pool is not in accordance with Figure 3.7.17-1, or Figure 3.7.14-1, paragraph 4.3.1.1, the immediate action is to initiate action to make the Figure 3.7.14-2, or Figure 3.7.14-3 necessary fuel assembly movement(s) to bring the configuration into compliance with Figure 3.7.17-1 or Specification 4.3.1.1.
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| If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of Freactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.
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| Turkey Point Unit 3 and Unit 4 14 Revision XXX Westinghouse STS B 3.7.17-2 Rev. 5.0
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| 6/9/22, 3:33 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1075 NRC Question JMW044 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:07 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1075 1/1
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| 5/20/22, 11:39 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 591 NRC Question JMW045 Number Category Editorial ITS Section 3.7 ITS Number 3.7.14 DOC Number JFD Number JFD Bases Number Page 373 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question The APPLICABILITY section of the Bases states in part of the spent fuel storage with the word pool struck out. Verify that the word pool was meant to be struck out.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:30 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=591 1/1
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| 8/14/22, 9:48 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 819 NRC Question JMW045 Number Select Licensee Response Application Attachment Attachment 1 - JMW045 LAR Markup (2).pdf (699KB) 1 Attachment 2
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| Response ITS B 3.7.14, Applicability, reference to "spent fuel storage" will be changed to "spent fuel pit." In addition, Statement ITS B 3.7.14 Background Insert 1, Applicable Safety Analyses, LCO, Applicability, and Actions sections reference to "spent fuel storage pool" will be changed to "spent fuel pit." See Attachment 1 - JMW045 LAR Markup.
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| Attachment
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| : 1. JMW045 LAR Markups
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| ===Response===
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| 6/5/2022 7:00 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/5/2022 6:00 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=819 1/1
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| [Spent Fuel Pool Storage] 1 B 3.7.17 2 14 B 3.7 PLANT SYSTEMS 14 2 1 B 3.7.17 [ Spent Fuel Pool Storage ]
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| BASES BACKGROUND In the Maximum Density Rack (MDR) [(Refs. 1 and 2)] design, the spent fuel storage pool is divided into two separate and distinct regions which, for the purpose of criticality considerations, are considered as separate pools. [Region 1], with [336] storage positions, is designed to accommodate new fuel with a maximum enrichment of [4.65] wt% U-235, 3
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| or spent fuel regardless of the discharge fuel burnup. [Region 2], with
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| [2670] storage positions, is designed to accommodate fuel of various initial enrichments which have accumulated minimum burnups within the acceptable domain according to Figure 3.7.17-1, in the accompanying LCO. Fuel assemblies not meeting the criteria of Figure [3.7.17-1] shall be stored in accordance with paragraph 4.3.1.1 in Section 4.3, Fuel Storage.
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| INSERT 1 3 The water in the spent fuel storage pool normally contains soluble boron, which results in large subcriticality margins under actual operating pit conditions. However, the NRC guidelines, based upon the accident condition in which all soluble poison is assumed to have been lost, 1.0 specify that the limiting keff of 0.95 be evaluated in the absence of soluble 3 boron. Hence, the design of both regions is based on the use of unborated water, which maintains each region in a subcritical condition during normal operation with the regions fully loaded. The double /ANS-8.1-1983 contingency principle discussed in ANSI N-16.1-1975 and the April 1978 3 1
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| NRC letter (Ref. 3) allows credit for soluble boron under other abnormal or accident conditions, since only a single accident need be considered at one time. For example, the most severe accident scenario is associated with the movement of fuel from [Region 1 to Region 2], and accidental misloading of a fuel assembly in [Region 2]. This could potentially 3
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| increase the criticality of [Region 2]. To mitigate these postulated criticality related accidents, boron is dissolved in the pool water. Safe operation of the MDR with no movement of assemblies may therefore be achieved by controlling the location of each assembly in accordance with the accompanying LCO. Prior to movement of an assembly, it is necessary to perform SR 3.7.16.1. 3 13 Turkey Point Unit 3 and Unit 4 14 Revision XXX Westinghouse STS B 3.7.17-1 Rev. 5.0
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| ITS 3.7.14 3
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| INSERT 1 spent fuel pit storage The Spent Fuel Storage racks provide safe subcritical storage of fuel assemblies by providing sufficient center-to-center spacing or a combination of spacing and poison to assure: a) Keff less than or equal to 0.95 with a minimum soluble boron concentration of 500 ppm present, and b) Keff less than 1.0 when flooded with unborated water for normal operations and postulated accidents. The 500 ppm value is needed to assure keff less than 0.95 for normal operating conditions. The criticality analysis needs 1700 ppm to assure keff less than 0.95 under the worst case accident condition. There is significant margin between the calculated ppm requirement and the spent fuel boron concentration requirement of 2300 ppm. The higher boron concentration value is chosen because, during refueling, the water volume in the spent fuel pool, the transfer canal, the refueling canal, the refueling cavity, and the reactor vessel form a single mass.
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| pit pit storage The spent fuel racks are divided into two regions, Region I and Region II. The Region I permanent racks have a 10.6 inch center-to-center spacing. The Region lI racks have a 9.0 inch center-to-center spacing. The cask area storage rack has a nominal 10.1 inch center to center spacing in the east-west direction and a nominal 10.7 inch center-to-center spacing in the north-south direction. cask area storage rack Any fuel for use at Turkey Point, and enriched to less than or equal to 5.0 wt % U-235, may be stored in the Cask Area Storage Rack. Fresh or irradiated fuel assemblies NOT stored in the Cask Area Storage Rack shall be stored in accordance with ITS 3.7.14.
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| not pit Fresh unirradiated fuel may be placed in the permanent Region I racks in accordance with the restrictions of Figure 3.7.14-1. Fresh unirradiated fuel may be placed in the permanent Region II racks in accordance with the restrictions of Figure 3.7.14-2. Prior to placement of irradiated fuel in Region I or II spent fuel storage rack cell locations, strict controls are employed to evaluate burnup of the fuel assembly. Upon determination that the fuel assembly meets the nominal burnup and associated post-irradiation cooling time requirements of Table 3.7.14-1 or Table 3.7.14-2, it may be placed in a Region I or II cell in accordance with the restrictions of Figures 3.7.14-1 through 3.7.14-3, respectively.
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| For all assemblies with blanketed fuel, the initial enrichment is based on the central zone enrichment (i.e.,
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| between the axial blankets) consistent with the assumptions of the analysis. These positive controls assure that the fuel enrichment limits, burnup, and post irradiation cooling time requirements assumed in the safety analyses will NOT be violated.
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| not Insert Page B 3.7.14-1
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| [Spent Fuel Pool Storage] 1 B 3.7.17 2 14 pit BASES APPLICABLE The hypothetical accidents can only take place during or as a result of 2
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| SAFETY the movement of an assembly (Ref. 4). For these accident occurrences, 3 ANALYSES 13 the presence of soluble boron in the spent fuel storage pool (controlled by LCO 3.7.16, "Fuel Storage Pool Boron Concentration") prevents criticality 3 in both regions. By closely controlling the movement of each assembly and by checking the location of each assembly after movement, the time period for potential accidents may be limited to a small fraction of the total operating time. During the remaining time period with no potential for accidents, the operation may be under the auspices of the accompanying LCO.
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| The configuration of fuel assemblies in the fuel storage pool satisfies pit Criterion 2 of 10 CFR 50.36(c)(2)(ii).
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| pit 2 LCO The restrictions on the placement of fuel assemblies within the spent fuel storage pool, in accordance with Figure 3.7.17-1, in the accompanying LCO, 14 1.0 3 through 3.7.14-3 and Tables ensures the keff of the spent fuel storage pool will always remain < 0.95, 3.7.14-1 through 3.7.14.4 assuming the pool to be flooded with unborated water. Fuel assemblies not meeting the criteria of Figure [3.7.17-1] shall be stored in accordance 3 INSERT 2 with Specification 4.3.1.1 in Section 4.3.
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| Region I or Region II APPLICABILITY This LCO applies whenever any fuel assembly is stored in [Region 2] of 3 1 spent the fuel storage pool. 3 ACTIONS A.1 pit Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.
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| When the configuration of fuel assemblies stored in [Region 2] the spent fuel storage pool is not in accordance with Figure 3.7.17-1, or Figure 3.7.14-1, paragraph 4.3.1.1, the immediate action is to initiate action to make the Figure 3.7.14-2, or Figure 3.7.14-3 necessary fuel assembly movement(s) to bring the configuration into compliance with Figure 3.7.17-1 or Specification 4.3.1.1.
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| If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of Freactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.
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| Turkey Point Unit 3 and Unit 4 14 Revision XXX Westinghouse STS B 3.7.17-2 Rev. 5.0
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| 6/13/22, 2:14 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1143 NRC Question JMW045 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/13/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/13/2022 12:40 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1143 1/1
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| 5/20/22, 1:22 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 595 NRC Question Number JMW046 Category Editorial ITS Section 3.7 ITS Number 3.7.14 DOC Number JFD Number JFD Bases Number Page Number(s) 373 NRC Reviewer Victor Cusumano Supervisor Technical Branch POC Add Name Conf Call Requested N NRC Question The bases for Action A.1 contains the word Freactor, please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:31 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=595 1/1
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| 8/14/22, 9:48 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 579 NRC Question JMW046 Number Select Application Licensee Response Attachment 1 Attachment 1 - JMW046 LAR Markup EA.pdf (85KB)
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| Attachment 2 Response ITS B 3.7.14, Action A.1, third paragraph, "Freactor" will be changed to "reactor." See Attachment 1 -
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| Statement JMW046 LAR Markups.
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| Attachment
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| : 1. JMW046 LAR Markups
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| ===Response===
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| 5/30/2022 3:05 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 5/30/2022 2:06 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=579 1/1
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| [Spent Fuel Pool Storage] 1 B 3.7.17 2 14 BASES APPLICABLE The hypothetical accidents can only take place during or as a result of 2
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| SAFETY the movement of an assembly (Ref. 4). For these accident occurrences, 3 ANALYSES 13 the presence of soluble boron in the spent fuel storage pool (controlled by LCO 3.7.16, "Fuel Storage Pool Boron Concentration") prevents criticality 3 in both regions. By closely controlling the movement of each assembly and by checking the location of each assembly after movement, the time period for potential accidents may be limited to a small fraction of the total operating time. During the remaining time period with no potential for accidents, the operation may be under the auspices of the accompanying LCO.
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| The configuration of fuel assemblies in the fuel storage pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
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| 2 LCO The restrictions on the placement of fuel assemblies within the spent fuel storage pool, in accordance with Figure 3.7.17-1, in the accompanying LCO, 14 1.0 3 through 3.7.14-3 and Tables ensures the keff of the spent fuel storage pool will always remain < 0.95, 3.7.14-1 through 3.7.14.4 assuming the pool to be flooded with unborated water. Fuel assemblies not meeting the criteria of Figure [3.7.17-1] shall be stored in accordance 3 INSERT 2 with Specification 4.3.1.1 in Section 4.3.
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| Region I or Region II APPLICABILITY This LCO applies whenever any fuel assembly is stored in [Region 2] of 3 1 spent the fuel storage pool. 3 ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.
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| When the configuration of fuel assemblies stored in [Region 2] the spent fuel storage pool is not in accordance with Figure 3.7.17-1, or Figure 3.7.14-1, paragraph 4.3.1.1, the immediate action is to initiate action to make the Figure 3.7.14-2, or Figure 3.7.14-3 necessary fuel assembly movement(s) to bring the configuration into compliance with Figure 3.7.17-1 or Specification 4.3.1.1.
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| If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor Freactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.
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| Turkey Point Unit 3 and Unit 4 14 Revision XXX Westinghouse STS B 3.7.17-2 Rev. 5.0
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| 6/9/22, 3:34 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1079 NRC Question JMW046 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:08 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1079 1/1
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| 5/20/22, 1:25 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 603 NRC Question JMW047 Number Category Editorial ITS 3.7 Section ITS 3.7.14 Number DOC Number JFD Number JFD Bases Number Page 374 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Insert 2 in the Bases states: The LCO is modified by a Note indicating that there are no Question restrictions on storage of fresh or irradiated fuel assemblies in the cask area storage rack.
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| The LCO does not appear to be modified by a note. Please clarify.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:33 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=603 1/1
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| 8/14/22, 9:49 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 583 NRC Question JMW047 Number Select Licensee Response Application Attachment Attachment 1 - JMW047 LAR Markup EA.pdf (96KB) 1 Attachment 2
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| Response ITS B 3.7.14, LCO, Insert 2, will be changed to state, "The LCO states that there are no restrictions on Statement storage of fresh or irradiated fuel assemblies in the cask area storage rack." The reference that the wording is contained in a note has been deleted, because the actual wording is part of the LCO and not in a note. See Attachment 1 - JMW047 LAR Markups.
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| Attachment
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| : 1. JMW047 LAR Markups
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| ===Response===
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| 5/30/2022 3:10 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 5/30/2022 2:10 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=583 1/1
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| ITS 3.7.14 3
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| INSERT 2 states The LCO is modified by a Note indicating that there are no restrictions on storage of fresh or irradiated fuel assemblies in the cask area storage rack. This is because in the cask area rack criticality is prevented by the design of the rack which limits fuel assembly interaction by fixing the separation distance between stored assemblies and/or by placing a neutron absorber panel between storage cells.
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| Insert Page B 3.7.14-2
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| 6/9/22, 3:35 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1083 NRC Question JMW047 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:09 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1083 1/1
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| 5/20/22, 2:28 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 611 NRC Question JMW048 Number Category Technical ITS 3.7 Section ITS 3.7.7 Number DOC Number JFD Number JFD Bases Number Page 165 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC CTS subsection 3.7.2 proposes to relocate SR 4.7.2.b.2 In accordance with the Surveillance Frequency Question Control Program verify by a performance test the heat exchanger surveillance curves, and the associated footnotes to the TRM.
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| The safety evaluation for increasing UHS temperature, dated August 8, 2014 (ML14199A107) states The licensee's CCW heat exchanger performance monitoring program keeps the CCW heat exchangers ready to perform their intended function and at their credited analysis capacity during normal and accident conditions. The CCW heat exchanger performance monitoring consists of TS SR testing and heat exchanger cleaning. The SE additionally states The addition of SR 4.7.4.b and the increased frequency of SR 4.7.2.b.2 assured that the LCO would be met.
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| Additionally, Chapter 14, Table 14.3.4.3-1 of the UFSAR states ICW temperatures up to 104 degrees F are allowed if supported by the CCW heat exchanger performance monitoring program.
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| Based on the information above it appears SR 4.7.2.b.2 may be a requirement 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. If so, it would be inappropriate to move this SR to the TRM. Please provide additional justification for removal of SR 4.7.2.b.2 and associated footnotes.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:35 PM Added https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=611 1/2
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| 5/20/22, 2:28 PM Turkey Point ITS Conversion Database Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=611 2/2
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| 8/3/22, 5:52 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1399 NRC Question JMW048 Number Select Licensee Response Application Attachment Attachment 1 - JMW048 3.7.7 LAR Markups (EA).pdf (1MB) 1 Attachment 2
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| Response FPL has determined that CTS SR 4.7.2.a and SR 4.7.2.b.2 are requirements relating to test, calibration, or Statement 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. Therefore, ITS 3.7.7 will be revised to retain the surveillance requirements as ITS SR 3.7.7.4 and SR 3.7.7.5, respectively. See Attachment 1 for proposed markups.
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| Attachment
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| : 1. JMW048 3.7.7 LAR Markup
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| ===Response===
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| 7/1/2022 12:20 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/1/2022 11:18 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1399 1/1
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| ITS A01 ITS 3.7.7 PLANT SYSTEMS (CCW) 3/4.7.2 COMPONENT COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION A02 Two trains LCO 3.7.7 3.7.2 The Component Cooling Water System (CCW) shall be OPERABLE with:
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| Two L01
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| : a. Three CCW pumps, and LA01
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| : b. Two CCW heat exchangers.
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| Applicability APPLICABILITY: MODES 1, 2, 3, and 4.
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| ACTION:
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| Required Action B.1 NOTE: Enter applicable ACTIONS of LCO 3.4.1.3, "Reactor Coolant System - Hot Shutdown," for residual heat Note removal loops made inoperable by CCW. L01
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| : a. With only two CCW pumps with independent power supplies OPERABLE, restore the inoperable CCW pump to OPERABLE status within 30 days or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
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| Action B b. With only one CCW pump OPERABLE or with two CCW pumps OPERABLE but not from independent power supplies, restore two pumps from independent power supplies to OPERABLE status within 72 hours or in accordance with the Risk Informed Completion Time Program, or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following Action C 30 hours. Add proposed Required Action C.2 and associated Note L02 one required inoperable Action A c. With less than two CCW heat exchangers OPERABLE, restore two heat exchangers to OPERABLE status within 1 hour or be in HOT STANDBY within the next 6 hours and in COLD Action C SHUTDOWN within the following 30 hours.
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| Add proposed Required Action C.2 and associated Note L02 Add proposed ACTION D SURVEILLANCE REQUIREMENTS A03 4.7.2 The Component Cooling Water System (CCW) shall be demonstrated OPERABLE:
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| LA02
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| : a. In accordance with the Surveillance Frequency Control Program, by verifying that two heat SR 3.7.7.4 exchangers and one pump are capable of removing design basis heat loads.
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| Restore the original CTS text and delete DOC LA02.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-14 AMENDMENT NOS. 287 AND 281 Page 1 of 2
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| ITS A01 ITS 3.7.7 SURVEILLANCE REQUIREMENTS (Continued)
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| Add proposed SR 3.7.7.1 Note A04 SR 3.7.7.1 b. 1) In accordance with the Surveillance Frequency Control Program verify that each valve (manual, power-operated, or automatic) servicing safety-related equipment A05 that is not locked, sealed, or otherwise secured in position is in its correct in the flowpath position.
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| LA02 SR 3.7.7.5 2) In accordance with the Surveillance Frequency Control Program verify by a performance test the heat exchanger surveillance curves.*
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| A05
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| : c. In accordance with the Surveillance Frequency Control Program during shutdown, by verifying that: that is not locked, sealed, or otherwise in the flowpath secured in position L03 SR 3.7.7.2 1) Each automatic valve servicing safety-related equipment actuates to its correct position on a SI test signal, and an actual or simulated actuation L04 SR 3.7.7.3 2) Each Component Cooling Water System pump starts automatically on a SI test signal.
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| SR 3.7.7.3 3) Interlocks required for CCW operability are OPERABLE.
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| A06 Restore the original CTS text and delete DOC LA02.
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| LA02 SR 3.7.7.5
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| *Technical specification 4.7.2.b.2 is not applicable for entry into MODE 4 or MODE 3, provided that:
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| NOTE
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| : 1) Surveillance 4.7.2.b.2 is performed no later than 72 hours after reaching a Reactor Coolant System Tavg of 547°F, and
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| : 2) MODE 2 shall not be entered prior to satisfactory performance of this surveillance.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-15 AMENDMENT NOS. 263 AND 258 Page 2 of 2
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| DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER SYSTEM (CCS) controlled by the Technical Specification Bases Control Program in Chapter 5.
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| This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA02 (Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 4.7.2.a requires verifying that two [CCW] heat exchangers and one [CCW] pump are capable of removing design basis heat loads at a frequency in accordance with the Surveillance Frequency Control Program. CTS 4.7.2.b.2) requires verifying by a performance test the heat exchanger surveillance curves at a frequency in accordance with the Surveillance Frequency Control Program. A footnote modifies the performance of CTS 4.7.2.b.2) stating that technical specification 4.7.2.b.2 is not applicable for entry into MODE 4 or MODE 3, provided that: 1) Surveillance 4.7.2.b.2 is performed no later than 72 hours after reaching a Reactor Coolant System Tavg of 547°F, and 2) MODE 2 shall not be entered prior to satisfactory performance of this surveillance. ITS 3.7.7 does not contain these surveillance requirements.
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| This changes the CTS by removing the CCW heat exchanger performance test surveillances.
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| The removal the of the CCW heat exchanger performance test surveillances from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health and safety. The requirements to maintain the CCW heat exchanger performance is relocated to the Technical Requirements Manual (TRM). The CCW heat exchanger performance test surveillances are surveillances performed to determine when a CCW heat exchanger requires cleaning to ensure the combination of any two CCW heat exchangers are adequate to remove the analyzed heat load and can be adequately controlled in the TRM. Changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a backup nitrogen supply is being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.7.2 states that the Component Cooling Water System (CCW) shall be OPERABLE with: a. Three CCW pumps, and b. Two CCW heat exchangers. In addition, CTS 3.7.2 Action
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| : a. requires that with only two CCW pumps with independent power supplies OPERABLE to restore the inoperable CCW pump to OPERABLE status within 30 days. ITS 3.7.7 states that two CCW trains shall be OPERABLE. This changes the CTS by reducing the number of CCW pumps required to be OPERABLE from three to two and eliminating the associated action requirement to restore a single CCW pump to OPERABLE status within 30 days.
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| The purpose of CTS 3.7.2 is to provide the lowest functional capability or performance levels of equipment required for safe operation of the facility and the Turkey Point Unit 3 and Unit 4 Page 4 of 7
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| CTS CCW System 3.7.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.7.2.b.1) SR 3.7.7.1 -------------------------------NOTE------------------------------
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| Isolation of CCW flow to individual components does not render the CCW System inoperable.
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| Verify each CCW manual, power operated, and [ 31 days 3 automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or OR 3 otherwise secured in position, is in the correct position. In accordance with the Surveillance Frequency Control Program ] 3 4.7.2.c.1) SR 3.7.7.2 Verify each CCW automatic valve in the flow path [ [18] months 3 that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an OR 3 actual or simulated actuation signal.
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| In accordance with the Surveillance Frequency Control Program ] 3 4.7.2.c.2) SR 3.7.7.3 Verify each CCW pump starts automatically on an [ [18] months 3 4.7.2.c.3) actual or simulated actuation signal.
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| OR 3 In accordance with the Surveillance Frequency Control Program ] 3 Add proposed SR 3.7.7.4 Add proposed SR 3.7.7.5 Westinghouse STS 3.7.7-2 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 AMENDMENT Nos. XXX and YYY
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| Proposed SR 3.7.7.4 and SR 3.7.7.5 4.7.2.a SR 3.7.7.4 Verify two CCW heat exchangers and one CCW In accordance pump are capable of removing design basis heat with the loads. Surveillance Frequency Control Program SR 3.7.7.5 ---------------------------NOTE-----------------------------------
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| Not required to be performed until 72 hours after 4.7.2.b.2 reaching Reactor Coolant System Tavg 547°F but 4 and footnore
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| * prior to MODE 2.
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| In accordance Verify the CCW heat exchanger performance curves with the by performance test. Surveillance Frequency Control Program
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| JUSTIFICATION FOR DEVIATIONS ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM
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| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 2. The ISTS is based on a single plant design with two redundant CCW trains consisting of a CCW pump and associated heat exchanger, and a swing pump that can be aligned to either CCW train. The PTN design also includes three CCW pumps but, in addition, includes three CCW heat exchangers downstream of the CCW pumps via a common discharger header. The safety analysis requires two of three heat exchangers and one of three CCW pumps to be OPERABLE to support the safety function. The changes continue to meet the intent of the ISTS requirement and made to align the PTN Technical Specifications, as reasonably practical, with the ISTS. ITS 3.7.7 ACTION A is added to address one of two required heat exchangers inoperable consistent with the CTS Actions. ITS 3.7.7 ACTION D is added to ensure proper application of the ITS in a condition when one required CCW pump is inoperable concurrent with one required CCW heat exchanger. Refer to ISTS 3.5.1, Accumulators, Condition D as an example of this ITS presentation, which has been previously approved and determined acceptable.
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| Subsequent Conditions and Required Actions have been relabeled to reflect the additions and deletions.
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| : 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| Add JFD 4 Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| Proposed JFD 4 JFD 4 CTS 4.7.2.a and CTS 4.7.2.b.2, including footnote *, provide testing requirements for the CCW heat exchangers and CCW pumps. The purpose of CTS 4.7.2.a is to ensure the CCW System is capable of removing design basis heat loads and the purpose of CTS 4.7.2.b.2 is to quantify the effectiveness of the CCW heat exchangers by performance testing. ITS SR 3.7.7.4 and SR 3.7.7.5 retain the CTS requirements. The testing required by CTS 4.7.2.a and CTS 4.7.2.b.2 and associated frequency are the same as those required by ITS SR 3.7.7.4 and ITS SR 3.7.7.5, respectively. Therefore, no technical change is being proposed.
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| CCW System B 3.7.7 BASES SURVEILLANCE REQUIREMENTS (continued) administrative controls. [ The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when 2 performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
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| OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| SR 3.7.7.3 This SR verifies proper automatic operation of the CCW pumps on an actual or simulated actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. [ The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when 2 performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
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| OR INSERT 7 1 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| Insert SR 3.7.7.4 and SR 3.7.7.5 Bases Westinghouse STS B 3.7.7-5 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| SR 3.7.7.4 and SR 3.7.7.5 Bases Insert SR 3.7.7.4 This SR verifies CCW System OPERABILITY by ensuring that sufficient cooling capacity is available for the continued operation of safety-related equipment during normal and accident conditions by demonstrating the systems ability to remove the design basis heat loads assumed in the safety analysis. The redundant cooling capacity of this system, assuming a single active failure, is consistent with the assumptions used in the safety analyses. One pump and two heat exchangers provide the heat removal capability for accidents that have been analyzed.
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| The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| SR 3.7.7.5 This SR verifies CCW System OPERABILITY by specifically verifying CCW heat exchanger performance is within the heat exchanger surveillance curve limits by performance testing. The performance test allows for quantification of the effectiveness of the CCW heat exchangers and provides assurance that the heat exchangers can provide sufficient cooling capacity during normal and accident conditions. Because CCW heat exchanger effectiveness can be affected over time by fouling (i.e., tube resistance), CCW heat exchanger performance is monitored to ensure the CCW heat exchangers can perform their intended function and at their credited analysis capacity during normal and accident conditions. CCW heat exchanger performance monitoring consists of performing SR 3.7.7.4 and SR 3.7.7.5 within their required Frequencies and heat exchanger cleaning to evaluate CCW heat exchanger performance when fouling of the heat exchangers is taken into consideration. 5 SR 3.7.7.5 is modified by a Note that specifies the surveillance is not required to be performed until 72 hours after Reactor Coolant System average temperature reaches 547° F but prior to entering MODE 2. This allows a delay of testing to establish conditions consistent with those under which the acceptance criterion was generated. However, the SR must be met within its Frequency prior to reactor operation in MODE 2.
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| Data is collected at a Frequency determined by the Surveillance Frequency Control Program to determine heat exchanger fouling at the corresponding conditions and a maximum ultimate heat sink (UHS) temperature. The performance test conservatively allows for tube resistance above the fouling factor used in the DBA safety analyses when the actual UHS temperature is lower than the maximum temperature allowed in the DBA safety analyses. A heat exchanger performance software program computes an overall heat transfer coefficient with the corresponding fouling (tube resistance) to determine a maximum allowed intake cooling water temperature for those conditions. If the maximum allowable UHS temperature (Specification 3.7.9, "Ultimate Heat Sink (UHS)") limit is maintained, the CCW heat exchanger performance meets the heat transfer required by the DBA safety analysis.
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| The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| SR 3.7.7.4 and SR 3.7.7.5 in conjunction with Specification 3.7.9 limit on UHS temperature ensures that sufficient cooling capacity is available to provide for normal cooldown of the facility, or to mitigate the effects of accident conditions within acceptable limits.
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| JUSTIFICATION FOR DEVIATIONS ITS 3.7.7 BASES, COMPONENT COOLING WATER (CCW) SYSTEM
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| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. Where a deletion has occurred, subsequent alphanumeric designators have been changed for any applicable affected Required Actions, Surveillance Requirements, Functions, and Footnotes.
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| : 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
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| Add JFD 5 Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| JFD 5 Insert JFD 5 CTS 4.7.2.a requires CCW System testing that verifies the capability to remove the design basis heat loads assumed in the safety analyses. CTS 4.7.2.b.2 requires verification by performance test that the CCW heat exchangers are capable of performing within the established heat exchanger surveillance curves when considering heat exchanger fouling (tube resistance). This is a periodic quantification of the effectiveness of CCW heat exchanger effectiveness to ensure the heat exchangers can provide the required cooling during normal and accident conditions.
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| ITS 3.7.7 adds SR 3.7.7.4 and SR 3.7.7.5 to require testing of the component cooling water system (heat exchanges and pumps) and testing of the effectiveness of the heat exchangers specifically when fouling is considered. The testing required by CTS 4.7.2.a and CTS 4.7.2.b.2 are the same as those required by ITS SR 3.7.7.4 and SR 3.7.7.5, respectively. Therefore, current technical specification requirements are being retained and no technical change is being proposed.
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| 7/6/22, 11:16 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1459 NRC Question JMW048 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/6/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/6/2022 9:51 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1459 1/1
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| 5/20/22, 11:45 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 615 NRC Question JMW049 Number Category Technical ITS 3.7 Section ITS 3.7.5 Number DOC Number JFD Number JFD Bases Number Page 97, 111, 113 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC CTS 4.7.1.2.1.a.1 states in part The provisions of Specification 4.0.4 are not applicable for entry into Question MODES 2 and 3. ITS 3.7.5 adds a note for equivalent SRs 3.7.5.2 and 3.7.5.6 which states Only required to be performed in MODE 1. This change does not appear to be specifically addressed in the DOCs. Please evaluate and make necessary corrections.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:36 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=615 1/1
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| 8/14/22, 9:50 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1339 NRC Question JMW049 Number Select Licensee Response Application Attachment Attachment 1 - JMW049 LAR Markups.pdf (2MB) 1 Attachment 2
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| Response This change is an ITS presentation change and addressed by ITS 3.7.5 Discussion of Change (DOC) A01, Statement which states in part, certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, Standard Technical Specifications - Westinghouse Plants (ISTS). To further describe how the CTS requirement is equivalent to the ITS presentation as described in ITS Section 1.4, Frequency, a new administrative DOC will be added to the ITS 3.7.5 DOCs as stated below to explain this change. See Attachment 1 - JMW049 LAR Markups.
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| A03 CTS 4.7.1.2.1.a.1 requires verifying each steam turbine-driven pump operates for 15 minutes or greater and develops a flow of greater than or equal to 373 gpm. CTS 4.7.1.2.1.a.2 requires verifying that the auxiliary feedwater discharge valves and the steam supply and turbine pressure valves operate as required to deliver the required flow during the pump performance test required by CTS 4.7.1.2.1.a.1. CTS 4.7.1.2.1.a.1 states that the provisions of Specification 4.0.4 are not applicable for entry into MODES 2 and
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| : 3. ITS SR 3.7.5.2 (CTS 4.7.1.2.1.a.1) and SR 3.7.5.6 (CTS 4.7.1.2.1.a.2) require pump flow testing and valve operational testing, respectively, and contain a similar Note that states, "Only required to be performed in MODE 1." This changes the CTS by revising the presentation of the CTS 4.0.4 exception.
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| CTS 4.0.4 (ITS SR 3.0.4) requires the normal periodic Surveillances to be performed and be current prior to entry into the applicable MODES. CTS 3.7.1.2 (ITS LCO 3.7.5) is Applicable in MODES 1, 2, and 3. The CTS 4.0.4 exception allows entry into MODES 2 and 3 to perform CTS 4.7.1.2.1.a.1(ITS SR 3.7.5.2). The CTS 4.0.4 exception also applies to CTS 4.7.1.2.1.a.2 (ITS SR 3.7.5.6) because CTS 4.7.1.2.1.a.2 is required to be performed during performance of CTS 4.7.1.2.1.a.1. The Note to ITS SRs 3.7.5.2 and 3.7.5.6 is functionally equivalent to the CTS 4.0.4 exception of CTS 4.7.1.2.1.a.1 and 4.7.1.2.1.a.2 and does not represent a technical change to the CTS. The ITS Note presentation that only requires the SR to be performed in MODE 1 is explained in ITS Section 1.4, Example 1.4-5 and states, in part, this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance. This change in presentation is designated as administrative as it results in no technical change to the CTS.
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| Attachment
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| : 1. JMW049 LAR Markups
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| ===Response===
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| 6/29/2022 12:15 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/29/2022 11:16 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1339 1/1
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| ITS A01 ITS 3.7.5 PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM SURVEILLANCE REQUIREMENTS 4.7.1.2.1 The required independent auxiliary feedwater trains shall be demonstrated OPERABLE:
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| : a. In accordance with the Surveillance Frequency Control Program by:
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| LA02 SR 3.7.5.2 1) Verifying by control panel indication and visual observation of equipment that each steam Only required to be performed in MODE 1. turbine-driven pump operates for 15 minutes or greater and develops a flow of greater than or equal to 373 gpm to the entrance of the steam generators. The provisions of SR 3.7.5.2 Note, Specification 4.0.4 are not applicable for entry into MODES 2 and 3; A03 SR 3.7.5.6 Note SR 3.7.5.6 2) Verifying by control panel indication and visual observation of equipment that the auxiliary feedwater discharge valves and the steam supply and turbine pressure valves operate as required to deliver the required flow during the pump performance test above; manual and power operated A01 SR 3.7.5.1 3) Verifying that each non-automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in its correct position; and L02
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| : 4) Verifying that power is available to those components which require power for flow path operability.
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| : b. In accordance with the Surveillance Frequency Control Program by:
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| SR 3.7.5.3 1) Verifying that each automatic valve in the flow path actuates to its correct position upon receipt of each Auxiliary Feedwater Actuation test signal, and on an actual or simulated actuation L03 SR 3.7.5.4 2) Verifying that each auxiliary feedwater pump receives a start signal as designed automatically upon receipt of each Auxiliary Feedwater Actuation test signal.
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| Add proposed SR 3.7.5.4 Note L04 SR 3.7.5.5 4.7.1.2.2 An auxiliary feedwater flow path to each steam generator shall be demonstrated OPERABLE following each COLD SHUTDOWN of greater than 30 days prior to entering MODE 1 by verifying normal flow to each steam generator.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-4 AMENDMENT NOS. 273 AND 268 Page 2 of 3
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| DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 CTS 3.7.1.2 Actions 2) and 4) provide directions to follow other Actions if specified conditions are not met. Action 2) states, in part, to either restore both trains to OPERABLE status or restore one train to OPERABLE status and follow ACTION statement 1 above for the other train. Action 4) states, in part, to verify OPERABILITY of two independent steam supply flowpaths or follow ACTION statement 1 or 2 above as applicable. ITS 3.7.5 does not contain these directions to follow other ACTION statements if specified conditions are not met.
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| This changes the CTS by not including direction to follow other Actions.
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| The purpose of these CTS 3.7.1.2 statements is to ensure all applicable Actions are entered based on the specific plant conditions at the time. ITS Section 1.3, Completion Times, states that if situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. This is reiterated in ITS LCO 3.0.2 which states that upon discovery a failure to meet an LCO, the Required Actions of the associated Conditions [multiple Conditions] shall be met. Therefore, in ITS if two trains are inoperable there is also one train inoperable and both Conditions are entered or if a steam supply is inoperable and the remaining two are not independent the unsupported train is considered inoperable. This change is acceptable because the Required Actions specified in CTS will continue to be taken in ITS in accordance with the ITS rules of usage. This change is considered administrative because no technical changes are being made to the CTS.
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| Insert DOC A03 MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None Turkey Point Unit 3 and Unit 4 Page 1 of 5
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| DOC A03 insert A03 CTS 4.7.1.2.1.a.1 requires verifying each steam turbine-driven pump operates for 15 minutes or greater and develops a flow of greater than or equal to 373 gpm. CTS 4.7.1.2.1.a.2 requires verifying that the auxiliary feedwater discharge valves and the steam supply and turbine pressure valves operate as required to deliver the required flow during the pump performance test required by CTS 4.7.1.2.1.a.1. CTS 4.7.1.2.1.a.1 states that the provisions of Specification 4.0.4 are not applicable for entry into MODES 2 and 3. ITS SR 3.7.5.2 (CTS 4.7.1.2.1.a.1) and SR 3.7.5.6 (CTS 4.7.1.2.1.a.2) require pump flow testing and valve operational testing, respectively, and contain a similar Note that states, "Only required to be performed in MODE 1." This changes the CTS by revising the presentation of the CTS 4.0.4 exception.
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| CTS 4.0.4 (ITS SR 3.0.4) requires the normal periodic Surveillances to be performed and be current prior to entry into the applicable MODES. CTS 3.7.1.2 (ITS LCO 3.7.5) is Applicable in MODES 1, 2, and 3. The CTS 4.0.4 exception allows entry into MODES 2 and 3 to perform CTS 4.7.1.2.1.a.1(ITS SR 3.7.5.2). The CTS 4.0.4 exception also applies to CTS 4.7.1.2.1.a.2 (ITS SR 3.7.5.6) because CTS 4.7.1.2.1.a.2 is required to be performed during performance of CTS 4.7.1.2.1.a.1. The Note to ITS SRs 3.7.5.2 and 3.7.5.6 is functionally equivalent to the CTS 4.0.4 exception of CTS 4.7.1.2.1.a.1 and 4.7.1.2.1.a.2 and does not represent a technical change to the CTS. The ITS Note presentation that only requires the SR to be performed in MODE 1 is explained in ITS Section 1.4, Example 1.4-5 and states, in part, this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance. This change in presentation is designated as administrative as it results in no technical change to the CTS.
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| 7/6/22, 11:17 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1455 NRC Question JMW049 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/6/2022 9:49 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1455 1/1
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| 5/20/22, 11:47 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 619 NRC Question JMW050 Number Category Technical ITS 3.7 Section ITS 3.7.5 Number DOC L-4 Number JFD Number JFD Bases Number Page 103, 112, 131 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS SR 3.7.5.4 is modified by a note that states Only required to be performed in MODE 1. ITS 3.7.5 L04 Question states in part Thus, the CTS SR is modified indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test verifying TDAFW pump OPERABILITY. The Bases for SR 3.7.5.4 states: This SR is modified by a Note. The Note indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test. The text of the corresponding NOTE in STS appears as Not required to be performed for the turbine driven AFW pump until [24 hours]
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| after [1000] psig in the steam generator. Verify that there are only suitable test conditions in Mode 1 to perform this test and provide information for why the proposed note replaced the STS NOTE for this SR.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:40 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=619 1/1
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| 8/3/22, 5:37 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1411 NRC Question JMW050 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response The proposed Note Only required to be performed in MODE 1 does not mean that the SR is only to be Statement performed in MODE 1, rather, it waives the SR 3.0.4 requirement to have performed the SR prior to entering the Applicability of ITS 3.7.5 (i.e., MODE 3), allowing entry into MODES 2 and 3 to perform the test prior to entry into MODE 1. The application of the proposed Note to SR 3.7.5.4 is discussed in ITS Section 1.4, Frequency, Example 1.4-5 and states, in part, this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance. Therefore, the proposed Note to ITS SR 3.7.5.4 allows entry into MODES 2 and 3 to perform the test consistent with ITS SR 3.7.5.2 and SR 3.7.5.6, which verifies auxiliary feedwater (AFW) pump flowrate and valve operation to deliver the required flow.
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| The subject Note is consistent with the proposed Note to SR 3.7.5.2, and both differ from the Note in ISTS SR 3.7.5.2 and Note 1 to ISTS SR 3.7.5.4 due to the design difference between PTN and the standard Westinghouse AFW design. The standard Westinghouse design consists of a single 200% turbine driven AFW (TDAFW) pump. Therefore, [24] hours after reaching [1000] psig in the steam generator provides adequate time to perform the required tests for a single TDAFW train. The PTN AFW System design consists of three 100% capacity TDAFW pumps shared between two units. The time required to perform this test along with the other required tests on three TDAFW pumps after suitable conditions are established is longer than the standard 24 hours after reaching 1000 psig in the stream generators specified in the ISTS. PTN usually performs these tests while in MODE 2, this allows for reactor coolant pump heat and heat from a critical reactor to minimize the cooldown recovery period caused by the AFW flow to the steam generators during the testing. As a result, the proposed Note to ITS SR 3.7.5.4 is maintained consistent with the allowance specified in CTS 4.7.1.2.1.a.1 as presented in ITS SR 3.7.5.2, which is a MODEdependent allowance instead of a timedependent allowance; Note 1 in ISTS SR 3.7.5.4 would allow entry into MODE 1 if within 24 hours of reaching adequate pressure in the steam generator.
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| Therefore, because the time required to perform the required testing on the TDAFW pumps can vary depending on how many TDAFW pumps require testing, the number of tests required, and plant recovery period from a cooldown due to AFW steam flow, the Note to ITS SR 3.7.5.4 will continue to allow time to perform the required testing on the TDAFW pumps after suitable conditions are established to perform the test provided testing is completed within the specified Frequency for each required AFW pump before entering MODE 1.
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| ===Response===
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| 7/1/2022 12:30 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/1/2022 11:32 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1411 1/1
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| 7/15/22, 1:44 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1598 NRC Question JMW050 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/15/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/15/2022 12:44 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1598 1/1
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| 5/20/22, 2:34 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 623 NRC Question JMW051 Number Category Editorial ITS Section 3.7 ITS Number 3.7.5 DOC Number JFD Number JFD Bases Number Page 112, 133 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC The Bases for SR 3.7.5.6 does not include a description of the ITS note included in ITS SR 3.7.5.6 which Question states Only required to be performed in MODE 1. Please evaluate and make necessary corrections.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:42 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=623 1/1
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| 8/3/22, 5:55 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1351 NRC Question JMW051 Number Select Licensee Response Application Attachment 1 Attachment 1 - JMW051 LAR Markup.pdf (660KB)
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| Attachment 2 Response FPL will include a description of the Note to SR 3.7.5.6 in Insert 8 of the ITS 3.7.5 Bases markup. See Statement attached JMW051 LAR markup.
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| Attachment
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| : 1. JMW051 LAR Markup
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| ===Response===
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| 6/29/2022 12:45 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 6/29/2022 11:43 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1351 1/1
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| ITS 3.7.5 1
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| INSERT 8 SR 3.7.5.6 This SR verifies that the AFW discharge valves and the steam supply and turbine pressure valves operate as required. Check valves in the AFW System that require full stroke testing under limiting flow conditions are tested in accordance with the INSERVICE TESTING PROGRAM. Proper functioning of the turbine admission valve and the operation of the pumps will demonstrate the integrity of the system. Verification of correct operation will be made both from instrumentation within the Control Room and direct visual observation of the pumps.
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| The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| This SR is modified by a Note that allows entry into and operation in MODES 2 and 3 prior to the surveillance being performed. This allows establishment of adequate steam generator pressure and flow to perform the test.
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| Insert Page B 3.7.5-11
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| 7/6/22, 11:17 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1451 NRC Question JMW051 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/6/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/6/2022 9:47 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1451 1/1
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| 5/20/22, 2:36 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 627 NRC Question Number JMW052 Category Editorial ITS Section 3.7 ITS Number 3.7.10 DOC Number JFD Number JFD Bases Number Page Number(s) 261 NRC Reviewer Supervisor Victor Cusumano Technical Branch POC Add Name Conf Call Requested N NRC Question ITS Action G states Two CREV trains Verify if this should be CREVS trains and correct.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:43 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=627 1/1
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| 8/14/22, 9:56 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 587 NRC Question JMW052 Number Select Licensee Response Application Attachment 1 Attachment 1 - JMW052 LAR Markups.pdf (681KB)
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| Attachment 2 Response FPL will revise ITS 3.7.10, ACTION G, to change the acronym reference to "CREVS." See attached Statement JMW052 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW052 LAR Markups
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| ===Response===
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| 5/30/2022 3:10 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date Added 5/30/2022 2:12 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=587 1/1
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| ITS 3.7.10 CTS INSERT 2 3 E. ------------NOTES----------- E.1 Be in MODE 3. 12 hours Only applicable when a dual unit shutdown is AND required.
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| ACTIONs a.1, a.3, -------------------------------- E.2 -------------NOTE----------------
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| a.4, a.6, a.7, & b Required Action and LCO 3.0.4.a is not associated Completion applicable when entering Time of Condition A, B, MODE 4.
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| or C not met. -------------------------------------
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| Be in MODE 4. 18 hours 1
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| S INSERT 3 G. Two CREV trains G.1 Place one CREVS train in Immediately DOC M01 inoperable due to normal recirculation mode.
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| outside air intake isolated.
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| H. Two CREVS trains H.1 Place compensatory 24 hours ACTION a.5 inoperable in MODE 1, filtration unit in service.
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| 2, 3, or 4 for reasons other than Condition C or G.
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| DOC A02 I. Two or more control I.1 Enter LCO 3.0.3. Immediately room AHUs inoperable in MODE 1, 2, 3, or 4.
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| OR Required Action and associated Completion Time of Condition G or H not met.
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| Insert Page 3.7.10-2
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| 6/9/22, 3:35 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1087 NRC Question JMW052 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/9/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/9/2022 10:14 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1087 1/1
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| 5/20/22, 2:37 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 631 NRC Question JMW053 Number Category Technical ITS Section 3.7 ITS Number 3.7.10 DOC Number JFD Number JFD Bases Number Page 260, 262 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call N
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| Requested NRC Question ITS Actions F, J, K do not appear to have a discussion of changes or direct equivalent CTS actions.
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| Please evaluate and provide justification for these changes.
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| Attach File 1 Attach File 2 Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date Added 5/19/2022 2:44 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=631 1/1
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| 8/3/22, 5:33 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1423 NRC Question JMW053 Number Select Licensee Response Application Attachment Attachment 1 - JMW053 LAR Markups.pdf (2MB) 1 Attachment 2
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| Response ITS 3.7.10, ACTIONS F, J and K, are provided to be consistent with the ISTS presentation, which separates Statement the CTS 3.7.5 Action requirements between MODES 1, 2, 3, and 4; and MODES 5 and 6 and during movement of irradiated fuel assemblies.
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| ITS 3.7.10, Required Action F.2, as identified in the CTS markup, is equivalent to the action to immediately suspend movement of irradiated fuel assemblies specified in CTS 3.7.5, Actions a.1 and a.3. The action to immediately suspend movement of irradiated fuel assemblies is the only action in CTS 3.7.5, Actions a.1 and a.3, that would be required when the unit is in a MODE or condition other than MODE 1, 2, 3, or 4 since the end state for CTS Actions a.1 and a.3 is Cold Shutdown (MODE 5). Therefore, Condition F is provided to address the situation of the Required Actions of ITS 3.7.10, Condition A (one air handling unit (AHU) inoperable) and Condition B (one Control Room Emergency Ventilation System (CREVS) train inoperable),
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| not met when in MODE 5 or 6 or during movement of irradiated fuel assemblies. The reference to Condition C in Condition F is not applicable in MODES 5 and 6 and during movement of irradiated fuel assemblies.
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| Therefore, Condition F will be revised to state, "Required Action and associated Completion Time of Condition A or B not met in MODE 5 or 6, or during movement of irradiated fuel assemblies." Required Actions F.1.1 and F.1.2, which are consistent with the intent of the ISTS and similar to CTS 3.7.5, Actions a.4, a.6, and a.7, are proposed to be added as an option to suspending movement of irradiated fuel assemblies. A new less restrictive Discussion of Change (DOC) L06 will be added to address Required Actions F.1.1 and F.1.2. See attached JMW053 license amendment request (LAR) markups for changes to CTS markup, ITS 3.7.10 Condition F (and Bases) markup, and new DOC L06.
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| The second Condition of ITS 3.7.10, ACTION J, is consistent with the third paragraph of CTS 3.7.5, Action
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| : b. The first Condition of ITS 3.7.10, ACTION J, is appropriate since there are no CTS 3.7.5 Actions defined for two or more AHUs inoperable and CTS 3.0.3 does not apply in MODE 5 or 6. A more restrictive DOC M02 will be added to address proposed Required Action J.1 to the condition when two or more AHUs are inoperable in MODE 5, or 6, or during movement of irradiated fuel assemblies. See attached JMW053 LAR Markups for changes to CTS markup, ITS 3.7.10 Condition J (and Bases) markup, and new DOC M02.
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| The first Condition of ITS 3.7.10, ACTION K, is provided consistent with CTS 3.7.5, Action a.5, in conditions other than MODES 1, 2, 3, and 4. ITS 3.7.10, Required Actions K.1 and K.2, as identified in the CTS markup, are equivalent to the action to immediately suspend movement of irradiated fuel assemblies and immediately initiate action to place the compensatory filtration unit in service. After the compensatory filtration unit is verified in service, CTS 3.7.5, Action a.5, allows movement of irradiated fuel assemblies to resume. ITS 3.7.10, ACTION K, simplifies these actions when in MODE 5 or 6 or during movement of irradiated fuel assemblies to either immediately place the compensatory filtration unit in service or immediately suspend movement of irradiated fuel assemblies. These simplified actions have the same effect as the CTS action of immediately suspending movement of irradiated fuel assemblies until the compensatory filtration unit is placed in service and proper operation verified. The second Condition of ITS 3.7.10, ACTION K, provides actions when the Required Action and associated Completion Time of proposed Condition G cannot be met in MODE 5, 6, or during movement of irradiated fuel assemblies. ITS 3.7.10, ACTION G, is a new proposed ACTION and discussed in ITS 3.7.10, DOC M01. ITS 3.7.10, DOC M01, will be revised to also address the second Condition of ITS 3.7.10, ACTION K. See attached JMW053 LAR markups for changes to CTS markup, ITS 3.7.10 (and Bases) markup, and revised DOC M01.
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| Additionally, the ITS references to ACTIONS G, J, and F.2 in the CTS markup associated with CTS 3.7.5, Action a.5, are revised to correctly reference ITS 3.7.10, ACTIONS H and K.
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| Attachment
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| : 1. JMW053 LAR Markups
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| ===Response===
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| 7/1/2022 1:10 PM Date/Time Closure Statement https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1423 1/2
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| 8/3/22, 5:33 PM Turkey Point ITS Conversion Database Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/1/2022 12:09 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1423 2/2
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| ITS A01 ITS 3.7.10 PLANT SYSTEMS (CREVS) 3.7.10 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM A01 LIMITING CONDITION FOR OPERATION Two CREVS trains LCO 3.7.10 3.7.5 The Control Room Emergency Ventilation System shall be OPERABLE* with:
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| A02 AND control room
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| : a. Three air handling units, (AHUs) shall be OPERABLE See ITS 3.7.11
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| : b. Two condensing units,
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| : c. Two control room recirculation fans,
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| : d. Two recirculation dampers,
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| : e. One filter train, LA01
| |
| : f. Two isolation dampers in the normal outside air intake duct,
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| : g. Two isolation dampers in the emergency outside air intake duct,
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| : h. Control Room Envelope APPLICABILITY APPLICABILITY: MODES 1, 2, 3, 4, 5 and 6 or during movement of irradiated fuel assemblies.
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| ACTION:`
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| ACTION A a.1 With one air handling unit inoperable, within 7 days, restore the inoperable air handling unit to ACTION F.2 OPERABLE status or, immediately suspend all movement of irradiated fuel and be in at least HOT ACTION D & Condition Note STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD ACTION E Condition Note SHUTDOWN within the following 30 hours.
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| Add proposed Required Actions D.2, E.2 and Note L01 a.2 With only one OPERABLE condensing unit, within 30 days, restore at least one of the inoperable See ITS condensing units to OPERABLE status or, immediately suspend all movement of irradiated fuel and 3.7.11 be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| ACTION B a.3 With one recirculation fan inoperable, within 7 days, restore the inoperable fan to OPERABLE ACTION F.2 status or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY ACTION D & Condition Note within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within ACTION E & Condition Note the following 30 hours.
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| Add proposed Required Actions D.2, E.2 and Note L01 Add proposed RA F.1.1 and F.1.2 L06 LCO 3.7.10 Note *The Control Room Envelope (CRE) boundary may be opened intermittently under administrative control.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-18 AMENDMENT NOS. 275 AND 270 Page 1 of 4
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| ITS A01 ITS 3.7.10 PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued)
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| L05 a.4 With one recirculation damper inoperable, within 7 days, restore the inoperable damper to OPERABLE status or, place and maintain at least one of the recirculation dampers in the open H
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| position and place the system in recirculation mode or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| a.5 With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable recirculation fans, ACTION G ACTION J and/or two inoperable recirculation dampers, immediately suspend all movement of irradiated fuel ACTION K and immediately initiate action to place the compensatory filtration unit in service and verify proper L02 ACTIONS G and J operation within 24 hours, following which movement of irradiated fuel may resume, and within 7 ACTION B days, restore the filter train to OPERABLE status.
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| ACTION F.2 ACTION K.2 ACTION D & Condition Note With the above requirements not met, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| L01 ACTION E & Condition Note Add proposed Required Actions D.2, E.2 and Note a.6 With an inoperable damper in the normal outside air intake, within 7 days, restore the inoperable damper to OPERABLE status or, place and maintain at least one of the normal outside air intake isolation dampers in the closed position and place the system in recirculation mode or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| L05 a.7 With an inoperable damper in the emergency outside air intake, within 7 days, restore the inoperable damper to OPERABLE status or, place and maintain at least one of the emergency outside air intake isolation dampers in the open position or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| L05 Add proposed ACTION G M01 TURKEY POINT - UNITS 3 & 4 3/4 7-19 AMENDMENT NOS. 275 AND 270 Page 2 of 4
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| | |
| ITS A01 ITS 3.7.10 PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued)
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| ACTION C b. With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary during MODES 1, 2, 3 or 4, immediately initiate action to implement mitigating actions.
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| Within 24 hours, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits, and CRE occupants are protected from smoke hazards, and restore CRE boundary to OPERABLE status within 90 days.
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| ACTION D& Condition Note With the above requirements not met, be in at least HOT STANDBY within the next 6 hours for L01 ACTION E & Condition Note one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| MODE 4 6 A03 With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE ACTION J boundary during MODES 5, 6 or during the movement of irradiated fuel assemblies, immediately suspend all movement of irradiated fuel.
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| or two or more AHUs inoperable M02 Add proposed ACTION I A02 SURVEILLANCE REQUIREMENTS 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:
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| See ITS a. In accordance with the Surveillance Frequency Control Program by verifying that the control room 3.7.11 air temperature is less than or equal to 120°F;
| |
| : b. In accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at SR 3.7.10.1 least 15 minutes**;
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| : c. In accordance with the Surveillance Frequency Control Program or (1) after 720 hours of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, See ITS or (3) following exposure of the filters to effluents from painting, fire, or chemical release in any 5.5.8 ventilation zone communicating with the system that may have an adverse effect on the functional SR 3.7.10.2 capability of the system, or (4) after complete or partial replacement of a filter bank by:
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| **As the mitigation actions of TS 3.7.5 Action a.5 include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room and TS LA02 4.7.5.c, d and f.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-20 AMENDMENT NOS. 275 AND 270 Page 3 of 4
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| | |
| M02 CTS 3.7.5 does not contain an Action addressing two or more inoperable AHUs in DISCUSSION OF CHANGES MODE 5, or 6, or ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) during movement of irradiated fuel assemblies.
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| Therefore, the first The purpose of the CTS 3.7.4, ACTION b, is to ensure prompt Action is taken to condition described restore the CREVS to an OPERABLE status within the specified Completion in ITS 3.7.10, ACTION J, is Times. The Notes described above conservatively allow only one unit in a dual modified to address unit shutdown event to apply the 12-hour Completion Time to reach MODE 3.
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| this configuration. This change is intended to provide clarity with respect to the different CTS This changes the CTS by providing Completion Times which depend on the CREVS. The described Notes and specific action addition of proposed Condition E is consistent with the CTS in that the 12-hour requirements Completion Time is only applicable during dual unit shutdown conditions. This associated with two change is considered Administrative as no technical changes are being made to or more inoperable the CTS. If ITS 3.7.10 Required Action G.1 cannot be performed within its AHUs inoperable in MODE 5, or 6, or associated Completion Time, ITS 3.7.10 ACTION I will apply when the during movement of unit is in MODE 1, 2, 3, or 4 and ITS 3.7.10 ACTION K will apply when irradiated fuel MORE RESTRICTIVE CHANGES the unit is in MODE 5 or 6 or during movement of irradiated fuel assemblies.
| |
| assemblies.
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| The purpose of the CTS actions is to M01 CTS 3.7.5 Action a.4, one recirculation damper inoperable and a.6, an inoperable ensure the control room envelop damper in the normal outside air intake require, in part, to place the CREVS in boundary and the recirculation mode. ITS 3.7.10 ACTION G requires that with two CREVS filtration functions are trains inoperable due to normal outside air intake isolated to immediately place maintained when redundant CREVS one CREVS train in the recirculation mode. This changes the CTS by replacing components, specific action requirements associated with an inoperable recirculation or intake isolation, or actuation damper in the CREVS with a requirement to place the CREVS in the recirculation capability is lost. The CREVS design mode if both CREVS trains are inoperable due to normal outside air intake requires two of the isolated.
| |
| three AHUs to be in service to support the CREVS recirculation The purpose of the CTS actions is to ensure the control room envelop boundary mode of operation. and filtration function are maintained when redundant isolation or actuation With two or more capability is lost on the CREVS. The CREVS design includes dual dampers on AHUs inoperable, the the normal intake, the emergency intake, and the recirculation ducting to ensure recirculation function cannot be met. An these penetrations are isolated and proper actuation in the event of an accident appropriate action for requiring control room habitability. The required dampers are powered and this level of actuated from redundant trains. When one required damper in the normal air degradation in MODE 5, or 6, or intake duct is closed both intake radiation monitors are isolated unable to detect during movement of an increase in external radiation levels, potentially preventing CREVS actuation irradiated fuel when needed. An appropriate action for this level of degradation is to declare assemblies is immediately suspend both CREVS intake radiation monitors inoperable causing the CREVS to be the movement of placed in the recirculation mode in accordance with LCO 3.3.4, "Control Room irradiated fuel Emergency Ventilation System (CREVS) Actuation Instrumentation." This assemblies, since LCO 3.0.3 is not change is acceptable because actions retained in the ITS continue to ensure applicable in MODES redundant capability is restored or the safety related function is performed.
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| 5 or 6. This change These remedial actions are consistent with safe operation under the specified is acceptable because actions in Condition, considering the OPERABLE status of the redundant dampers and the the ITS continue to low probability of a DBA occurring during this condition. This change is ensure appropriate designated as more restrictive because the CREVS will be placed in the measures are taken until the safety recirculation mode sooner in ITS (immediately) than in CTS (7 days).
| |
| related function is Because the only DBA associated with operation in MODE 5, or 6, or restored. during movement of irradiated fuel assemblies is a fuel handling RELOCATED SPECIFICATIONS accident (FHA), the proposed ACTION, requiring the suspension of the movement of irradiated fuel assemblies removes the potential for an FHA. This change is designated as more restrictive because the None movement of irradiated fuel assemblies will now be suspended upon the loss of two or more AHUs in MODE 5, or 6, or during movement of irradiated fuel assemblies.
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| Turkey Point Unit 3 and Unit 4 Page 2 of 7
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| | |
| DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) requires CREVS components to actuate on a containment isolation signal, which includes automatic isolation valves. ITS SR 3.7.10.3 requires similar testing with an exception for dampers and valves that are locked, sealed, or otherwise secured in the actuated position. Therefore, the exception in the SR effectively allows continued operation when one or more dampers inoperable, provided the dampers are locked, sealed, or otherwise secured in the actuated position. This change is acceptable because actions retained in the ITS continue to ensure redundant capability is restored or the safety related function is performed.
| |
| These remedial actions, including the exception provided in ITS SR 3.7.10.3, are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant dampers and the low probability of a DBA occurring during this condition. This change is designated as less restrictive because removal of the CTS actions allows restoration of the damper's capability to be controlled by other ITS 3.7.10 actions, which are less restrictive and allows more than one isolation damper per air duct to be inoperable provided the safety related function is performed.
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| L06 (Category 4 - Relaxation of Required Action) CTS 3.7.5, Actions a.1 and a.3, require the suspension of the movement of irradiated fuel assemblies immediately if required AHUs or recirculation fans are not restored to OPERABLE status within 7 days.
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| ITS 3.7.10, Required Actions F.1.1 and F.1.2, permit placing the control room in the recirculation mode of operation with at least two AHUs operating as an option to suspending the movement of irradiated fuel (ITS 3.7.10, Required Action F.2). This changes the CTS by providing optional action requirements when required AHUs or recirculation fans are not restored to OPERABLE status within 7 days during operation in MODES 5 or 6, or during the movement of irradiated fuel assemblies.
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| The purpose of the CTS actions is to ensure the control room envelop boundary and filtration function are maintained when redundant CREVS components, isolation, or actuation capability is lost. The CREVS safety function is based on limiting radiological dose to the control room operators following a DBA. The safety function is accomplished by placing the control room in the recirculation mode of operation with the appropriate number of AHUs in operation. In MODES 5 and 6, and during the movement of irradiated fuel assemblies, the only associated DBA is the fuel handling accident (FHA). CTS 3.7.5, Actions a.1 and a.3, remove the potential of an FHA by requiring the suspension of irradiated fuel assemblies. However, placing the control in the recirculation mode of operation with at least two AHUs in operation will also ensure the potential radiological dose to the control room operators will remain within safety analyses limits should an FHA occur. Therefore, the addition of the ITS 3.7.10, Required Actions F.1.1 and F.1.2, options of placing the control in the recirculation mode of operation with at least two AHUs in operation provides the required radiological protection of the control room operators assumed in the accident analyses. This change is acceptable because the safety function is met by performance of proposed ITS 3.7.10, Required Actions F.1.1 and F.1.2, or Required Action F.2, during operation in MODES 5 or 6, or during the movement of irradiated fuel assemblies. This change is designated as less restrictive because optional actions are proposed in lieu of the CTS actions.
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| Turkey Point Unit 3 and Unit 4 Page 7 of 7
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| V CREFS 1 3.7.10 CTS 3.7 PLANT SYSTEMS Ventilation V 1 3.7.5 3.7.10 Control Room Emergency Filtration System (CREFS) 3 AND LCO 3.7.5 LCO 3.7.10 Two CREFS trains shall be OPERABLE. 1 V Three control room air handling units (AHUs) shall be OPERABLE.
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| ---------------------------------------------NOTE--------------------------------------------
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| The control room envelope (CRE) boundary may be opened intermittently LCO 3.7.5 Footnote
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| * under administrative control.
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| APPLICABILITY APPLICABILITY: MODES 1, 2, 3, 4, [5, and 6], 2 During movement of [recently] irradiated fuel assemblies.
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| INSERT 1, ACTION A 3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B V A. One CREFS train C A.1 Restore CREFS train to 7 days V
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| inoperable for reasons OPERABLE status.
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| ACTIONs a.1, a.3, a.4, a.6, & a.7 other than Condition B.
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| B. One or more CREFS B.1 Initiate action to implement Immediately trains inoperable due to mitigating actions.
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| ACTION b inoperable CRE boundary in MODE 1, 2, AND 3, or 4.
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| 1 B.2 Verify mitigating actions 24 hours ensure CRE occupant C
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| exposures to radiological, chemical, and smoke hazards will not exceed limits.
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| AND B.3 Restore CRE boundary to 90 days OPERABLE status.
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| Westinghouse STS 3.7.10-1 Rev. 5.0 1 Amendment Nos. XXX and YYY Turkey Point Unit 3 and Unit 4
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| | |
| ITS 3.7.10 CTS INSERT 1 3 1
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| ACTION a.3 A. One control room AHU A.1 Restore control room AHU 7 days inoperable. to OPERABLE status.
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| Insert Page 3.7.10-1
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| | |
| V CTS
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| ----------------NOTE-------------
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| CREFS 1 Not applicable when a dual unit 3.7.10 shutdown is required.
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| ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME
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| , B, or C ACTIONs a.1, a.3, C. Required Action and C.1 Be in MODE 3. 6 hours a.4, a.5, a.6, & a.7, b associated Completion 3
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| Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 --------------NOTE--------------
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| D LCO 3.0.4.a is not applicable when entering MODE 4.
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| DOC A03 Be in MODE 4. 12 hours INSERT 2, ACTION E 3 F F.1.1 ACTIONs a.3, a.4, a.6, & a.7 D. Required Action and D.1 --------------NOTE--------------
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| B or C associated Completion [ Place in toxic gas Time of Condition A not protection mode if 2
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| or B met [in MODE 5 or 6, or] automatic transfer to toxic during movement of gas protection mode is
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| [recently] irradiated fuel inoperable. ]
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| assemblies. -------------------------------------
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| V Place OPERABLE CREFS Immediately 1 AND F.1.2 Place two OPERABLE train in emergency mode.
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| control room AHUs in recirculation 3
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| service.
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| OR Immediately F
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| D.2 Suspend movement of Immediately 2
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| [recently] irradiated fuel assemblies.
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| INSERT 3, ACTIONS G & H Westinghouse STS 3.7.10-2 Rev. 5.0 1 Amendment Nos. XXX and YYY Turkey Point Unit 3 and Unit 4
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| | |
| ITS 3.7.10 CTS INSERT 2 3 E. ------------NOTES----------- E.1 Be in MODE 3. 12 hours Only applicable when a dual unit shutdown is AND required.
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| ACTIONs a.1, a.3, -------------------------------- E.2 -------------NOTE----------------
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| a.4, a.6, a.7, & b Required Action and LCO 3.0.4.a is not associated Completion applicable when entering Time of Condition A, B, MODE 4.
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| or C not met. -------------------------------------
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| Be in MODE 4. 18 hours in MODE 1, 2, 3, or 4 1
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| INSERT 3 G. Two CREV trains G.1 Place one CREVS train in Immediately DOC M01 inoperable due to normal recirculation mode.
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| outside air intake isolated.
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| H. Two CREVS trains H.1 Place compensatory 24 hours ACTION a.5 inoperable in MODE 1, filtration unit in service.
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| 2, 3, or 4 for reasons other than Condition C or G.
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| DOC A02 I. Two or more control I.1 Enter LCO 3.0.3. Immediately room AHUs inoperable in MODE 1, 2, 3, or 4.
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| OR Required Action and associated Completion Time of Condition G or H not met.
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| in MODE 1, 2, 3, or 4 Insert Page 3.7.10-2
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| V CTS CREFS 1 3.7.10 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME J J DOC M02 E. Two CREFS trains E.1 Suspend movement of Immediately 3
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| inoperable [in MODE 5 [recently] irradiated fuel or 6, or] during assemblies.
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| movement of [recently]
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| Two or more control room irradiated fuel AHUs assemblies. inoperable OR 2 V
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| 1 One or more CREFS ACTION b trains inoperable due to an inoperable CRE boundary [in MODE 5 ACTIONs or 6, or] during OR a.4, a.6, a.7 movement of [recently]
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| DOC L05 K.2. Suspend irradiated fuel movement Place compensatory assemblies. filtration unit in service.
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| of irradiated fuel ACTION a.5 K
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| 1 V
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| F. Two CREFS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 3 Immediately 5 or 6, or during 2, 3, or 4 for reasons J movement of irradiated fuel assemblies, other than Condition B.
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| OR DOC M01 3 Required Action and associated Completion Time of Condition G not met in MODE 5 or 6, or during movement of irradiated fuel assembles.
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| SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY V
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| SR 4.7.5.b SR 3.7.10.1 Operate each CREFS train for 15 continuous [ 31 days minutes [with heaters operating]. 2 OR In accordance with the Surveillance Frequency Control Program ]
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| Westinghouse STS 3.7.10-3 Rev. 5.0 1 Amendment Nos. XXX and YYY Turkey Point Unit 3 and Unit 4
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| | |
| 7/25/22, 3:01 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1654 NRC Question JMW053 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/25/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/25/2022 1:57 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1654 1/1
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| 5/20/22, 2:38 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 635 NRC Question JMW054 Number Category Editorial ITS 3.7 Section ITS 3.7.10 Number DOC Number JFD Number JFD Bases Number Page 260, 261 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS Condition D (Single unit shutdown) specifies not met in MODE 1,2,3,4. ITS Condition E (dual unit Question shutdown) does not specify Modes. Confirm Modes are not necessary for Condition E. ITS Condition F includes Modes 5, 6 for the same Actions and Completion Times not met as Condition D and E. Please evaluate and make corrections as appropriate.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:46 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=635 1/1
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| 8/14/22, 9:56 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1115 NRC Question JMW054 Number Select Licensee Response Application Attachment Attachment 1 - JMW054 LAR Markups.pdf (684KB) 1 Attachment 2
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| Response FPL will revise ITS 3.7.10, Condition E, to specify its applicability as Modes 1, 2, 3, and 4 only. This is Statement necessary to differentiate Condition E from Condition F, which applies in Modes 5 and 6, or during the movement of irradiated fuel assemblies. See attached JMW054 license amendment request (LAR), Revision 1, markups.
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| Attachment
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| : 1. JMW054 LAR Markups
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| | |
| ===Response===
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| 6/10/2022 1:00 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/10/2022 12:02 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1115 1/1
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| | |
| ITS 3.7.10 CTS INSERT 2 3 E. ------------NOTES----------- E.1 Be in MODE 3. 12 hours Only applicable when a dual unit shutdown is AND required.
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| ACTIONs a.1, a.3, -------------------------------- E.2 -------------NOTE----------------
| |
| a.4, a.6, a.7, & b Required Action and LCO 3.0.4.a is not associated Completion applicable when entering Time of Condition A, B, MODE 4.
| |
| or C not met. -------------------------------------
| |
| Be in MODE 4. 18 hours in MODE 1, 2, 3, or 4 1
| |
| INSERT 3 G. Two CREV trains G.1 Place one CREVS train in Immediately DOC M01 inoperable due to normal recirculation mode.
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| outside air intake isolated.
| |
| H. Two CREVS trains H.1 Place compensatory 24 hours ACTION a.5 inoperable in MODE 1, filtration unit in service.
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| 2, 3, or 4 for reasons other than Condition C or G.
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| DOC A02 I. Two or more control I.1 Enter LCO 3.0.3. Immediately room AHUs inoperable in MODE 1, 2, 3, or 4.
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| OR Required Action and associated Completion Time of Condition G or H not met.
| |
| Insert Page 3.7.10-2
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| | |
| 6/16/22, 1:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1171 NRC Question JMW054 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/16/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/16/2022 10:19 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1171 1/1
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| | |
| 5/20/22, 2:39 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 639 NRC Question JMW055 Number Category Technical ITS 3.7 Section ITS 3.7.10 Number DOC Number JFD Number JFD Bases Number Page 258, 260, 262 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
| |
| Requested NRC TS Condition F includes Required Action and associated Completion Time of Condition A, B, or C not met in Question MODE 5 or 6, or during movement of irradiated fuel assemblies. Condition C states One or more CREVS trains inoperable due to inoperable CRE boundary in MODE 1, 2, 3, or 4. Condition J also includes actions for One or more CREVS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies. Verify that Condition C is appropriate to reference in Condition F due to the apparent conflicting modes of applicability.
| |
| Attach File 1
| |
| Attach File 2
| |
| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:47 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=639 1/1
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| 8/14/22, 9:57 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1119 NRC Question JMW055 Number Select Licensee Response Application Attachment Attachment 1 - JMW055 LAR Markups.pdf (665KB) 1 Attachment 2
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| Response ITS 3.7.10, Condition F, should not include reference to Condition C not being met, since Condition C Statement (inoperable Control Room Envelope (CRE) boundary) applies to operation in MODES 1, 2, 3, and 4. ITS 3.7.10, ACTION J, governs actions associated with an inoperable CRE boundary while operating in MODES 5, 6, or during the movement of irradiated fuel assemblies. Therefore, FPL will remove reference to not meeting Condition C in ITS 3.7.10, ACTION F. See attached JMW055 license amendment request (LAR) markups.
| |
| Attachment
| |
| : 1. JMW055 LAR Markups
| |
| | |
| ===Response===
| |
| 6/10/2022 1:05 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 6/10/2022 12:04 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1119 1/1
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| | |
| V
| |
| ----------------NOTE-------------
| |
| CREFS 1 Not applicable when a dual unit 3.7.10 shutdown is required.
| |
| ACTIONS (continued)
| |
| CONDITION REQUIRED ACTION COMPLETION TIME
| |
| , B, or C ACTIONs a.1, a.3, C. Required Action and C.1 Be in MODE 3. 6 hours a.4, a.5, a.6, & a.7, b associated Completion 3
| |
| Time of Condition A or B AND not met in MODE 1, 2, 3, or 4. C.2 --------------NOTE--------------
| |
| D LCO 3.0.4.a is not applicable when entering MODE 4.
| |
| DOC A03 Be in MODE 4. 12 hours INSERT 2, ACTION E 3 F F.1.1 ACTIONs a.3, a.4, a.6, & a.7 D. Required Action and D.1 --------------NOTE--------------
| |
| B or C associated Completion [ Place in toxic gas Time of Condition A not protection mode if 2
| |
| met [in MODE 5 or 6, or] automatic transfer to toxic during movement of gas protection mode is or B
| |
| [recently] irradiated fuel inoperable. ]
| |
| assemblies. -------------------------------------
| |
| V Place OPERABLE CREFS Immediately 1 AND F.1.2 Place two OPERABLE train in emergency mode.
| |
| control room AHUs in recirculation 3
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| service.
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| OR F
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| D.2 Suspend movement of Immediately 2
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| [recently] irradiated fuel assemblies.
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| INSERT 3, ACTIONS G & H Westinghouse STS 3.7.10-2 Rev. 5.0 1 Amendment Nos. XXX and YYY Turkey Point Unit 3 and Unit 4
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| 6/16/22, 1:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1175 NRC Question JMW055 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/16/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 6/16/2022 10:23 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1175 1/1
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| 5/20/22, 11:51 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 643 NRC Question JMW056 Number Category Technical ITS 3.7 Section ITS 3.7.10 Number DOC Number JFD Number JFD Bases Number Page 247, 261 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS Action H Required Action H.1 required the compensatory filtration unit to be placed in service within 24 Question hours. CTS Action a.5 has a similar requirement, but with additional actions and different completion times: CTS a.5 states in part immediately suspend all movement of irradiated fuel and immediately initiate action to place the compensatory filtration unit in service and verify proper operation within 24 hours, following which movement of irradiated fuel may resume, and within 7 days, restore the filter train to OPERABLE status. Provide justification for not including all of the CTS requirements in ITS Action H.
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| Attach File 1
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| Attach File 2
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| Issue Date 5/19/2022 Added By Joshua Wilson Date Modified Modified By Date 5/19/2022 2:49 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=643 1/1
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| 8/3/22, 5:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1479 NRC Question JMW056 Number Select Licensee Response Application Attachment Attachment 1 - JMW056 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response The CTS Action a.5 requirement to restore the Control Room Emergency Ventilation System (CREVS) filter Statement train to OPERABLE status within 7 days is addressed in ITS 3.7.10, ACTION B. The ISTS presentation does not duplicate Required Actions in each Condition, but instead, multiple Conditions are entered, as required.
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| Refer to Example 1.3-3 in ITS Section 1.3, "Completion Times," for explanation of entry into multiple Conditions. When the common CREVs filter is inoperable, both CREVS trains are inoperable, which also includes one CREVS train inoperable. Therefore, when the CREVS common filter unit is inoperable in MODE 1, 2, 3, or 4, both ITS 3.7.10, ACTIONS B and H, are entered concurrently. When the CREVS common filter unit is inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies, both ITS 3.7.10, ACTIONS B and K, are entered concurrently.
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| FPL proposes to create a new Discussion of Change (DOC) A04 to more fully address the presentation changes made to CTS 3.7.5, ACTION a.5, during the conversion to ITS. CTS 3.7.5, ACTION a.5, provides requirements for when the common Control Room Emergency Ventilation System (CREVS) filter unit is inoperable or when redundant CREVS components are inoperable and includes actions for all MODES and conditions. The ISTS 3.7.10 ACTIONS are separated based on whether the unit is in MODE 1, 2, 3, or 4, or the unit is in MODE 5 or 6 or moving irradiated fuel assemblies. A draft of ITS 3.7.10, DOC A04, is included in the attached JMW056 license amendment request (LAR) markups. The markups also add reference to DOC A04 on the affected CTS and ITS markup pages. Note that the ITS references in the left-hand column of the ITS 3.7.10 CTS page 3/4 7-19 markup were revised in response to NRC request for additional information (RAI) JMW053 and are further revised in response to this RAI (JMW056). The markup of CTS page 3/4 7-19 included herein supersedes the markup of the same page contained in the RAI JMW053 response.
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| In addition to the above, FPL identified that ITS 3.7.10, Condition I, currently requires entry into Limiting Condition for Operation (LCO) 3.0.3 when two or more air handling units (AHUs) are inoperable or when other conditions exist that represent a loss of the CREVS specified safety function. CTS Action a.5 does not require LCO 3.0.3 entry but provides shutdown actions dependent on whether a single or dual unit shutdown is necessary. Therefore, FPL proposes to modify ITS 3.7.10, Condition I, to address a single unit shutdown and add a Condition J to address a dual unit shutdown, both associated with a loss of safety function and consistent with CTS Action a.5. Because the current requirements are maintained, no additional DOC is required. ITS 3.7.10, Conditions J and K, are subsequently renumbered as Conditions K and L, respectively.
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| The response to RAI JMW026 created a new ITS 3.7.10, DOC A04, to further address the adoption of ITS 3.7.10, Condition I (LCO 3.0.3 entry). As stated above, a new DOC is not required to address Condition I and new Condition J, which are consistent with the current licensing basis. Therefore, the new DOC A04 included in response to RAI JMW026 is no longer required, along with any DOC A04 references added to the associated JMW026 markups. However, a new Justification for Deviation (JFD) 4 will be added herein to address the change from the ISTS Condition requiring LCO 3.0.3 entry to the current licensing basis associated with single or dual unit shutdown. Subsequently, the JMW026 ITS 3.7.10 CTS page 3/4 7-20 markup, DOC page 2 of 7, and ITS page 3.7.10-2 markup are superseded by the associated pages included in the attached file of this response (Attachment 1 - JMW056 LAR Markups).
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| The response to RAI JMW034 revised ITS 3.7.10 Bases, Insert 7 (page B 3.7.10-6b). This page is superseded by the associated page included in the attached file herein (JMW034 changes included). In addition, the markup of ITS 3.7.10 Bases page 3.7.10-7 included in response to RAI JMW035 is superseded by the associated page included in the attached file herein (JMW035 changes revised due to renumbering ITS 3.7.10, ACTION J as ACTION K).
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| Attachment
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| : 1. JMW056 LAR Markups
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| ===Response===
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| 7/6/2022 2:45 PM Date/Time Closure https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1479 1/2
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| 8/3/22, 5:32 PM Turkey Point ITS Conversion Database Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/6/2022 1:44 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1479 2/2
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| ITS A01 ITS 3.7.10 PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued)
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| L05 a.4 With one recirculation damper inoperable, within 7 days, restore the inoperable damper to OPERABLE status or, place and maintain at least one of the recirculation dampers in the open position and place the system in recirculation mode or, immediately suspend all movement of H
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| irradiated fuel and be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| a.5 With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable recirculation fans, A04 ACTION G ACTION J and/or two inoperable recirculation dampers, immediately suspend all movement of irradiated fuel ACTION L and immediately initiate action to place the compensatory filtration unit in service and verify proper L02 ACTIONS G and J operation within 24 hours, following which movement of irradiated fuel may resume, and within 7 ACTION B MODE 5 in 36 hours for one days, restore the filter train to OPERABLE status. A01 unit, or 42 hours for both units ACTION F.2 ACTION L.2 ACTION D & Condition Note With the above requirements not met, immediately suspend all movement of irradiated fuel and be ACTION I & Condition Note in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| L01 ACTION E & Condition Note Add proposed Required Actions D.2, E.2 and Note ACTION J & Condition Note a.6 With an inoperable damper in the normal outside air intake, within 7 days, restore the inoperable damper to OPERABLE status or, place and maintain at least one of the normal outside air intake isolation dampers in the closed position and place the system in recirculation mode or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| L05 a.7 With an inoperable damper in the emergency outside air intake, within 7 days, restore the inoperable damper to OPERABLE status or, place and maintain at least one of the emergency outside air intake isolation dampers in the open position or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours for one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| L05 Add proposed ACTION G M01 TURKEY POINT - UNITS 3 & 4 3/4 7-19 AMENDMENT NOS. 275 AND 270 Page 2 of 4
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| ITS A01 ITS 3.7.10 PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued)
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| ACTION C b. With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary during MODES 1, 2, 3 or 4, immediately initiate action to implement mitigating actions.
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| Within 24 hours, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits, and CRE occupants are protected from smok e hazards, and restore CRE boundary to OPERABLE status within 90 days.
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| ACTION D& Condition Note With the above requirements not met, be in at least HOT STANDBY within the next 6 hours for L01 ACTION E & Condition Note one Unit, or 12 hours for both Units, and in COLD SHUTDOWN within the following 30 hours.
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| MODE 4 6 K A03 With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE ACTION J boundary during MODES 5, 6 or during the movement of irradiated fuel assemblies, immediately suspend all movement of irradiated fuel.
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| Add proposed ACTION I A02 SURVEILLANCE REQUIREMENTS 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:
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| See ITS a. In accordance with the Surveillance Frequency Control Program by verifying that the control room 3.7.11 air temperature is less than or equal to 120 F;
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| : b. In accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at SR 3.7.10.1 least 15 minutes**;
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| : c. In accordance with the Surveillance Frequency Control Program or (1) after 720 hours of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, See ITS or (3) following exposure of the filters to effluents from painting, fire, or chemical release in any 5.5.8 ventilation zone communicating with the system that may have an adverse effect on the functional SR 3.7.10.2 capability of the system, or (4) after complete or partial replacement of a filter bank by:
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| **As the mitigation actions of TS 3.7.5 Action a.5 include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room and TS LA02 4.7.5.c, d and f.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-20 AMENDMENT NOS. 275 AND 270 Page 3 of 4
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| DISCUSSION OF CHANGES ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
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| The purpose of the CTS 3.7.4, ACTION b, is to ensure prompt Action is taken to restore the CREVS to an OPERABLE status within the specified Completion Times. The Notes described above conservatively allow only one unit in a dual unit shutdown event to apply the 12-hour Completion Time to reach MODE 3.
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| This change is intended to provide clarity with respect to the different CTS Completion Times which depend on the CREVS. The described Notes and addition of proposed Condition E is consistent with the CTS in that the 12-hour Completion Time is only applicable during dual unit shutdown conditions. This change is considered Administrative as no technical changes are being made to the CTS.
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| Add DOC A04 MORE RESTRICTIVE CHANGES M01 CTS 3.7.5 Action a.4, one recirculation damper inoperable and a.6, an inoperable damper in the normal outside air intake require, in part, to place the CREVS in the recirculation mode. ITS 3.7.10 ACTION G requires that with two CREVS trains inoperable due to normal outside air intake isolated to immediately place one CREVS train in the recirculation mode. This changes the CTS by replacing specific action requirements associated with an inoperable recirculation or intake damper in the CREVS with a requirement to place the CREVS in the recirculation mode if both CREVS trains are inoperable due to normal outside air intake isolated.
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| The purpose of the CTS actions is to ensure the control room envelop boundary and filtration function are maintained when redundant isolation or actuation capability is lost on the CREVS. The CREVS design includes dual dampers on the normal intake, the emergency intake, and the recirculation ducting to ensure these penetrations are isolated and proper actuation in the event of an accident requiring control room habitability. The required dampers are powered and actuated from redundant trains. When one required damper in the normal air intake duct is closed both intake radiation monitors are isolated unable to detect an increase in external radiation levels, potentially preventing CREVS actuation when needed. An appropriate action for this level of degradation is to declare both CREVS intake radiation monitors inoperable causing the CREVS to be placed in the recirculation mode in accordance with LCO 3.3.4, "Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation." This change is acceptable because actions retained in the ITS continue to ensure redundant capability is restored or the safety related function is performed.
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| These remedial actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant dampers and the low probability of a DBA occurring during this condition. This change is designated as more restrictive because the CREVS will be placed in the recirculation mode sooner in ITS (immediately) than in CTS (7 days).
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| RELOCATED SPECIFICATIONS None Turkey Point Unit 3 and Unit 4 Page 2 of 7
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| A04 CTS 3.7.5, ACTION a.5, contains the remedial actions for all MODES and conditions listed in the Applicability when both recirculation fans or the required CREVS filter is inoperable (MODES 1, 2, 3, 4, 5, 6, and during the movement of irradiated fuel assemblies). The ITS proposes to create separate Conditions, one applicable to operation in MODES 1, 2, 3, and 4 (ACTION H) and one applicable in MODES 5 and 6, and during the movement of irradiated fuel assemblies (ACTION L) consistent with the ISTS presentation approach. This changes the CTS by creating separate ACTIONS to differentiate between specific MODES of operation.
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| The purpose of the CTS Action is to ensure appropriate remedial measures are taken upon the loss of both recirculation fans or the common CREVS filter is inoperable. ITS 3.7.10, ACTION H, requires placing the compensatory filtration unit in service within 24 hours while CTS 3.7.5, ACTION a.5, states to initiate action immediately to place the compensatory filtration unit in service and verify its operation within 24 hours. In either case, the compensatory filtration unit is required to be operational and in service within 24 hours. A statement to "initiate action" immediately does not imply that physical realignments can begin at time zero. Action to initiate would include, but is not limited to, verification of plant conditions, ongoing activities, personnel availability, component configurations, and verification of filter unit testing requirements are met within the required frequency. These activities must be taken into account prior to changing the status of a system or train. Also, verification of the compensatory filter unit's proper operation is part of the action of placing the compensatory unit in service. Therefore, a single Required Action to place the compensatory filtration unit in service within 24 hours fully encompasses the CTS requirements to initiate action immediately (i.e., without delay and in a controlled manner) to ensure the compensatory filtration unit is in service and proper operation verified within the 24-hour Completion Time.
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| ITS 3.7.10, ACTION L, provides two options: 1) place the compensatory filtration unit in service immediately, or 2) immediately suspend the movement of irradiated fuel assemblies. This is equivalent to the CTS 3.7.5, ACTION a.5, requirement to immediately suspend the movement of irradiated fuel in that the CTS Action further states the movement of irradiated fuel may recommence once the compensatory filtration unit is placed in service. Therefore, if action is taken to suspend the movement of irradiated fuel, the compensatory filtration unit need not be placed in service. This is acceptable because the radiological consequences to Control Room operators in MODES 5, 6, and during the movement of irradiated fuel assemblies are associated with a fuel handling accident (i.e., other design basis accidents are addressed by the ACTIONS applicable to operation in MODES 1, 2, 3, and 4). With the unit operating in MODES 1, 2, 3, or 4 while also moving irradiated fuel, both ACTION H and ACTION L would be applicable, ensuring the movement of irradiated fuel is suspended until the compensatory filtration unit is placed in service. Based on the above, these changes are considered administrative in that the movement of irradiated fuel will continue to be suspended immediately until the compensatory filtration unit is in service and the compensatory filtration unit will be placed in service within 24 hours, when required.
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| ITS 3.7.10 CTS INSERT 2 3 E. ------------NOTES----------- E.1 Be in MODE 3. 12 hours Only applicable when a dual unit shutdown is AND required.
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| ACTIONs a.1, a.3, -------------------------------- E.2 -------------NOTE----------------
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| a.4, a.6, a.7, & b Required Action and LCO 3.0.4.a is not associated Completion applicable when entering Time of Condition A, B, MODE 4.
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| or C not met. -------------------------------------
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| Be in MODE 4. 18 hours 1
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| INSERT 3 G. Two CREV trains G.1 Place one CREVS train in Immediately 1 DOC M01 inoperable due to normal recirculation mode.
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| outside air intake isolated.
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| H. Two CREVS trains H.1 Place compensatory 24 hours inoperable in MODE 1, filtration unit in service. 1 ACTION a.5 DOC A04 2, 3, or 4 for reasons ------------------NOTE----------------
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| other than Condition C Not applicable when a dual unit or G. shutdown is required.
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| DOC A02 I. Two or more control I.1 Enter LCO 3.0.3. Be in MODE 3. Immediately 6 hours 4 room AHUs inoperable ACTION a.5 in MODE 1, 2, 3, or 4. AND I.2 Be in MODE 5. 36 hours OR 1 Required Action and associated Completion Time of Condition G or H not met.
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| Add Condition J 1 Insert Page 3.7.10-2
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| ----------------------NOTE---------------------- J.1 Be in MODE 3. 12 hours 4 ACTION a.5 Only applicable when a dual unit shutdown is required. AND J.2 Be in MODE 5. 42 hours 1
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| J. Two or more control room AHUs inoperable in MODE 1, 2, 3, or 4.
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| OR Required Action and associated Completion Time of Condition G or H not met.
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| V CREFS 1 3.7.10 ACTIONS (continued)
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| K CONDITION REQUIRED ACTION COMPLETION TIME J J E. Two CREFS trains E.1 Suspend movement of Immediately 3
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| inoperable [in MODE 5 [recently] irradiated fuel or 6, or] during assemblies.
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| movement of [recently]
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| Two or more control room irradiated fuel AHUs assemblies.
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| OR 2 V
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| 1 One or more CREFS ACTION b trains inoperable due to an inoperable CRE boundary [in MODE 5 L.2 or 6, or] during OR movement of [recently]
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| K.2. Suspend irradiated fuel movement Place compensatory assemblies. L filtration unit in service.
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| of irradiated fuel K
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| 1 V
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| F. Two CREFS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 3 Immediately 5 or 6, or during 2, 3, or 4 for reasons J movement of irradiated fuel assemblies, other than Condition B. K OR 3
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| Required Action and associated Completion Time of Condition G not met in MODE 5 or 6, or during movement of irradiated fuel assembles.
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| SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY V
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| SR 4.7.5.b SR 3.7.10.1 Operate each CREFS train for 15 continuous [ 31 days minutes [with heaters operating]. 2 OR In accordance with the Surveillance Frequency Control Program ]
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| Westinghouse STS 3.7.10-3 Rev. 5.0 1 Amendment Nos. XXX and YYY Turkey Point Unit 3 and Unit 4
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| ITS 3.7.10 JUSTIFICATION FOR DEVIATIONS ITS 3.7.10, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
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| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 2. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 3. Changes made to reflect the current licensing basis. The Control Room Emergency Ventilation System (CREVS) Current Technical Specifications (CTS) for the Turkey Point Nuclear Generating Station (PTN) is shared between Units 3 and 4 Control Rooms. The ISTS is based on a single plant design with two redundant trains/subsystems. Due to the shared systems between the PTN units, changes are made (additions, deletions, and/or changes) to the ISTS presentation that reflect the plant-specific multi-unit and shared systems design on a unit basis. In addition, renumbering is required due to added Actions. The changes do not represent a change to the plant design or safety analysis basis.
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| 4 CTS 3.7.5, Action a.5, includes shutdown requirements if the other actions contained in CTS 3.7.5, Action a.5, are not completed within the designated time. For these conditions, ISTS 3.7.10, ACTION I, requires entry into LCO 3.0.3. CTS 3.7.5, Action a.5, provides different times to complete a shutdown, depending on whether a single or dual unit shutdown is necessary. ISTS 3.7.10, Condition I, is written for single unit, in which case entry into LCO 3.0.3 would be appropriate upon failure to meet the requirements. However, to avoid unnecessary risk to the offsite power grid and station operation, simultaneous shutdown of both PTN units is not required by CTS when a dual unit shutdown is necessary. An extra six hours is provided beyond the standard 6 hours to MODE 3 and 36 hours to MODE 5 Completion Times to allow the unit shutdowns to be staggered. Therefore, the ISTS 3.7.10, ACTION I, requirement to immediately enter LCO 3.0.3 is replaced with ITS 3.7.10, ACTIONS I and J, consistent with the current licensing basis requirements associated with dual unit shutdowns.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| ITS 3.7.10 1
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| INSERT 6 (cont.)
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| H.1 With both CREVS trains inoperable for reasons other than an inoperable CRE boundary (e.g.,
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| the common filter unit is inoperable, two recirculation fans are inoperable, or required dampers are inoperable and not secured in the accident position) or the normal outside air intake flowpath is isolated, the compensatory filtration unit is required to be placed in service within 24 hours. This remedial action ensures control room occupant radiological exposures will not exceed limits. The 24-hour allowance to place the compensatory filtration unit in service is reasonable based on the low probability of a DBA occurring during this time period.
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| The compensatory filtration unit is designed as a manual, safety-related, Seismic Class I backup to the installed system with the same functional and operational capabilities as the installed CREVS filter unit. The requirements for the compensatory filtration unit are located in the Technical Requirements Manual.
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| 4 INSERT 7 In MODES in MODES I.1 and I.2 1, 2, 3, or 4 1, 2, 3, and 4 if If two or more AHUs are inoperable, the CREVS can no longer provide its specified safety function. Additionally, if the Required Action of Condition G or H cannot be performed within the required Completion Time, no additional time is justified for continued operation. Therefore, LCO 3.0.3 must be entered immediately.
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| the unit must be placed in a MODE in which the overall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 5 within 36 hours.
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| Condition I is modified by a Note stating that the Condition is not applicable when a dual unit shutdown is required. Condition J is entered if a dual unit shutdown is required. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
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| J.1 and J.2 With both units operating in MODE 1, 2, 3, or 4, if two or more AHUs are inoperable or if the Required Action of Condition G or H cannot be performed within the required Completion Time, the units must be placed in a MODE in which the overall plant risk is reduced. To achieve this status, the units must be placed in at least MODE 3 within 12 hours, and in MODE 5 within 42 hours.
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| Condition J is modified by a Note stating that the Condition is only applicable when a dual unit shutdown is required. To achieve a consecutive unit shutdown, the first unit should be in MODE 3 and MODE 5 within 6 hours and 36 hours, respectively, to allow time for the second unit to reach MODE 3 and MODE 5 in 12 hours and 42 hours, respectively. This is to allow for the orderly shutdown of one unit at a time and not jeopardize the stability of the electrical grid by imposing a simultaneous dual unit shutdown. Condition I is entered if a single unit shutdown is required.
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| The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
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| INSERT Page B 3.7.10-6b
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| V CREFS 1 B 3.7.10 BASES ACTIONS (continued)
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| K E.1 4 I.1 or more Control Room [In MODE 5 or 6, or] during movement of [recently] irradiated fuel 2 AHUs inoperable or with assemblies, with two CREFS trains inoperable or with one or more 4
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| CREVS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.
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| INSERT 8 F.1 4 If both CREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e., Condition B), the CREFS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.
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| SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. Operation [with the heaters on] for 15 continuous minutes demonstrates OPERABILITY of the 3 system. Periodic operation ensures that [heater failure,] blockage, fan or motor failure, or excessive vibration can be detected for corrective action.
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| [ The 31 day Frequency is based on the reliability of the equipment and 3 the two train redundancy.
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| OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the 2 Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| Westinghouse STS B 3.7.10-7 Rev. 5.0 1
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| Turkey Point Unit 3 and Unit 4 Revision XXX
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| ITS 3.7.10 4
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| L INSERT 8 K.1 and K.2 K In MODE 5 or 6, or during movement of irradiated fuel assemblies, if both CREVS trains are inoperable for reasons other than Condition J or the Required Action and associated Completion Time of Condition G cannot be met, action must be taken to immediately to place the compensatory filtration unit in service, ensuring control room occupant radiological exposures will not exceed limits. The compensatory filtration unit is designed as a manual, safety-related, Seismic Class I backup to the installed system with the same functional and operational capabilities as the installed CREVS filter unit. The requirements for the compensatory filtration unit are located in the Technical Requirements Manual.
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| action is provided An alternative to Required Action K.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.
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| Once the compensatory filter is placed in service, movement of irradiated fuel Because the assemblies may resume and fuel handling operation continued with the compensatory filter may compensatory filter operating.
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| not be immediately available to place in service, an INSERT Page B 3.7.10-7
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| 7/25/22, 3:04 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1658 NRC Question JMW056 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/25/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/25/2022 1:58 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1658 1/1
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| 6/17/22, 12:28 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 803 NRC Question JMW057 Number Category Technical ITS 3.7 Section ITS 3.7.9 Number DOC Number JFD Number JFD Bases Number Page 220, 225 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC During a public meeting, held June 16, 2022, the licensee stated their intent to revise TS LCO Question 3.7.9 to retain their CTS instead of adopting the STS. Please provide the revised TS LCO 3.7.9 in order for the NRC staff to review.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/17/2022 Added By Joshua Wilson Date Modified Modified By Date 6/17/2022 11:26 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=803 1/1
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| 8/14/22, 9:59 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1483 NRC Question JMW057 Number Select Licensee Response Application Attachment Attachment 1 - JMW057 3.7.9 LAR Markup (EA).pdf (2MB) 1 Attachment 2
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| Response The incorporation of CTS 3.7.4 into the ISTS as proposed in the ITS 3.7.9 markups of the ITS Conversion Statement license amendment request would result in the requirements of CTS 4.7.4.b not being required. As initially proposed, ITS 3.7.9 Condition A would never be applicable because LCO 3.7.9 is met until UHS temperature exceeds 104°F. Upon not meeting LCO 3.7.9 (i.e., UHS temperature > 104°F), ACTION B would apply, ACTION A would never apply.
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| FPL proposes the addition of an initial frequency to SR 3.7.9.1 that requires verification of the UHS temperature when UHS is > 100°F consistent with the requirements of CTS 4.7.4.b. As a result, verification that the UHS average supply water temperature is 104°F will continue to be performed at a frequency in accordance with the Surveillance Frequency Control Program consistent with CTS 4.7.4.a and verified every hour when UHS water temperature exceeds 100°F which is consistent with CTS 4.7.4.b. This change is considered an administrative change per Discussion of Change A01 because the change between CTS and ITS is solely a presentation change and does not result in a technical change to the current requirement.
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| As a result of this change, the ITS 3.7.9 package is revised to add a Frequency to ITS SR 3.7.9.1 and eliminate ITS ACTION A and associated changes made to the CTS markup and ITS Bases markup. DOC A02 is revised to clarify the redundancy with CTS 3.0.5 (ITS 3.0.10) requirements. See Attachment 1 for proposed markups.
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| Attachments
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| : 1. JMW057 3.7.9 LAR Markups
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| ===Response===
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| 7/6/2022 3:20 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/6/2022 2:19 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1483 1/1
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| ITS A01 ITS 3.7.9 PLANT SYSTEMS 3/4.7.4 ULTIMATE HEAT SINK LIMITING CONDITION FOR OPERATION LCO 3.7.9 3.7.4 The ultimate heat sink shall be OPERABLE with an average supply water temperature less than or Action A, equal to 104°F.
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| SR 3.7.9.1 A02 Applicability APPLICABILITY: MODES 1, 2, 3, and 4.
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| Add proposed Required Action B.1, C.1 and associated Notes ACTION: Add proposed Required Action A B.2, C.2 and associated Notes L01 Action B, With the requirements of the above specification not satisfied, be in at least HOT STANDBY within Action C 12 hours and in COLD SHUTDOWN within the following 30 hours. This ACTION shall be applicable to both units simultaneously. Add proposed Required Action B.2 Note A03 UHS inoperable Only applicable when a dual unit A02 Action B Note shutdown is required.
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| in MODE 4 within 18 hours L01 SURVEILLANCE REQUIREMENTS 4.7.4 The ultimate heat sink shall be determined OPERABLE:
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| SR 3.7.9.1 a. In accordance with the Surveillance Frequency Control Program by verifying the average supply water temperature* is less than or equal to 104°F.
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| Action A b. At least once per hour by verifying the average supply water temperature* is less than or equal to 104°F, when water temperature exceeds 100°F.
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| SR 3.7.9.1 first Frequency
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| *Portable monitors may be used to measure the temperature.
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| LA01 TURKEY POINT - UNITS 3 & 4 3/4 7-17 AMENDMENT NOS. 263 AND 258 Page 1 of 1
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| DISCUSSION OF CHANGES ITS 3.7.9, ULTIMATE HEAT SINK (UHS)
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| ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable, because they do not result in technical changes to the CTS.
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| DOC A02 insert A02 The CTS 3.7.4 ACTION, states, in part, with the requirements of the above specification (UHS temperature limitation) not satisfied to be in at least HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours. The CTS 3.7.4 further states that This ACTION shall be applicable to both units simultaneously. In addition, CTS Bases states that that when an ACTION statement requires a dual unit shutdown, the time to be in HOT STANDBY is 12 hours. This is to allow the orderly shutdown of one unit at a time and NOT jeopardize the stability of the electrical grid by imposing a dual unit shutdown. ITS 3.7.9 Condition B, (be in MODE 3 in 6 hours) is modified by a Note that states "Condition B only applies to one Unit during a dual Unit shutdown." ITS 3.7.9 Condition C (be in MODE 3 in 12 hours) is modified by two Notes:
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| : 1) "Condition C only applies when a dual Unit shutdown is required", and 2) "Only one Unit can enter Condition C." This modifies the CTS to clarify what Completion Times should be followed for an inoperable UHS.
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| The purpose of the CTS 3.7.4 ACTION is to ensure prompt Action is taken to restore the inoperable UHS or shutdown the unit when the UHS cannot be restored to an OPERABLE status within the specified Completion Times. The UHS temperature requirements ensure that sufficient cooling capacity is available either: (1) To provide normal cooldown of the facility, or (2) To mitigate the effects of accident conditions within acceptable limits. The Notes described above conservatively allow only one unit in a dual unit shutdown event to apply the 12-hour Completion Time to reach MODE 3. This change is intended to provide clarity with respect to the different CTS Completion Times which depend on the UHS. Because the new Notes clarify that only one unit can apply the 12-hours to be in MODE 3 consistent with the CTS ACTION as discussed in the CTS Bases, this change is considered Administrative as no technical changes are being made to the CTS.
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| A03 CTS 3.7.4 Action states, in part, that this Action shall be applicable to both units simultaneously. ITS 3.7.9 does not include this statement. This changes the CTS by removing duplicative information.
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| The purpose of the CTS Action statement is to ensure application of this Action to both units. CTS 3.0.5 (ITS 3.0.10) states that Limiting Conditions for Operation (LCOs) including the associated ACTION requirements shall apply to each unit individually unless otherwise indicated as follows: a. whenever the Limiting Conditions for Operation refers to systems or components which are shared by both units, the ACTION requirements will apply to both units simultaneously; b. whenever the Limiting Conditions for Operation applies to only one unit, this will be identified in the APPLICABILITY section of the specification; and c. whenever certain portions of a specification contain Turkey Point Unit 3 and Unit 4 Page 1 of 3
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| DOC A02 A02 The CTS Action includes a statement that the action applies to both units simultaneously. ITS 3.7.9 ACTIONS do not explicitly state that the ACTIONS apply to both units. This changes the CTS by deleting redundant detail.
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| The purpose of the CTS statement is to ensure action requirements are performed simultaneously for both units when required equipment shared between the units is inoperable. The statement is redundant to the generic requirement provided in CTS 3.0.5.a (ITS 3.0.10.a) and therefore is not necessary. ITS 3.0.10.a states, Whenever the LCO refers to systems or components which are shared by both units, the Conditions and Required Actions will apply to both units simultaneously. UHS is a system common to both units. As a result, applying Technical Specification Requirements to both units simultaneously is required of all requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. Technical Specification ACTIONS associated with shared systems will continue to be performed for both units simultaneously per the requirements of ITS LCO 3.0.10. A Note to ITS Condition B clarifies that the condition applies when a dual unit shutdown is required.
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| This change is solely a presentation preference and is designated as administrative because it does not result in a technical change to the CTS.
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| DISCUSSION OF CHANGES ITS 3.7.9, ULTIMATE HEAT SINK (UHS) operating parameters, Setpoints, etc., which are different for each unit, this will be identified in parentheses, footnotes or body of the requirement. Because a closed cooling canal system provides cooling water to both Unit 3 and Unit 4 ICW intake bays the ICW supply water temperature would be the same. As stated in CTS 3.0.5, "
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| Whenever the Limiting Conditions for Operation refers to systems or components which are shared by both units, the ACTION requirements will apply to both units simultaneously. This statement is also in ITS as LCO 3.0.10. This change is acceptable because the ICW supply is shared by both unit causing the Actions to be applicable to both units in accordance with ITS LCO 3.0.10. This change is considered administrative because no technical changes are being made.
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| MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.7.4 provides the requirements for verifying the UHS average supply water temperature is within limits. CTS 4.7.4 includes a footnote that states, "Portable monitors may be used to measure the temperature." ITS 3.7.9 does not include this footnote. This changes the CTS by moving an allowable method of measuring the supply temperature to the Bases.
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| The removal of these details for performing Surveillance Requirements from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for verifying the average supply temperature with no change in frequency. This change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.7.4, Action, identifies a degraded condition of the Ultimate Heat Sink (UHS) and provides specific Completion Times to restore the degraded condition or commence a unit shutdown. If a unit shutdown is A required, the CTS 3.7.4 Action requires the unit be in HOT STANDBY within the next 12 hours and in COLD SHUTDOWN within the following 30 hours. ITS 3.7.9 ACTION B Turkey Point Unit 3 and Unit 4 Page 2 of 3
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| requires that with the UHS inoperable, and a DISCUSSION OF CHANGES dual unit shutdown is ITS 3.7.9, ULTIMATE HEAT SINK (UHS) not required, states that if the Required Action and associated Completion Time of UHS degraded conditions are not met to be in MODE 3 in 6 hours and MODE 4 in 12 hours and is modified by a Note stating that LCO 3.0.4.a is not applicable when entering MODE 4.
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| ITS 3.7.9 ACTION C states that if the Required Action and associated Completion Time of UHS degraded conditions are not met to be in MODE 3 in 12 hours and MODE 4 in 18 hours and is modified by a Note stating that LCO 3.0.4.a is not applicable when ACTION B is applicableentering MODE 4. This changes the CTS by allowing a Required Action end state of when the UHS is HOT SHUTDOWN (MODE 4) rather than an end state of COLD SHUTDOWN inoperable and a dual (MODE 5).
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| unit shutdown is required and requires both units One purpose of CTS 3.7.4, Action is to provide an end state, a condition that the reactor must be placed in, if the Required Actions allowing remedial measures to be taken in response to the degraded conditions with continued operation are not met. End states are usually defined based on placing the unit into a MODE or condition in which the Technical Specification Limiting Condition for Operation (LCO) is not applicable. MODE 5 is the current end state for LCOs that are applicable in MODES 1 through 4. This change is acceptable because the risk of the transition from MODE 1 to MODES 4 or 5 depends on the availability of alternating current (AC) sources and the ability to remove decay heat such that remaining in MODE 4 may be safer. During the realignment from MODE 4 to MODE 5, there is an increased potential for loss of shutdown cooling and loss of inventory events. Decay heat removal following a loss-of-offsite power event in MODE 5 is dependent on AC power for shutdown cooling whereas, in MODE 4, the turbine driven auxiliary feedwater (AFW) pump will be available. Therefore, transitioning to MODE 5 is not always the appropriate end state from a risk perspective. Thus, for specific TS conditions, Westinghouse Topical Report WCAP-16294-A R1 (ADAMS Accession No. ML103430249) justifies MODE 4 as an acceptable alternate end state to Mode 5. The proposed change to the Technical Specifications will allow time to perform short-duration repairs, which currently necessitate exiting the original mode of applicability. The MODE 4 TS end state is applied, and risk is assessed and managed in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants."
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| This proposed change is consistent with NRC approved TSTF-432-A Revision 1 (ADAMS Accession No. ML103360003), noticed for availability by the NRC in the Federal Register (77 FR 27814) on May 11, 2012. The NRC's approval of WCAP-16294-A included four limitations and conditions on its use as identified in Section 4.0 of the NRC Safety Evaluation associated with WCAP-16294-A. Implementation of these stipulations were addressed in the Bases of TSTF-432-A. Florida Power & Light implemented these limitations and conditions at PTN in the adoption of the associated TSTF-432-A Bases. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 3 of 3
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| CTS UHS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS) 3.7.4 LCO 3.7.9 The UHS shall be OPERABLE.
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| Applicability APPLICABILITY: MODES 1, 2, 3, and 4.
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| ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. [ One or more cooling A.1 Restore cooling tower 7 days towers with one cooling fan(s) to OPERABLE tower fan inoperable. status. [OR 1
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| In accordance with the Risk Informed Completion Time Program] ]
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| A
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| -----REVIEWER'S NOTE----- B.1 Verify water temperature of Once per hour] 3 4 1
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| 104 The [ ]°F is the maximum the UHS is [90]°F allowed UHS temperature averaged over the previous 4 value and is based on 24 hour period.
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| temperature limitations of 2 the equipment that is relied upon for accident mitigation and safe shutdown of the unit.
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| A B. [ Water temperature of 3 the UHS > [90] °F and 1 4
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| [ ]°F. 100 104 Westinghouse STS 3.7.9-1 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY
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| CTS UHS 3.7.9 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME A
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| B INSERT 1 B DOC L01 C. [ Required Action C.1 Be in MODE 3. 6 hours 3 1 5 and associated A Completion Time of AND 7
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| Condition A or B not B 3
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| met. C.2 --------------NOTE--------------
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| LCO 3.0.4.a is not OR ] applicable when entering 1 MODE 4.
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| UHS inoperable [for ------------------------------------- 1 reasons other than Condition A or B] . Be in MODE 4. 12 hours 5 INSERT 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 [. t o [562] ft [mean sea [ [24] hours level] .
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| OR In accordance 1 with the Surveillance Frequency Control Program ] ]
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| 1 SR 3.7.9.2 [ Verify average water temperature of UHS is [ 24 hours 6
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| [90] °F. 1 104 OR 3.7.4 1 hour when UHS temperature is >
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| 4.7.4.a 100°F and b.
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| In accordance AND with the Surveillance Frequency Control Program ] ] 1 Westinghouse STS 3.7.9-2 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY
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| 4 5
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| 1 INSERT 1
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| ----------------NOTE-------------
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| Action Not applicable when a dual DOC L01 unit shutdown is required.
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| 4 1
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| INSERT 2 5 CONDITION REQUIRED ACTION COMPLETION TIME B
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| Action C. ------------NOTE----------- C.1 Be in MODE 3. 12 hours 3 DOC A02 Only applicable when a DOC L01 dual unit shutdown is B AND required.
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| -------------------------------- C.2 --------------NOTE--------------
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| Required Action LCO 3.0.4.a is not and associated applicable when entering Completion Time not MODE 4.
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| met. -------------------------------------
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| OR Be in MODE 4. 18 hours UHS inoperable for reasons other than Condition A.
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| Insert Page 3.7.9-2
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| JUSTIFICATION FOR DEVIATIONS ITS 3.7.9, ULTIMATE HEAT SINK (UHS)
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| : 1. The Improved Standard Technical Specification (ISTS) contain bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 2. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
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| : 3. Changes have been made to delete Actions; the subsequent Actions and Required Actions have been renumbered to reflect the deletions.
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| : 4. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 5. The Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) 3.7.9 (Ultimate Heat Sink) allows for 12 hours to be in MODE 3 if the inoperability applies to both units simultaneously. The Completion Time allows for an orderly sequential shutdown of both units when the inoperability of a component affects both units with equal severity and is reasonable based on operating experience to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Another 6 hours is allowed to reach MODE 4 and is reasonable based on operating experience to reach the required unit conditions from MODE 3 in an orderly manner.
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| : 6. Changes have been made that deleted Surveillance Requirements (SRs)' the subsequent SRs have been renumbered to reflect the deletions.
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| : 7. Corrections to the Condition have been made consistent with the Writers Guide for the Improved Technical Specifications, TSTF-GG-05-01, Section 4.1.6.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| UHS B 3.7.9 BASES ACTIONS (continued)
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| A
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| [ B.1 3
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| The [ ] ° F is the maximum allowed UHS temperature value and is based 4 on temperature limitations of the equipment that is relied upon for accident mitigation and safe shutdown of the unit.
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| -With water temperature of the UHS > [90] °F, the design basis assumption 2 associated with initial UHS temperature are bounded provided the 100 temperature of the UHS averaged over the previous 24 hour period is 1 104
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| [90] °F. With the water temperature of the UHS > [90] °F, long term 2 EDGs cooling capability of the ECCS loads and DGs may be affected. 1 Therefore, to ensure long term cooling capability is provided to the ECCS 100 loads when water temperature of the UHS is > [90]°F, Required Action 2 A
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| B.1 is provided to more frequently monitor the water temperature of the 3 104 UHS and verify the tem t [90] °F when averaged over the 2 1
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| previous 24 hour period. The once per hour Completion Time tak es into consideration UHS temperature variations and the increased monitoring frequency needed to ensure design basis assumptions and equipment limitations are not exceeded in this condition. If the water temperature of 104 the UHS exceeds [90] °F when averaged over the previous 24 hour period 2 1
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| or the water temperature of the UHS exceeds [ ]°F, Condition C must be entered immediately.] B or 2 A
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| B
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| [ C.1 and C.2 3 If the Required Actions and Completion Times of Condition [A or B] are both units not met, or the UHS is inoperable for reasons other than Condition A [or 2 B] , the unit must be placed in a MODE in which overall plant risk is the unit one reduced. To achieve this status, the unit must be placed in at least 1 MODE 3 within 6 hours and in MODE 4 within 12 hours.
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| restore text INSERT 3 Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant 2
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| risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 1 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As 2
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| stated in Reference 3, the steam turbine driven auxiliary feedwater pump 1 must be available to remain in MODE 4. Should steam generator cooling Westinghouse STS B 3.7.9-3 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 1 INSERT 3 Condition A MODE applies CONDITION B allows for one unit to be in Mode 3 within 6 hours if the inoperability apply to one unit. The Completion Time allows for an orderly shutdown of one unit when the inoperability of a component affects only one unit. The 6 hour Completion Time is reasonable based on operating experience to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Another 6 hours is allowed to reach MODE 4 and is also reasonable based on operating experience to reach the required unit conditions in an orderly manner. CONDITION B is modified by a Note stating that this ACTION is not applicable when a dual unit shutdown is required.
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| Condition A Insert Page B 3.7.9-3
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| UHS B 3.7.9 BASES ACTIONS (continued) be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 A
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| may be made as it is also acceptable from a risk perspective.
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| B Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is 3 not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.
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| However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. ]
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| INSERT 4 SURVEILLANCE [ SR 3.7.9.1 REQUIREMENTS This SR verifies that adequate long term (30 day) cooling can be maintained. The specified level also ensures that sufficient NPSH is available to operate the SWS pumps. [ The [24] hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. This SR verifies that the UHS water level
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| [562] ft [mean sea level]. 2 OR 1 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ---------------------------------------------------------------------------------------------- ] ]
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| Westinghouse STS B 3.7.9-4 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 1 INSERT 4 B
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| applies C.1 and C.2 If the Required Actions and Completion Times of CONDITION A are not met, or the UHS is inoperable for reasons other than CONDITION A, the units must be placed in a MODE in which overall plant risk is reduced. Because this ACTION may apply to both units simultaneously to achieve this status, the second unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 18 hours. CONDITION C is modified by a Note stating that this ACTION is only applicable when a dual unit shutdown is required. Allowing one unit to be shut down to MODE 3 in 6 hours and the second unit to be shut down to MODE 3 in 12 hours, sequentially shutting down.
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| Condition B Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the steam generators and RHR System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.
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| B Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. This also allows the orderly shutdown of one unit at a time and not jeopardize the stability of the electrical grid by imposing a simultaneous dual unit shutdown.
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| Insert Page B 3.7.9-4
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| UHS B 3.7.9 BASES SURVEILLANCE REQUIREMENTS (continued) 1
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| [ SR 3.7.9.2 2 3 ICW System This SR verifies that the SWS is available to cool the CCW System to at 1 DBA least its maximum design temperature with the maximum accident or INSERT 5 normal design heat loads for 30 days following a Design Basis Accident. 1
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| [ The 24 hour Frequency is based on operating experience related to The hourly Frequency when the UHS trending of the parameter variations during the applicable MODES. This average supply temperature is >100° R t tt t t t o t [90°F] . 2 F accounts for potential daily variations in temperature. When the UHS average supply water OR non-conditional temperature exceeds 100°F the water 1 temperature must be verified at least The Surveillance Frequency is controlled under the Surveillance hourly to ensure that Cooling Canal Frequency Control Program.
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| System temperature variations are appropriately captured, thus ensuring the limit is not exceeded. (Ref. 3) -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ---------------------------------------------------------------------------------------------- ] ]
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| [ SR 3.7.9.3 O t oo to o minutes ensures that all fans are OPERABLE and that all associated controls are functioning properly.
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| It also ensures that fan or motor failure, or excessive vibration, can be detected for corrective action. [ The 31 day Frequency is based on operating experience, the known reliability of the fan units, the redundancy available, and the low probability of significant degradation of the UHS cooling tower fans occurring between surveillances.
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| OR 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ---------------------------------------------------------------------------------------------- ] ]
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| Westinghouse STS B 3.7.9-5 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| UHS B 3.7.9 BASES SURVEILLANCE REQUIREMENTS (continued)
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| [ SR 3.7.9.4 This SR verifies that each cooling tower fan starts and operates on an actual or simulated actuation signal. [ The [18] month Frequency is consistent with the typical refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
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| OR 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ---------------------------------------------------------------------------------------------- ] ]
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| U 14.
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| ==3.4 REFERENCES==
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| : 1. FSAR, Section [9.2.5]. 1 2
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| : 2. Regulatory Guide 1.27. 1 2
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| : 3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes 3 to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.
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| : 3. Letter from A. L. Klett (NRC) to M. Nazar (NextEra) dated August 8, 2014, Turkey Point Nuclear Generating Unit Nos. 3 and 4- Issuance of Amendments Under Exigent Circumstances Regarding Ultimate Heat Sink and Component Cooling Water Technical 3 Specifications (TAC Nos. MF4392 and MF4393) (NRC ADAMS Accession No. ML14199A107).
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| Westinghouse STS B 3.7.9-6 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| 7/18/22, 8:54 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1610 NRC Question JMW057 Number Select NRC Response Application Attachment 1
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| Attachment 2
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| Response In the markup attached to the response to JMW057, ITS SR 3.7.9.1 has a frequency of 1 Statement hour when UHS temperature is > 100º F. CTS SR 4.7.4.b has a frequency of At least once per hour. The proposed ITS wording could cause confusion on how often this SR is required to be performed. Please revise the ITS markup for SR 3.7.9.1 to Once per hour when UHS temperature is > 100º F to align with the CTS.
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| ===Response===
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| 7/16/2022 12:50 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date 7/16/2022 11:50 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1610 1/1
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| 8/3/22, 5:34 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1618 NRC Question JMW057 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response Section 4.1.7a of TSTF-GG-05-01, "Writers Guide for Plant-Specific Improved Technical Specifications",
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| Statement Revision 1, states:
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| Surveillance Requirements consist of short descriptions of each Surveillance and its Frequency of performance (implied as "once per").
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| As an example, many ISTS Surveillance Requirement (SR) Frequencies are performed at 31day intervals.
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| The interval designated in the "Frequency" column of these SRs simply states "31 days". In accordance with the ITS Writer's Guide and consistent with ISTS usage rules, the SR must be performed at least once every 31 days. Therefore, designating a Frequency for verifying the average temperature of the ultimate heat sink (UHS) of "1 hour" when UHS temperature is above 100 °F inherently requires this verification to occur on a once-per-hour basis until the average UHS temperature is verified to be at or below 100 °F. The proposed Frequency is a conditional based Frequency that is repeated on an hourly basis when the condition is met. Therefore, the proposed presentation meets the guidance of the ITS Writers Guide.
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| Based on the considerations herein, no further changes are proposed to ITS SR 3.7.9.1.
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| ===Response===
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| 7/20/2022 10:30 AM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Joshua Wilson Added By Christina Long Date 7/20/2022 9:33 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1618 1/1
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| 7/22/22, 3:00 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1638 NRC Question JMW057 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 7/22/2022 Date Notification Gregg Ellis Christina Long Added By Joshua Wilson Date Added 7/22/2022 1:04 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1638 1/1
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| 2/9/23, 9:05 AM Turkey Point ITS Conversion Database - New - ITS NRC Questions Turkey Point ITS Conversion Database - New Logged In As: Christina Long February 9, 2023 ITS NRC Questions NRC Question JMW058 Number Library Link Category Technical ITS Section 3.7 ITS Number 3.7.7 DOC Number JFD Number JFD Bases Number Page Number(s) 174, 175 NRC Reviewer Victor Cusumano Supervisor Technical Add Name Branch POC Conf Call Requested NRC Question During a public meeting conducted on January 31, 2023, the licensee stated their intent to revise ITS LCO 3.7.7 due to a self-identified issue that would occur during maintenance activities. Please provide the revised TS LCO 3.7.7 for NRC staff review Attach File 1 Attach File 2 Issue Date 02/08/2023 Notification Gregg Ellis Christina Long ID 813 Added By Joshua Wilson Date Added 2/8/2023 3:13 PM CST Modified By https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16624&id=813 1/2
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| 2/9/23, 9:05 AM Turkey Point ITS Conversion Database - New - ITS NRC Questions Date Modified Locked No https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16624&id=813 2/2
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| 2/21/23, 9:56 AM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure Turkey Point ITS Conversion Database - New Logged In As: Christina Long February 21, 2023 Licensee Response/NRC Response/NRC Question Closure NRC Question View Question Link Select Licensee Response Application Attachment
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| : 1. Attachment 1 - JMW058 LAR Markup (23-02-16).pdf (3MB) 1 Attachment 2
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| Response During a review of the Component Cooling Water (CCW) System proposed Improved Technical Specifications Statement (ITS) by operators, an issue was discovered associated with the CCW System operation of splitting the headers. Splitting of the CCW System headers is necessary when performing certain testing (e.g., inservice testing and post maintenance testing of the CCW pumps). When splitting the headers, one pump is aligned to each header allowing testing of an individual pump; however, the alignment results in two CCW heat exchangers aligned to one header while the other header has only one CCW heat exchanger aligned to it.
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| ITS 3.7.7, Condition A states, "One or more CCW trains inoperable due to one required CCW heat exchanger inoperable." The Limiting Condition for Operation (LCO) Bases for ITS 3.7.7 states, in part, that a CCW train is considered OPERABLE when: two common heat exchanges are OPERABLE. With one train aligned to only one CCW heat exchanger, the ITS presentation would require entry into ITS 3.7.7 Condition A and restoring the required CCW heat exchanges within one hour or commence a plant shutdown.
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| Turkey Point Units 3 and 4 current Technical Specifications (CTS) for CCW (CTS 3.7.2) states that the CCW System shall be OPERABLE with: a) Three CCW pumps, and b) Two CCW heat exchanges. CTS 3.7.2 Action
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| : c. that states, "With less than two CCW heat exchangers OPERABLE, restore two heat exchangers to OPERABLE status within 1 hour or be in Hot Standby within the next 6 hours and in Cold Shutdown within the following 30 hours." During split header operation, at least two CCW heat exchanges are considered OPERABLE since each heat exchanger can perform its intended safety function and therefore no CTS 3.7.2 Action would be applied. In this condition, current procedures require declaring the RHR heat exchanger inoperable that is associated with the ECCS train with only one CCW heat exchanger available. Additionally, one emergency containment cooling is declared inoperable. As a result, CTS 3.5.2 Action a and CTS 3.6.2.2 Action a are applied requiring restoration (i.e., restoring alignment such that at least two CCW heat exchangers can supply both CCW loops) within 72 hours or in accordance with the Risk Informed Completion Time (RICT)
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| Program.
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| To eliminate the unintended consequences as a result of the more restrictive change as a result of the ITS presentation of ITS 3.7.7 ACTION A, ITS 3.7.7 is revised as follows: Delete ITS 3.7.7 Condition A and eliminate the phrase for reasons other than Condition A from ITS 3.7.7 Conditions B and D. Additionally, the ITS 3.7.7 Conditions and Required Actions are relabeled as a result of deletion of ACTION A.
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| See Attachment 1 - JMW058 LAR Markups for proposed ITS 3.7.7 changes, including appropriate revision to CTS markup, Discussion of Changes, ISTS and Bases justifications for deviation, and ISTS Bases.
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| ATTACHMENT
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| : 1. JMW058 LAR Markups https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1708 1/2
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| 2/21/23, 9:56 AM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure
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| ===Response===
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| 02/21/2023 9:55 am Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long ID 1708 Added By Christina Long Date Added 2/21/2023 8:55 AM CST Modified By Date Modified Locked No https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1708 2/2
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| ITS A01 ITS 3.7.7 PLANT SYSTEMS (CCW) 3/4.7.2 COMPONENT COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION A02 Two trains LCO 3.7.7 3.7.2 The Component Cooling Water System (CCW) shall be OPERABLE with:
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| Two L01
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| : a. Three CCW pumps, and LA01
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| : b. Two CCW heat exchangers.
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| Applicability APPLICABILITY: MODES 1, 2, 3, and 4.
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| A With two CCW trains A03 ACTION: inoperable Required Action B.1 NOTE: Enter applicable ACTIONS of LCO 3.4.1.3, "Reactor Coolant System - Hot Shutdown," for residual heat Note removal loops made inoperable by CCW. L01
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| : a. With only two CCW pumps with independent power supplies OPERABLE, restore the inoperable CCW pump to OPERABLE status within 30 days or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
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| A B Action B b. With only one CCW pump OPERABLE or with two CCW pumps OPERABLE but not from independent power supplies, restore two pumps from independent power supplies to OPERABLE B status within 72 hours or in accordance with the Risk Informed Completion Time Program, or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following Action C 30 hours. Add proposed Required Action C.2 and associated Note L02 C one required inoperable Action A c. With less than two CCW heat exchangers OPERABLE, restore two heat exchangers to M01 OPERABLE status within 1 hour or be in HOT STANDBY within the next 6 hours and in COLD Action C SHUTDOWN within the following 30 hours.
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| Add proposed Required Action C.2 and associated Note L02 Add proposed ACTION D SURVEILLANCE REQUIREMENTS C A03 immediately enter LCO 3.0.3 4.7.2 The Component Cooling Water System (CCW) shall be demonstrated OPERABLE:
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| LA02
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| : a. In accordance with the Surveillance Frequency Control Program, by verifying that two heat exchangers and one pump are capable of removing design basis heat loads.
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| TURKEY POINT - UNITS 3 & 4 3/4 7-14 AMENDMENT NOS. 287 AND 281 Page 1 of 2
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| DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER SYSTEM (CCS)
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| ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 CTS 3.7.2 states that the Component Cooling Water System (CCW) shall be OPERABLE with: a. Three CCW pumps, and b. Two CCW Heat Exchangers.
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| ITS LCO 3.7.7 states that two CCW trains shall be OPERABLE. This changes the CTS by placing the CCW system components into separate trains.
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| The purpose of CTS 3.7.2 is to ensure that sufficient cooling capacity is available for continued operation of safety-related equipment during normal and accident conditions. The redundant cooling capacity of this system, assuming a single active failure, is consistent with the assumptions used in the safety analyses.
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| This change is acceptable because the LCO requirements continue to ensure that the structures, systems, and components are maintained consistent with the safety analyses and licensing basis. This is a change in presentation only and does not result in technical changes to the CTS.
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| A03 CTS 3.7.2 requires the Component Cooling Water System to be OPERABLE in MODES 1, 2, 3, and 4 and provide actions for various levels of system C inoperability. However, CTS does not explicitly provide actions for all degraded conditions (e.g., three CCW pumps inoperable). ITS 3.7.7 ACTION D provides similar actions for the condition when two CCW trains are inoperable for reasons other than one required CCW heat exchanger inoperable. This changes the CTS by explicitly stating when entry into LCO 3.0.3 is required.
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| Insert DOC A03 The purpose of the CTS 3.7.2 actions is to ensure applicable Actions are taken when the CCW System is degraded and when multiple system components are inoperable that results in a loss the required safety function. CTS does not provide action in these conditions which prompts entry into CTS 3.0.3.
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| CTS 3.0.3 (ITS LCO 3.0.3) requires a plant shutdown when no actions are provided in the associated Technical Specifications for the specified condition.
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| ITS Section 1.3, Completion Times, states that if situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. In addition, when a combination of Conditions stated in the ACTIONS can be made that corresponds to the actual condition of the unit, ITS LCO 3.0.3 is not required. As a result, if one required CCW heat exchanger is inoperable concurrent with a redundant required CCW pump inoperable, ITS 3.7.7 ACTIONS A and B would apply instead of LCO 3.0.3. ITS 3.7.7 ACTION D is provided to specifically state a Condition corresponding to CCW System inoperable combinations that warrants entry into LCO 3.0.3 (i.e.,
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| Turkey Point Unit 3 and Unit 4 Page 1 of 7
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| Insert DOC A03 The purpose of CTS actions is to ensure applicable Actions are taken based on the level of CCW System degradation and when multiple system components are inoperable that results in a loss the required safety function, a plant shutdown is required.
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| CTS 3.7.2 Actions a and b provide remedial actions when one or two CCW pumps are inoperable or when at least two CCW pumps are not powered from independent power supplies.
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| Except for CTS 3.7.2 Action c, which provides actions for the condition of less than two OPERABLE CCW heat exchangers, CTS 3.7.2 does not provide explicit actions for conditions when multiple system components are inoperable (e.g., three inoperable CCW pumps) that represents a loss of cooling capability to both CCW cooling loops (i.e.,
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| trains). Therefore, CTS 3.0.3 would apply. Due to the multiple CCW cooling loop configurations available, ITS 3.7.7 ACTION C ensures proper application of the ITS in a condition when neither CCW train can provide the required safety function, which requires at least one OPERABLE cooling pump and two OPERABLE heat exchangers aligned to at least one cooling loop. ITS 3.7.7 ACTION C requires that when two CCW trains are inoperable (e.g., three inoperable CCW pumps or less than two CCW heat exchangers are OPERABLE) LCO 3.0.3 is entered immediately. This changes the CTS requirements in presentation and format only. This change is designated as administrative because it does not result in technical changes to the CTS.
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| DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER SYSTEM (CCS) two CCW trains inoperable for reasons other than one required CCW heat exchanger inoperable). This change is acceptable because the actions associated with a condition in CTS that warrant entry into LCO 3.0.3 will continue to be taken in ITS in accordance with the ITS rules of usage. This change is considered administrative because no technical changes are being made to the CTS.
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| A04 CTS 4.7.2.b.1) does not contain explicit guidance concerning CCW system OPERABILITY when isolating CCW flow to individual components. ITS Surveillance Requirement (SR) 3.7.7.1 contains a Note, which states, "Isolation of CCW flow to individual components does not render the CCW system inoperable." This changes the CTS by adding an allowance that is not explicitly stated in the CTS.
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| The purpose of CTS 4.7.2.b.1) is to provide assurance that CCW is available to the appropriate plant components. This change is acceptable because by current use and application of the CTS, isolation of a component supplied with CCW does not necessarily result in a CCW system being considered inoperable, but the respective component may be declared inoperable for its system. This change clarifies this application.
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| This change is designated as administrative because it does not result in technical changes to the CTS.
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| A05 CTS 4.7.2.b.1) requires verification that each CCW valve (manual, power operated, or automatic) servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position. CTS 4.7.2.c.1) requires verification that each CCW automatic valve servicing safety related equipment actuates to its correct position on a Safety Injection test signal. ITS SR 3.7.7.1 requires verification that each CCW manual, power operated, and automatic valve in the flow path servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in the correct position. ITS SR 3.7.7.2 requires verification that each CCW automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal. This changes the CTS by adding the words "in the flow path" to CTS 4.7.2.b.1) (ITS SR 3.7.7.1) and replacing the words "servicing safety related equipment" with "in the flow path" in CTS 4.7.2.c.1) (ITS SR 3.7.7.2).
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| The purpose of CTS 4.7.2.b.1) is to ensure all valves in the CCW flow path are in the correct position. The purpose of CTS 4.7.2.c.1) is to provide assurance that each CCW automatic valve actuates to its correct position. The addition of the words "in the flow path" to CTS 4.7.2.b.1) (ITS SR 3.7.7.1) does not change the intent of the Surveillance Requirement. Each manual, power operated, and automatic valve servicing safety related equipment that is not locked, sealed, or otherwise secured in position will continue to be verified to be in the correct position. The removal of the words "servicing safety related equipment" in CTS 4.7.2.c.1) (ITS SR 3.7.7.2) does not change the intent of the Surveillance Requirement. Each CCW automatic valve in the flow path that is not locked, sealed or otherwise secured in position, will still be checked to ensure it actuates to the correct position on an actual or simulated Safety Injection actuation signal.
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| Turkey Point Unit 3 and Unit 4 Page 2 of 7
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| DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER SYSTEM (CCS)
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| This change is designated as administrative because it does not result in technical changes to the CTS.
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| A06 CTS 4.7.2.c.2) requires verification that each CCW System pump starts automatically on a SI test signal. CTS 4.7.2.c.3) requires verification that the interlocks required for CCW OPERABILITY are OPERABLE. ITS SR 3.7.7.3 requires verification that each CCW pump starts automatically on an actual or simulated actuation signal. This changes the CTS by removing the duplicative requirement to verify that the interlocks required for OPERABILITY are OPERABLE, aligning those interlocks to the requirement to verify the CCW pumps start automatically on a SI test signal.
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| The purpose of CTS 4.7.2.c.3) is to verify the interlocks required for system OPERABILITY are OPERABLE. The associated interlock is the starting of the C CCW pump automatic start on an SI test signal when either CCW pump A or B breaker is racked out and the C CCW pump power supply is aligned to the racked out pump's power supply. The C CCW pump is interlocked with the A and B CCW pump such that the C CCW pump can only start automatically on an SI signal when aligned to replace either the A or B CCW pump. Because both of the CTS surveillances are associated with the automatic starting of the CCW pumps on an SI signal, the duplicative surveillance is being deleted. This change is acceptable because the test requirements and frequency regarding the CCW pumps remain the same. This change is designated as administrative because it does not result in technical changes to the CTS.
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| MORE RESTRICTIVE CHANGES None Insert DOC M01 RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.7.2 requires the Component Cooling Water System (CCW) to be OPERABLE with: a. Three CCW pumps, and b. Two CCW heat exchangers (Changed to two CCW pumps by DOC L01). ITS LCO 3.7.7 requires two CCW trains to be OPERABLE but does not define the components and the associated flow path that comprise an OPERABLE CCW train. This changes the CTS by moving the description of the CCW trains to the Bases.
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| The removal of these details which are related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included to provide adequate protection of public health and safety. The ITS still retains the requirement for both CCW trains to be OPERABLE. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are Turkey Point Unit 3 and Unit 4 Page 3 of 7
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| Insert DOC M01 M01 CTS 3.7.2 Action c requires that with less than two CCW heat exchangers OPERABLE, restore two heat exchangers to OPERABLE status within 1 hour or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. ITS 3.7.7 ACTION C requires that with two CCW trains inoperable to enter LCO 3.0.3 immediately, which includes the condition of less than two CCW heat exchanges OPERABLE. This changes the CTS by explicitly stating when entry into LCO 3.0.3 is required which results in the additional requirement to be MODE 4 within a specified time period for the condition with less than two OPERABLE CCW heat exchangers.
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| The purpose of CTS actions is to ensure applicable Actions are taken based on the level of CCW System degradation and when multiple system components are inoperable that results in a loss of the required safety function, a plant shutdown is required.
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| CTS 3.7.2 Action c provides actions for the condition where the number of CCW heat exchangers OPERABLE will not support the ability of the CCW System to perform its specified safety function. CTS 3.7.2 Action c requires restoration of two CCW heat exchangers to OPERABLE status within one hour or be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours (37 hours total).
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| ITS 3.7.7 ACTION C provides a requirement to immediately enter LCO 3.0.3 when two CCW trains are inoperable, which includes the condition of less than two CCW heat exchanges OPERABLE. LCO 3.0.3 requires that within 1 hour action shall be initiated to place the unit, as applicable, to be in: a) MODE 3 in 7 hours (i.e., Hot Standby within the next 6 hours, b) MODE 4 in 13 hours (i.e., Hot Shutdown within the following 6 hours),
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| and c) MODE 5 in 37 hours (i.e., Cold Shutdown within the subsequent 24 hours).
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| In addition to the CTS 3.0.3 Actions that are equivalent to CTS 3.7.2 Action c, application of ITS LCO 3.0.3 (CTS 3.0.3) also requires the unit to be in MODE 4 in 13 hours, which is more restrictive than CTS 3.7.2 Action c actions and is appropriate because this condition represents a loss of the required safety function. This change is designated as more restrictive because the remedial actions are more stringent in ITS than in CTS.
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| DISCUSSION OF CHANGES ITS 3.7.7, COMPONENT COOLING WATER SYSTEM (CCS) purpose of the CTS action requirement is to provide appropriate remedial actions when the LCO is not met consistent with the requirements of 10 CFR 50.36(c)(2)(i). Required Actions are used to establish remedial measures that must be taken in response to degraded conditions in order to minimize risk associated with continued plant operation while providing time to repair inoperable equipment. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the remaining CCW equipment, a reasonable time for repairs or replacement of required equipment, and the low probability of a design basis accident occurring during the time period. The redundant cooling capacity of this system, assuming a single active failure, is consistent with the assumptions used in the safety analyses. The CCW System design includes an installed spare pump and heat exchanger that can be aligned to either CCW loop to provide adequate cooling to the required components. One pump and two heat exchangers provide the heat removal capability for accidents that have been analyzed. This change is acceptable because the LCO requirements continue to ensure that the number of CCW pumps required to be OPERABLE maintains the minimum cooling capacity of the system assuming a single active failure and maintained consistent with the safety analyses and licensing basis. In addition, eliminating the TS requirement for the third CCW pump to be OPERABLE is acceptable because other regulatory requirements ensure the degradation of structures, systems, and components (SSCs) will not result in undue risk to the health and safety of the public. Pursuant to 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, PTN monitors the performance or condition of SSCs, against established Maintenance Rule goals, in a manner sufficient to provide reasonable assurance that SSCs are capable of fulfilling their intended functions. When the performance or condition of an SSC does not meet established goals, appropriate corrective action will be taken to ensure the risk to the health and safety of the public is minimized. Therefore, NRC regulations contain the necessary programmatic requirements to ensure SSCs are capable of fulfilling their intended functions and appropriate compensatory actions are taken to minimize risk to the health and safety of the public. This change is designated as less restrictive because less stringent LCO requirements and actions are being applied in the ITS than were applied in the CTS.
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| L02 (Category 4 - Relaxation of Required Action) CTS 3.7.2, ACTIONS a, b, and c, identify degraded conditions of the CCW system and provides specific b identifies a Completion Times to restore the degraded condition or commence a unit shutdown. If a unit shutdown is required, each CTS 3.7.2 Action requires the unit B be in HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. ITS 3.7.7 ACTION C, similarly, states that if the Required Action and associated Completion Time of Condition A or B not met, to be in MODE 3 in 6 hours and MODE 4 in 12 hours and is modified by a Note stating that LCO 3.0.4.a is not applicable when entering MODE 4. This changes the CTS by permitting a Required Action end state of HOT SHUTDOWN (MODE 4) rather that an end state of COLD SHUTDOWN (MODE 5).
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| One purpose of CTS 3.7.2, ACTIONS a, b, and c is to provide an end state, a condition that the reactor must be placed in, if the Required Actions allowing remedial measures to be taken in response to the degraded conditions with Turkey Point Unit 3 and Unit 4 Page 5 of 7
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| CTS CCW System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System 3.7.2 LCO 3.7.7 Two CCW trains shall be OPERABLE.
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| Applicability APPLICABILITY: MODES 1, 2, 3, and 4.
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| ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A INSERT 1 A B B 3.7.2 Action b A. One CCW train A.1 --------------NOTE-------------- 2 inoperable. Enter applicable Conditions for reasons other and Required Actions of than Condition A. LCO 3.4.6, "RCS Loops -
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| MODE 4," for residual heat removal loops made inoperable by CCW.
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| Restore CCW train to 72 hours OPERABLE status.
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| [OR 3 In accordance with the Risk Informed Completion Time B Program] 3 C C 3.7.2 Action b, B. Required Action and B.1 Be in MODE 3. 6 hours 2 3.7.2 Action c.
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| associated Completion B Time of Condition A not AND 2 met. or B C 2
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| B.2 --------------NOTE--------------
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| LCO 3.0.4.a is not DOC L01 applicable when entering MODE 4.
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| 2 -------------------------------------
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| DOC L01 Be in MODE 4. 12 hours 1
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| INSERT 2 Westinghouse STS 3.7.7-1 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 AMENDMENT Nos. XXX and YYY
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| CTS ITS 3.7.7 2
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| INSERT 1 Action c. A. One or more CCW trains A.1 Restore required CCW heat 1 hour inoperable due to one exchanger to OPERABLE required CCW heat status.
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| exchanger inoperable.
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| 1 2
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| INSERT 2 C
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| DOC A03 D. Two CCW trains D.1 Enter LCO 3.0.3. Immediately DOC M01 inoperable for reasons other than Condition A.
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| Insert Page 3.7.7-1
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| JUSTIFICATION FOR DEVIATIONS ITS 3.7.7, COMPONENT COOLING WATER (CCW) SYSTEM
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| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 2. The ISTS is based on a single plant design with two redundant CCW trains consisting of a CCW pump and associated heat exchanger, and a swing pump that can be aligned to either CCW train. The PTN design also includes three CCW pumps but, in addition, includes three CCW heat exchangers downstream of the CCW pumps via a common discharger header. The safety analysis requires two of Due to multiple CCW three heat exchangers and one of three CCW pumps to be OPERABLE to support cooling loop the safety function. The changes continue to meet the intent of the ISTS configurations requirement and made to align the PTN Technical Specifications, as reasonably available, practical, with the ISTS. ITS 3.7.7 ACTION A is added to address one of two C
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| required heat exchangers inoperable consistent with the CTS Actions. ITS 3.7.7 ACTION D is added to ensure proper application of the ITS in a condition when one required CCW pump is inoperable concurrent with one required CCW heat neither CCW train exchanger. Refer to ISTS 3.5.1, Accumulators, Condition D as an example of this can provide the ITS presentation, which has been previously approved and determined acceptable. required safety Subsequent Conditions and Required Actions have been relabeled to reflect the function, which requires at least one additions and deletions. OPERABLE cooling pump and two
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| : 3. The ISTS contains bracketed information and/or values that are generic to OPERABLE heat exchangers aligned Westinghouse vintage plants. The brackets are removed, and the proper plant to at least one specific information/value is inserted to reflect the current licensing basis. cooling loop.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| CCW System B 3.7.7 B 3.7 PLANT SYSTEMS B 3.7.7 Component Cooling Water (CCW) System BASES BACKGROUND The CCW System provides a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident (DBA) or transient. During normal operation, the CCW System also provides this function for various nonessential components, as well as the spent fuel storage pool. The CCW System serves as a barrier to the release of radioactive byproducts between potentially radioactive systems and the Service Water System, and thus to the environment.
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| The A typical CCW System is arranged as two independent, full capacity cooling loops, and has isolatable nonsafety related components. Each safety related train includes a full capacity pump, surge tank , heat 1 The CCW System design also exchanger, piping, valves, and instrumentation. Each safety related train includes three heat is powered from a separate bus. An open surge tank in the system exchangers that are common provides pump trip protective functions to ensure that sufficient net to both cooling loops.
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| positive suction head is available. The pump in each train is automatically started on receipt of a safety inj ection signal, and all nonessential components are isolated.
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| INSERT 1 Additional information on the design and operation of the system, along U
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| 9.3.2 with a list of the components served, is presented in the FSAR, 1 Section [9.2.2] (Ref. 1). The principal safety related function of the CCW 2 System is the removal of decay heat from the reactor via the Residual Heat Removal (RHR) System. This may be during a normal or post accident cooldown and shutdown.
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| APPLICABLE The design basis of the CCW System is for one CCW train to remove the SAFETY post loss of coolant accident (LOCA) heat load from the containment ANALYSES sump during the recirculation phase, with a maximum CCW temperature of [120] °F (Ref. 2). The Emergency Core Cooling System (ECCS) LOCA and containment OPERABILITY LOCA each model the maximum and minimum performance of the CCW System, respectively. The normal 1
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| temperature of the CCW is [80] °F, and, during unit cooldown to MODE 5 (Tcold < [200]°F), a maximum temperature of 95°F is assumed. This prevents the containment sump fluid from increasing in temperature during the recirculation phase following a LOCA, and provides a gradual reduction in the temperature of this fluid as it is supplied to the Reactor Coolant System (RCS) by the ECCS pumps.
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| INSERT 2 The CCW System is designed to perform its function with a single failure of any active component, assuming a loss of offsite power.
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| Westinghouse STS B 3.7.7-1 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| ITS 3.7.7 The CCW pumps and heat exchangers are arranged such 1 that any combination of pumps and heat exchangers can INSERT 1 supply either CCW cooling loop. The CCW trains are normally cross-tied at common suction and discharge headers and can be separated by closing crosstie valves between headers.
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| In addition, the CCW System design includes an additional CCW pump and associated heat exchanger that can swing from one train to the other, with interlocks to ensure the swing pump/heat exchanger combination can serve as a backup to either CCW train. During normal full power operation, one component cooling water pump and two or three component cooling water heat exchangers accommodate the heat removal loads. Each of the two standby pumps provides 100% backup, during normal operation.
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| The CCW heat loads are transferred by the CCW System to the Intake Cooling Water (ICW)
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| System. The CCW System serves as an intermediate system to provide a barrier between the ICW and the CCW cooled components. This barrier prevents any potential leakage of radioactive fluid into the environment or any saltwater intrusion into the Reactor Coolant System.
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| The CCW head tank accommodates normal expansion and limited in-leakage of water. The head tank and surge tank combine to accommodate contraction and ensure a continuous component cooling water supply until the leak can be isolated.
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| Each pump is automatically started on receipt of a start signal from the emergency bus load sequencer, and all nonessential components are isolated. The emergency bus load sequencer is actuated by a loss of offsite power (LOOP), a safety injection (SI) signal on its associated unit, a SI from the opposite unit, or a combination LOOP/LOCA. CCW pumps A and B are sequenced on by their associated train sequencer for these actuation signals except for the opposite units SI signal without a LOOP. A swing 4.16 kV emergency bus provides power to the swing CCW pump and can be manually aligned to either the A or B train 4.16 kV bus. The swing CCW pump is sequenced based on which AC electrical power train the 4.16 kV swing bus is aligned to. In addition, the swing pump is interlocked with the A and B CCW pumps such that for a pump start signal to initiate the swing pump on a LOOP or SI signal, the supply breaker associated with the train to which the swing pump is aligned must be open and racked out.
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| With offsite power available the CCW pumps receive a start signal 25 seconds (nominally) after the sequencer load timing begins; 41 seconds (nominally) with offsite power unavailable.
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| Insert Page B 3.7.7-1a
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| If one CCW train is inoperable (e.g., an inoperable CCW pump associated with 1 the train or associated CCW pump not capable of supplying at least two heat exchangers), action must be taken to restore the CCW train to OPERABLE status within 72 hours or in accordance with the Risk Informed Completion Time CCW System Program. In this Condition, the remaining OPERABLE CCW train is adequate to perform the heat removal function. The 72 hour Completion Time is reasonable, B 3.7.7 based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this period.
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| BASES STET 1
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| ACTIONS A.1 Required Action A.1 is modified by a Note indicating that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"
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| be entered if an inoperable CCW train results in an inoperable RHR loop. 1 This is an exception to LCO 3.0.6 and ensures the proper actions are tak en for these components.
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| one or more CCW trains a required heat exchanger are inoperable due to required heat exchanger If one CCW train is inoperable, action must be tak en to restore 1
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| OPERABLE status within 72 hours [or in accordance with the Risk 2
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| . The 1 hour Completion Time Informed Completion Time Program]. In this Condition, the remaining to restore a required CCW heat exchanger to OPERABLE status OPERABLE CCW train is adequate to perform the heat removal function. 1 is consistent with other The 72 hour Completion Time is reasonable, based on the redundant Completion Times established capabilities afforded by the OPERABLE train, and the low probability of a for loss of a safety function and ensures that the plant will not DBA occurring during this period.
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| operate for long periods outside INSERT 5 1 of the safety analyses.
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| C B.1 and B.2 B 3
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| a require heat exchanger or one If the CCW train cannot be restored to OPERABLE status within the 1 the associated Completion Time, the unit must be placed in a MODE in which overall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 4 within 12 hours.
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| Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the steam generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven auxiliary feedwater pump must be available to remain in MODE 4. Should steam generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.
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| B C
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| Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is 3 not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.
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| However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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| Westinghouse STS B 3.7.7-3 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| ITS 3.7.7 1
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| INSERT 5 B.1 Required Action B.1 is modified by a Note indicating that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," be entered if an inoperable CCW train results in an inoperable RHR loop. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.
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| If one CCW train is inoperable for reasons other than Condition A, action must be taken to restore the CCW train to OPERABLE status within 72 hours or in accordance with the Risk Informed Completion Time Program. In this Condition, the remaining OPERABLE CCW train is adequate to perform the heat removal function. The 72 hour Completion Time is reasonable, based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this period.
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| Insert Page B 3.7.7-3
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| CCW System B 3.7.7 BASES ACTIONS (continued)
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| The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power 3 conditions in an orderly manner and without challenging unit systems.
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| INSERT 6 1 SURVEILLANCE SR 3.7.7.1 5 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable but does not affect the OPERABILITY of the CCW System.
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| Verifying the correct alignment for manual, power operated, and automatic valves in the CCW flow path provides assurance that the proper flow paths exist for CCW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
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| [ The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| SR 3.7.7.2 This SR verifies proper automatic operation of the CCW valves on an actual or simulated actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under Westinghouse STS B 3.7.7-4 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| ITS 3.7.7 3
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| 5 1
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| INSERT 6 C neither CCW train can provide the required safety function, which requires at least one OPERABLE cooling pump and two D.1 OPERABLE heat exchangers aligned to at least one cooling loop If both CCW trains are inoperable for reasons other than Condition A, the plant is in a condition outside the accident analyses; therefore, LCO 3.0.3 must be entered immediately.
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| Insert Page B 3.7.7-4
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| CCW System B 3.7.7 BASES SURVEILLANCE REQUIREMENTS (continued) administrative controls. [ The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when 2 performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
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| OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| SR 3.7.7.3 This SR verifies proper automatic operation of the CCW pumps on an actual or simulated actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. [ The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when 2 performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
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| 6 OR INSERT 7 1 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWER S NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 4 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| Westinghouse STS B 3.7.7-5 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Revision XXX
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| ITS 3.7.7 6
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| 1 INSERT 7 The CCW swing pump (C pump) is interlocked to prevent starting if CCW pumps A and B are aligned for starting. For a start signal to initiate starting the swing pump on a LOOP or SI signal, the supply breaker for the CCW pump, associated with the AC electrical power distribution train to which it is aligned, must be open and racked out. Testing the automatic starting of the swing CCW pump includes testing this interlock.
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| Insert Page B 3.7.7-5
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| JUSTIFICATION FOR DEVIATIONS ITS 3.7.7 BASES, COMPONENT COOLING WATER (CCW) SYSTEM
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| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed, and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. Where a deletion has occurred, subsequent alphanumeric designators have been changed for any applicable affected Required Actions, Surveillance Requirements, Functions, and Footnotes.
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| : 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
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| Changes made to the Bases reflect the changes made to the Specification. Due to the multiple CCW cooling loop configurations available, ITS 3.7.7 ACTION C is added to ensure proper application of the ITS in a condition when neither CCW train can provide the required safety function, which requires at least one OPERABLE cooling pump and two OPERABLE heat exchangers aligned to at least one cooling loop.
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 2/28/23, 1:26 PM Turkey Point ITS Conversion Database - New - Licensee Response/NRC Response/NRC Question Closure Turkey Point ITS Conversion Database - New Logged In As: Christina Long February 28, 2023 Licensee Response/NRC Response/NRC Question Closure NRC Question Link View Question Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 02/28/2023 Date Notification Gregg Ellis Christina Long ID 1709 Added By Joshua Wilson Date Added 2/28/2023 12:18 PM CST Modified By Date Modified Locked No https://taktixwf.certrec.com/6050?req=areaItemPrint&a=16625&id=1709 1/1
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| 3/17/22, 4:58 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 61 NRC Question KAB001 Number Category Technical ITS 3.8 Section ITS 3.8.1 Number DOC LA-1 Number JFD Number JFD Bases Number Page Page 9 of 17 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.1 discussion of changes (DOC) page 9 of 17, DOC L01 states, "ITS ACTION J Question requires that with the Required Action and associated Completion Time of Condition A, B, C, D, E, F, G, or H not met to be in MODE 3 in 6 hours and MODE 4 in 12 hours." However, on ITS 3.8.1 page 3.8.1-4 Condition J is entered when Required Action and associated Completion Time of Condition A, B, C, D, E, F, G, H, or I not met. Update DOC L01 to reflect all the Conditions listed in ITS 3.8.1 Condition J or provide a technical basis explaining the difference.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 3:56 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=61 1/1
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| 8/14/22, 10:00 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 65 NRC Question KAB001 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the LAR. Revision 1 of the FPL ITS Statement Conversion license amendment request (LAR) revises ITS 3.8.1 such that DOC L01 is now DOC L02. As part of this revision, ITS 3.8.1, ACTION I, was changed to ACTION H and ACTION J was changed to ACTION I.
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| The new Condition I for ACTION I states, "Required Action and associated Completion Time of Condition A, B, C, D, E, F, G, or H not met."
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| ITS 3.8.1, DOC L02, has been modified in Revision 1 of the LAR such that the sentence in question states, "ITS 3.8.1, ACTION I, requires that with the Required Action and associated Completion Time of Condition A, B, C, D, E, F, G, or H not met to be in MODE 3 in 6 hours and MODE 4 in 12 hours." The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.1, AC Sources - Operating, Revision 1, of the ITS conversion LAR.
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| ===Response===
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| 4/1/2022 8:55 PM Date/Time Closure Statement Question Closure 4/1/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/1/2022 7:57 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=65 1/1
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| 5/23/22, 2:07 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 443 NRC Question KAB001 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/23/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/23/2022 9:18 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=443 1/1
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| 3/17/22, 5:00 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 65 NRC Question KAB002 Number Category Technical ITS 3.8 Section ITS 3.8.1 Number DOC L-3 Number JFD Number JFD Bases Number Page Page 10 of 17 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.1 discussion of changes (DOC) page 10 of 17, DOC L03 states, "ITS 3.8.1 Required Question Action E.3.2 allows 24 hours to perform a similar check on the remaining OPERABLE EDGs."
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| On ITS 3.8.1 page 3.8.1-2, it shows Required Actions E.1, E.3, E.4.1 and E.4.2 with Required Action E.4.2 requiring within 24 hours the performance of SR 3.8.1.6 (EDG start from standby condition) for operable EDGs. Revise DOC L03 to reflect ITS required action E.4.2 instead of E.3.2 or explain why it is appropriate to reference Required Action E.3.2.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 3:59 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=65 1/1
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| 8/14/22, 10:00 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 69 NRC Question KAB002 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the LAR. Revision 1 of the FPL ITS Statement Conversion license amendment request (LAR) revises ITS 3.8.1 such that CTS 3.8.1.1, ACTION c.2, is now mapped to ITS 3.8.1, Required Actions C.3.1 and C.3.2. In addition, DOC L03 is changed to DOC L04 in Revision 1 of the LAR. Revision 1, ITS 3.8.1, DOC L04, has been revised to state, "ITS 3.8.1, Required Action C.3.2, allows 24 hours to perform a similar check on the remaining OPERABLE EDGs." The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.1, AC Sources - Operating, Revision 1, of the ITS Conversion LAR.
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| ===Response===
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| 4/1/2022 9:00 PM Date/Time Closure Statement Question Closure 4/1/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/1/2022 8:00 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=69 1/1
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| 5/23/22, 2:06 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 447 NRC Question KAB002 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/23/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/23/2022 9:34 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=447 1/1
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| 3/17/22, 5:03 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 69 NRC Question KAB003 Number Category Technical ITS 3.8 Section ITS 3.8.1 Number DOC Number JFD Number JFD Bases Number Page Page 3.8.1-3 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.1 page 3.8.1-3 for ITS 3.8.1, Required Action G.1 proposes a completion time of 72 hours. CTS Question 3.8.1.1 Action a.3 is entered when one of two startup transformers or an associated circuit are inoperable in Mode 1 and has a 72 hour (24hrs + 48hrs) Completion Time if rated thermal power is not reduced.
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| However, CTS 3.8.1.1 Action a.5 addresses the same equipment inoperability when the unit is in Modes 2, 3, or 4 and has an completion time of 24 hours or in accordance with the Risk Informed Completion Time Program. Changing the CTS 3.8.1.1 Action a.5 completion time from 24 hours to the proposed 72 hours is less restrictive. Provide the basis for the less restrictive change from 24 hours to 72 hours for CTS 3.8.1.1 Action a.5.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:02 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=69 1/1
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| 8/14/22, 10:01 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 194 NRC Question KAB003 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the LAR. Revision 1 of the FPL ITS Statement Conversion license amendment request (LAR) addresses and justifies the change from 24 hours to 72 hours for operation in MODES 2, 3, and 4 in revised DOC L01. The proposed Completion Time is consistent with the 72-hour Completion Time currently allowed when a startup transformer or an associated circuit is inoperable for the associated unit when in MODE 1 without a power reduction. Operation in MODES 2, 3, and 4 typically represents less risk than operation in MODE 1. Limiting operation in in MODE 2, 3, or 4 with the unit offsite circuit inoperable to 72 hours or in accordance with the Risk Informed Completion Time Program is, therefore, reasonable and acceptable. The ITS 3.8.1 ACTION for an inoperable unit offsite circuit is consistent with the ISTS and provides acceptable remedial actions pursuant to 10 CFR 50.36(c)(2)
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| (i).
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| The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.1, AC Sources - Operating, Revision 1, of the ITS Conversion LAR.
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| ===Response===
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| 4/13/2022 6:35 PM Date/Time Closure Statement Question Closure 4/13/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/13/2022 5:36 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=194 1/1
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| 5/24/22, 10:48 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 459 NRC Question KAB003 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/24/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/24/2022 9:47 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=459 1/1
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| 3/17/22, 5:07 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 73 NRC Question KAB004 Number Category Technical ITS 3.8 Section ITS 3.8.4 Number DOC LA-1 Number JFD Number JFD Bases Number Page page 2 of 7 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.4 discussion of changes (DOC) page 2 of 7, DOC LA01 states, "ITS LCO 3.8.4 states that Train A Question and Train B of the DC electrical power subsystem shall be OPERABLE." On ITS 3.8.4 page 3.8.4-1, ITS 3.8.4 LCO states, "Four Trains of DC electrical power subsystems shall be OPERABLE." Explain this discrepancy between the referenced LCO trains or revise LA01.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:05 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=73 1/1
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| 8/14/22, 10:01 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 70 NRC Question KAB004 Number Select Licensee Response Application Attachment Attachment 1 - KAB004 LAR Markup.pdf (672KB) 1 Attachment 2
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| Response ITS LCO 3.8.4 was changed to state, "Four DC electrical power trains shall be OPERABLE," without Statement updating DOC LA01. ITS 3.8.4, DOC LA01, will be revised to match ITS LCO 3.8.4.
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| A markup of the affected ITS 3.8.4 DOC page is attached.
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| ===Response===
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| 4/12/2022 11:55 AM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/12/2022 10:53 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=70 1/1
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| DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING however, credit may be taken for unplanned events that satisfy this SR. This changes the CTS requirement by specifying conditions for when the associated vital batteries are tested.
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| The purpose of CTS 4.8.2.1.d is to verify the OPERABILITY of the DC Batteries.
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| The addition of the Note limiting the conditions under which the Surveillance can be performed is acceptable because performance of the Surveillance on in-service batteries could cause perturbations to the electrical distribution system.
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| Restricting performance of the Surveillance to a battery not in-service during MODES 1, 2, 3, and 4 minimizes challenges to continued steady state operation and, as a result, the units safety systems. In addition, providing a statement that credit may be taken if the surveillance is performed during unplanned event does not change the CTS because credit can be taken if it can be shown the unplanned event satisfied the surveillance. This change is designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES four LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.2.1 states that the DC electrical sources shall be trains OPERABLE and lists the details of what constitutes a DC electrical source. ITS LCO 3.8.4 states that Train A and Train B of the DC electrical power subsystem shall be OPERABLE. This changes the CTS by moving the details of what constitutes an OPERABLE DC electrical power train (battery and charger) from the CTS to the ITS Bases.
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| The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements for the Vital 125 VDC subsystem trains. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases.
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| Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.1.a.2) requires verifying total battery terminal voltage to be greater than or equal to 129 volts on float charge and the battery charger(s) output voltage to be 129 volts. ITS SR 3.8.4.1 requires the verification that the Turkey Point Unit 3 and Unit 4 Page 2 of 7
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| 5/25/22, 12:50 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 467 NRC Question KAB004 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/25/2022 10:23 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=467 1/1
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| 3/17/22, 5:07 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 77 NRC Question KAB005 Number Category Technical ITS 3.8 Section ITS 3.8.4 Number DOC Number JFD Number JFD Bases Number Page Page 4 of 7 Number(s)
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| NRC Reviewer Select Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.4 discussion of changes (DOC) page 4 of 7, DOC L01 states, "(see DOC L02 for change from 2 Question hours to 72 hours)." On ITS 3.8.4 DOC page 5 of 7, DOC L02 discusses the change to allow a battery and required charger in the same train to be inoperable concurrently. DOC L03 discusses the change of the completion time from 2 hours to 72 hours. Provide a revised DOC L01 with reference to L03 or explain why it is appropriate to reference DOC L02 Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:06 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=77 1/1
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| 8/14/22, 10:02 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 74 NRC Question KAB005 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the LAR. Revision 1 of the FPL ITS Statement Conversion license amendment request (LAR) has revised the DOCs such that the reference to DOC L02 in DOC L01 was removed since the markup of the associated CTS page appropriately maps the Completion Time change from 2 hours to 72 hours to DOC L02 (in Revision 1 of the LAR, the Completion Time change is now addressed in DOC L02). The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.4, DC Sources - Operating, Revision 1, of the ITS Conversion LAR.
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| ===Response===
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| 4/12/2022 12:05 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 11:04 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=74 1/1
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| 5/28/22, 12:36 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 483 NRC Question KAB005 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/27/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/27/2022 10:01 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=483 1/1
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| 3/17/22, 5:08 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 81 NRC Question KAB006 Number Category Technical ITS 3.8 Section ITS 3.8.4 Number DOC L-2 Number JFD Number JFD Bases Number Page multiple - see question Number(s)
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| NRC Reviewer Select Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.4 discussion of changes (DOC) page 5 of 7, DOC L02 states, "Thus ITS 3.8.4 ACTION E covers Question both battery and chargers in one train concurrently inoperable." ITS 3.8.4 Condition E is entered when one DC electrical power train is inoperable for reasons other than Conditions A, B, C, or D. ITS 3.8.4 Condition A is entered when one required battery charger on one train is inoperable and allows 72 hours to restore the required battery charger to operable status. Condition B is entered when one battery in one train is inoperable and allows 2 hours to restore the battery to operable status. If both battery and chargers in one train are concurrently inoperable, ITS 3.8.4 requires entry into both Conditions A and B. ITS 3.8.4 Condition E is not entered in this case, because it is not for a reason other than that stated in Conditions A and B. CTS does not have an ACTION equivalent to ITS 3.8.4 Condition E and therefore would require entry into CTS limiting conditions for operation (LCO) 3.0.3. Provide a revised DOC for adding ITS 3.8.4 Condition E.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:07 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=81 1/1
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| 8/14/22, 10:03 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 255 NRC Question KAB006 Number Select Licensee Response Application Attachment Attachment 1 - KAB006 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response ITS 3.8.4, Condition E (ITS 3.8.4, Condition C, in ITS Conversion LAR, Revision 1), is consistent with CTS Statement 3.8.2.1, Action b (DC Sources - Operating) and CTS 3.8.3.1, Action d (Onsite Power Distribution Operating).
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| With one DC bus not energized from its associated battery bank or associated charger, CTS 3.8.3.1, Action d, requires, in part, reenergizing the DC bus from its associated battery bank within two hours or in accordance with the Risk Informed Completion Time Program. Therefore, CTS 3.0.3 would not be applied when the required battery bank and both full capacity battery chargers in one train are inoperable since actions are provided for this condition. Additionally, CTS 3.8.2.1, Action b, would be applied because one required battery bank is inoperable and both full capacity chargers are inoperable, resulting in the DC electrical power distribution train being inoperable. CTS 3.8.2.1, Action b, is applied as an inclusive condition when any combination of required battery or chargers are inoperable and the grammatical conjunction "or" is not treated as a logical connector "OR" as described in ITS Section 1.2, Logical Connectors. ITS 3.8.4, Required Action E.1 (ITS 3.8.4, Required Action C.1, in ITS Conversion LAR, Revision 1), is technically equivalent to the CTS requirements, consistent with both CTS 3.8.2.1, Action b, and CTS 3.8.3.1, Action d. Therefore, the addition of ITS 3.8.4, Condition E (ITS 3.8.4, Condition C in ITS Conversion LAR, Revision 1), is considered an administrative presentation difference with no technical change and covered by ITS 3.8.4, DOC A03 in ITS Conversion LAR, Revision 1. DOC A03 will be revised to clarify the intended application of CTS 3.8.2.1, Action b, as an inclusive condition when any combination of required battery or chargers are inoperable (i.e., one required battery bank inoperable, or associated full capacity chargers inoperable, or both the required battery bank and associated full capacity chargers inoperable) and that this application is consistent with CTS 3.8.3.1, Action d (see attachment).
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| ==Attachment:==
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| : 1. KAB006 LAR Markups
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| ===Response===
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| 4/18/2022 10:15 AM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/18/2022 9:14 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=255 1/1
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| DISCUSSION OF CHANGES ITS 3.8.4, DC SOURCES - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 CTS 3.8.2.1 requires, in part, a 125-volt DC battery bank and a full capacity charger for each of four direct current (DC) electrical sources. ITS Limiting Condition for Operation (LCO) 3.8.4 requires that four trains of the DC electrical power subsystem shall be OPERABLE. This changes the CTS by changing the statement that the following DC electrical sources shall be OPERABLE, then listing the required sources and combining the requirements for the battery, battery charger, and battery charger power supply into one separate Specification stating four trains of the DC electrical power subsystem shall be OPERABLE.
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| The purpose, in part, of CTS 3.8.2.1 is to define LCO for required DC systems during plant operation. The change is acceptable because ITS LCO 3.8.4 retains the requirements of CTS 3.8.2.1 associated with required DC sources. This change is designated as administrative because it does not result in technical changes to the CTS.
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| A03 CTS 3.8.2.1, ACTION b, states, in part, that with one of the required battery banks inoperable, or with none of the full-capacity chargers associated with a battery bank OPERABLE, restore all battery banks to OPERABLE status and at least one charger associated with each battery bank to OPERABLE status.
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| ITS 3.8.4, ACTION B and ACTION C, state, in part, that with one DC electrical power train inoperable to restore the DC electrical power train to OPERABLE status. This changes the CTS by describing the Condition and Required Action as a train (battery bank and associated charger) instead of listing the train components separately.
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| The purpose of CTS 3.3.8.2.1, ACTION b, is to prescribes remedial measures required under designated conditions. Whether the condition described lists the components (battery bank and associated battery charger) or lists the or combination of the components as a train only changes the manner that the condition is presented. This change is acceptable because no technical changes are made. This change is designated as administrative because it does not result in technical changes to the CTS.
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| Insert 1 chargers Turkey Point Unit 3 and Unit 4 Page 1 of 9
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| Insert 1 CTS 3.8.2.1, Action b, is applied as an inclusive condition when any combination of required battery or chargers are inoperable (i.e., one required battery bank inoperable, or associated full capacity chargers inoperable, or both the required battery bank and associated full capacity chargers inoperable). This application is also consistent with CTS 3.8.3.1, Action d, which requires in part, reenergizing the DC bus from its associated battery bank within two hours or in accordance with the Risk Informed Completion Time Program with one DC bus not energized from its associated battery bank or associated charger. As such, ITS 3.8.4, ACTIONS B and C are technically equivalent to the CTS requirements, consistent with both CTS 3.8.2.1, Action b, and CTS 3.8.3.1, Action d. Presenting ITS 3.8.4 Conditions B and C on train basis instead of a component basis clarifies the intended application of the requirement.
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| 5/28/22, 12:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 487 NRC Question KAB006 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/27/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/27/2022 10:02 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=487 1/1
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| 3/17/22, 5:11 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 85 NRC Question KAB007 Number Category Technical ITS 3.8 Section ITS 3.8.4 Number DOC Number JFD 3
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| Number JFD Bases Number Page multiple - see question Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.4 page 3.8.4-3, ITS 3.8.4 surveillance requirement (SR) 3.8.4.2 can be satisfied by meeting one Question of two criteria. The second criteria verifies each battery charger can recharge the battery to the fully charged state within [24] hours during specified conditions. As stated in justification for deviations (JFD) 3 the ISTS contains bracketed information and/or values that are generic to Westinghouse plants and these brackets are meant to be removed after inserting the proper plant specific information to reflect the current licensing basis.
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| The ISTS bases for SR 3.8.4.2 states that the time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours. On ITS 3.8.4 Bases page B 3.8.4-9, the proposed change deletes this sentence and JFD 6 is applied which states that the removed information related to the basis for the time that a battery charger is required to be capable of supplying its rated amps at the minimum established float voltage, as the Turkey Point Nuclear Generating Station (PTN) current licensing basis does not include time for the charger temperature to stabilize.
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| Explain if the plant specific current licensing basis for PTN supports the second criteria and its associated
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| [24] hour time in ITS 3.8.4, SR 3.8.4.2 given that it is based on the sufficiency of the battery charger temperature to stabilize and to have been maintained for at least [2] hours. Update the timing in the second criteria of ITS 3.8.4, SR 3.8.4.2 and ITS 3.8.4 Bases SR 3.8.4.2 as necessary to reflect the current licensing basis or remove the second criteria in ITS 3.8.4 SR 3.8.4.2 since it isn't in PTN CTS and the current licensing basis for PTN does not support adoption of this criteria.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=85 1/2
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| 3/17/22, 5:11 PM Turkey Point ITS Conversion Database Date 3/17/2022 4:10 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=85 2/2
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| 8/3/22, 5:25 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 214 NRC Question KAB007 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response As indicated in ITS 3.8.4 DOC L04, the second criterion of ISTS SR 3.8.4.2 is added in PTN ITS SR 3.8.4.2.
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| Statement Therefore, the current licensing basis does not include this criterion. To support this additional battery charger testing criterion, FPL has confirmed that the PTN safety related 125VDC battery charger design includes the capability of recharging the battery to the fully charged state within 24 hours while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. Therefore the current design basis for the 125VDC battery charger does support the adoption of the ISTS SR 3.8.4.2 optional second timing criterion of 24 hours specified in ITS SR 3.8.4.2 and does not need to be revised.
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| CTS SR 4.8.2.1.c.3) requires verifying each battery charger can supply the rated amperes at 129 volts for at least 8 hours. CTS 4.8.2.1.c.3) maps to ITS SR 3.8.4.2 (first criterion) that requires, in part, the same verification. The ISTS Bases for SR 3.8.4.2 states that SR 3.8.4.2 provides two options, one is associated with charger current capability while the other is associated with the capability of the charger to recharge the battery to a fully charged state within 24 hours. The ISTS Bases discusses these two optional testing criteria in separate paragraphs.
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| The first paragraph, which is related to the Surveillance option currently required by CTS 4.8.2.1.c.3, discusses the use of the ability of the charger to maintain the required current for an 8-hour period and clarifies that this time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours. Although 8 hours is a reasonable time period for battery charger temperature to stabilize, PTN does not currently track this information and cannot confirm this ISTS Bases statement. Therefore, this information is not included in the PTN ITS Bases.
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| The ISTS 3.8.4 Bases paragraph that discusses the optional method of verifying the design capacity of the battery chargers does not contain a sentence regarding battery charger temperature stabilization. The optional method is time dependent on the capability to recharge the battery to the fully charged state coincident with supplying the largest coincident demands of the various continuous steady state loads.
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| This alternative SR was included in TSTF-500 R2-A, "DC Electrical Rewrite - Update to TSTF-360." TSTF-500 states, in part:
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| "An alternative criteria is added to SR 3.8.4.6 (now SR 3.8.4.2), which states, "Verify each battery charger can recharge the battery to the fully charged state within [24] hours while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state."
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| This is an alternate method for verifying the design capacity of each battery charger. As described in the revised Bases for SR 3.8.4.2, this test would occur following a service, performance or modified performance test. The level of loading required may not normally be available following the battery service test and may need to be supplemented with additional loads. The duration of this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. If each battery charger is capable of recharging its respective battery within [24] hours while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state, the proposed alternate testing criteria would satisfy the purpose of SR 3.8.4.2.
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| Since there is no limitation or condition related to charger temperature stabilization associated with the adoption of the optional testing criterion specified in ISTS SR 3.8.4.2 or the associated Bases, ITS SR 3.8.4.2 continues to include the optional battery charger testing criterion to verify each battery charger can recharge the battery to the fully charged state within 24 hours while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.
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| ===Response===
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| 4/15/2022 4:00 PM Date/Time https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=214 1/2
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| 8/3/22, 5:25 PM Turkey Point ITS Conversion Database Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/15/2022 2:59 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=214 2/2
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| 6/6/22, 10:17 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 875 NRC Question KAB007 Number Select NRC Response Application Attachment 1
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| Attachment 2
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| Response SR 3.8.4.2 verifies the operability (design capacity) of the battery chargers, not the battery. The chargers Statement supply various steady state loads and the battery (see the second option of the SR). Temperature variations impact the battery chargers current not the voltage used to charge the battery. The statement in the STS Bases provides justification for the 8-hour duration for the first option in SR 3.8.4.2, and that is that the 8-hour duration ensures that the charger temperature is stabilized and maintained stable for at least two hours. The [8] hours is bracketed in the STS, which means that the time for testing the battery charger capacity is specific to each plant. Please revise ITS Bases JFD 6 to provide the technical basis for why the 8-hour duration is acceptable for testing PTNs chargers and why two hours are not required to stabilize battery charger temperature.
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| ===Response===
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| 6/6/2022 9:30 PM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date 6/6/2022 8:31 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=875 1/1
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| 8/3/22, 5:23 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1614 NRC Question KAB007 Number Select Licensee Response Application Attachment Attachment 1 - KAB007-1 LAR Markup R1.pdf (659KB) 1 Attachment 2
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| Response As stated in the initial FPL response to KAB007 and restated in the NRC follow-up to request for additional Statement information (RAI) KAB007, the ISTS Surveillance Requirement (SR) 3.8.4.2 Bases statement regarding battery charger temperature stabilization and maintaining a stable temperature for at least two hours is the basis for the 8-hour duration specified in ISTS SR 3.8.4.2 first option. Adopting the first option of ISTS SR 3.8.4.2 is not a change to the PTN current licensing basis or a deviation from the ISTS. As stated in the initial FPL response to KAB007, CTS 4.8.2.1.c.3 requires verifying each battery charger can supply the rated amperes at 129 volts for at least 8 hours. The 8hour duration is consistent with ITS SR 3.8.4.2 (first criterion). FPL cannot confirm that the historical basis for the 8-hour duration specified in CTS 4.8.2.1.c.3 includes consideration of charger temperature stabilization. Therefore, this ISTS Bases statement is not included in PTN ITS Bases. The current method of determining battery charger operability (design capacity) using an 8-hour duration has been and continues to be an acceptable method of testing to assure that the necessary quality of the battery chargers is maintained, that facility operation will be within safety limits, and that the associated limiting condition for operation will be met pursuant to 10 CFR 50.36(c)(3).
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| ITS 3.8.4 Bases Justification for Deviation (JFD) 6 will be revised as shown in the attached KAB007-1 LAR Markup to explain the deletion of the temperature stabilization statement more clearly.
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| In addition, during a discussion with the NRC staff, another question arose associated with the second option of ITS SR 3.8.4.2. The second option requires verification that each battery charger can recharge the battery to the fully charged state within [24] hours while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. The question was associated with what the bounding design basis event discharge state is (i.e., what constitutes a partially discharged battery). The PTN battery sizing calculation and the Updated Safety Analysis Report (UFSAR) state that the chargers have the capability to recharge a partially discharged battery within 24 hours while carrying its loads. As stated in the UFSAR, the safety related battery chargers have been sized to meet the requirements of Position C.1.b of Regulatory Guide 1.32, Criteria For Safety-Related Electric Power Systems For Nuclear Power Plants and the capacity of the battery charger supply is based on the largest combined demands of the various steady-state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the plant during which these demands occur. The battery charger sizing is calculated using methods described in Standard IEEE 946-1992, "IEEE Recommended Practice for the Design of DC Auxiliary Power Systems for Generating Stations."
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| From the standard, the required ampere capacity (I) of the battery charger is defined by the following formula:
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| I minimum = L + (1.1 x AH)/T, where:
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| AH = Ampere-Hour discharge from the battery (taken from a two-hour load profile analysis separated into three periods, 01 minute, 160 minutes, and 60120 minutes).
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| 1.1 = battery constant that compensates for battery losses.
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| T = number of hours for recharging the battery, which is 24 hours in the safety related battery sizing calculations.
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| L = total steady state current (the current during the period prior to load tripping (1 minute to 60th minute) is assumed the "normal" operating current for determining battery charger size).
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| The battery charger calculation determines the AHs discharged from a battery using three AH profiles; 0-1, 1-60, and 60-120 minute periods, respectively. For example: the sizing calculation for the 3A battery charger indicates the total AH discharged is 857 amp hours based on the 3A two-hour load profile analysis.
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| The steady state current (L) includes the 1-60 period current, minus emergency lighting (which transfers to AC on charger restorations) and an adjustment for inverter input (due to a voltage increase when the chargers are returned to service) and is determined to be 269 amps. The battery charger size is considered https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1614 1/2
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| 8/3/22, 5:23 PM Turkey Point ITS Conversion Database acceptable if the required minimum current (Iminimum) is less than the maximum battery charger current rating for the 24-hour recharge period. For the above example, Battery 3A charger Iminimum calculation results is less than 310 amps, which is less than the 400-amp capacity of the charger.
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| Thus, the battery charger sizing calculations show that the chargers are sized such that each can recharge the battery to the fully charged state within 24 hours while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state and, therefore, meets the requirements for applying the second option of ITS SR 3.8.4.2.
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| Attachment
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| : 1. KAB007-01 LAR Markup
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| ===Response===
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| 7/18/2022 4:45 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/18/2022 3:43 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1614 2/2
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| JUSTIFICATION FOR DEVIATIONS ITS 3.8.4 BASES, DC SOURCES - OPERATING
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| : 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
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| : 2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
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| : 3. These battery design values have been deleted because this type of information is not necessary to provide sufficient background for this Specification.
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| : 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
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| : 5. Changes have been made to be consistent with changes made to the Specifications.
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| : 6. Removed information related to the basis for the time that a battery charger is required to be capable of supplying its rated amps at the minimum established float voltage, as the Turkey Point Nuclear Generating Station (PTN) current licensing basis does not include time for the charger temperature to stabilize.
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| The information in the Bases of ISTS SR 3.8.4.2 related to battery charger temperature stabilization is not included in the ITS Bases because it cannot be confirmed that the historical basis for the 8-hour duration specified in the PTN current Technical Specifications includes consideration of charger temperature stabilization. The current method of determining battery charger operability (design capacity) using an 8-hour duration has been and continues to be an acceptable method of testing to assure that the necessary quality of the battery chargers is maintained, that facility operation will be within safety limits, and that the associated limiting condition for operation will be met pursuant to 10 CFR 50.36(c)(3).
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| Turkey Point Unit 3 and Unit 4 Page 1 of 1
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| 7/29/22, 10:31 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1690 NRC Question KAB007 Number Select NRC Question Closure Application Attachment 1
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| Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as indicated in the licensee response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 7/29/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 7/29/2022 9:00 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1690 1/1
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| 3/17/22, 5:17 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 89 NRC Question KAB008 Number Category Technical ITS 3.8 Section ITS 3.8.4 Number DOC Number JFD Number JFD Bases Number Page Enc 2 Vol 13 pdf page 213 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.4 Insert page 3.8.4-1a, Insert 2 states, "These ACTIONS apply to both units simultaneously,"
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| Question and its proposed placement is an Action note which applies to all ACTIONS in ITS 3.8.4. Explain how proposed Action D will be applied to both units simultaneously.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:15 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=89 1/1
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| 8/14/22, 10:08 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 198 NRC Question KAB008 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response Proposed ITS 3.8.4, ACTION D, would apply to both units simultaneously because four DC electrical power Statement trains (two DC electrical power trains per unit) are required for both units when the units are in MODE 1, 2, 3, or 4. Therefore, the corresponding CTS 4.8.2.1.a.3 requirement would apply to both units simultaneously when both units are in MODE 1, 2, 3, or 4. Please note that Revision 1 of the FPL ITS Conversion license amendment request (LAR) deletes the specific Note requiring application to both units simultaneously and removes proposed ACTION D. ITS 3.8.4, DOC A04, in Revision 1 of the LAR, discusses applicability to both units (original DOC A04 renumbered as A05). The current Note is unnecessary and redundant to the generic requirement provided in CTS 3.0.5.a (ITS LCO 3.0.10.a). ITS LCO 3.0.10.a states, "Whenever the LCO refers to systems or components which are shared by both units, the Conditions and Required Actions will apply to both units simultaneously." As a result, applying Technical Speciation requirements to both units simultaneously is required to all requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not.
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| The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.4, DC Sources - Operating, Revision 1, of the ITS Conversion LAR.
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| ===Response===
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| 4/13/2022 6:40 PM Date/Time Closure Statement Question Closure 4/13/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/13/2022 5:39 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=198 1/1
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| 6/2/22, 12:16 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 687 NRC Question KAB008 Number Select NRC Response Application Attachment 1
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| Attachment 2
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| Response 10CFR50.36 states that Each applicant for a license authorizing operation of a production or utilization Statement facility shall include in his application proposed technical specifications in accordance with the requirements of this section. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications. As indicated in PTNs response to KAB008, 4 trains of DC Sources are required to be operable because they are shared between units. Please update the proposed Bases in the PTN ITS for Sections 3.8.4 and 3.8.5 to indicate that the DC Sources are shared between Units 3 and 4.
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| ===Response===
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| 6/2/2022 11:10 AM Date/Time Closure Statement Question Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date 6/2/2022 10:08 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=687 1/1
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| 8/14/22, 10:09 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1195 NRC Question KAB008 Number Select Licensee Response Application Attachment Attachment 1 - KAB008-1 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response FPL will revise the ITS 3.8.4 Limiting Condition for Operation (LCO) Bases to note that four DC electrical Statement trains exist which are shared between Units 3 and 4. See attached KNW008-1 license amendment request (LAR) markup.
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| However, FPL has determined that it is unnecessary to update the LCO Bases of ITS 3.8.5 since the beginning sentence of the Background section states:
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| A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."
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| In addition, ITS 3.8.5 requires only three DC electrical trains to be OPERABLE; therefore, adding redundant discussion concerning the potential availability of four DC electrical trains could create confusion.
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| Attachment
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| : 1. KAB008-1 LAR Markups
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| | |
| ===Response===
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| 6/16/2022 4:15 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 6/16/2022 3:17 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1195 1/1
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| DC Sources - Operating B 3.8.4 BASES BACKGROUND (continued)
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| When desired, the charger can be placed in the equalize mode. The equalize mode is at a higher voltage than the float mode and charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.
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| Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery service test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead-calcium batteries have recharge efficiencies of greater than 95%, so once at least 105% of the ampere-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours discharged from the battery and amp-hours returned to the battery.
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| APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 14 U
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| SAFETY analyses in the FSAR, Chapter [6] (Ref. 5) and Chapter [15] (Ref. 6), 2 1 ANALYSES assume that Engineered Safety Feature (ESF) systems are OPERABLE.
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| The DC electrical power system provides normal and emergency DC EDG electrical power for the DGs, emergency auxiliaries, and control and 1 switching during all MODES of operation.
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| The OPERABILITY of the DC sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining the DC sources OPERABLE during accident conditions in the event of:
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| trains, which a. An assumed loss of all offsite AC power or all onsite AC power and 1 are shared between Units 3 and 4, b. A worst-case single failure.
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| four The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
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| train LCO The DC electrical power subsystems, each subsystem consisting of [two] 1 INSERT 2 2 batteries, battery charger [for each battery] and the corresponding control equipment and interconnecting cabling supplying power to the associated train bus within the subsystem are required to be OPERABLE to ensure the 1 availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a train postulated DBA. Loss of any DC electrical power subsystem does not 1 prevent the minimum safety function from being performed (Ref. 4).
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.4-3 Rev. 5.0 1
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| 6/30/22, 3:07 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1383 NRC Question KAB008 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/30/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/30/2022 1:38 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1383 1/1
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| 3/17/22, 5:19 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 93 NRC Question KAB009 Number Category Technical ITS Section 3.8 ITS Number 3.8.5 DOC Number LA-2 JFD Number JFD Bases Number Page Number(s) Enc 2 Vol 13 pdf page 241 NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call Requested N NRC Question On ITS 3.8.5 Discussion of Changes (DOC) page 2 of 5, DOC LA02 does not exist.
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| Provide DOC LA02.
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| Attach File 1 Attach File 2 Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date Added 3/17/2022 4:18 PM Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=93 1/1
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| 8/14/22, 10:09 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 315 NRC Question KAB009 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the license amendment request (LAR).
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| Statement Revision 1 of the FPL ITS Conversion LAR addresses and justifies the change to CTS 3.8.2.2 as an administrative change (ITS 3.8.5, DOC A03) in lieu of a less restrictive relocation of detail change (ITS 3.8.5, DOC LA02). DOC LA02 was associated with CTS 3.8.2.2 Applicability Note which states, "CAUTION - If the opposite unit is in MODES 1, 2, 3 or 4, see the corresponding Limiting Condition for Operation 3.8.2.1." ITS 3.8.5 and associated Bases do not contain a similar Note. The Note is simply a reminder that inoperable equipment shared between the two PTN units has the potential to result in Technical Specification entry for both units specific to the MODE of operation of each unit. However, this is redundant to the generic requirement provided in CTS 3.0.5 (ITS LCO 3.0.10). CTS 3.0.5 states, in part, "Limiting Conditions for Operation including the associated ACTION requirements shall apply to each unit individually unless otherwise indicated" This requirement is retained in ITS LCO 3.0.10.
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| As a result, Technical Specification requirements are applicable to each unit and apply, based on the units applicable MODE, to the requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. The appropriate Technical Specification ACTIONS associated with shared systems will continue to be performed for each unit based on the units applicable MODE or specified condition per the requirements of ITS LCO 3.0.10 and, therefore, this change is considered administrative.
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| The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, Revision 1, ITS 3.8.5, "DC Sources - Shutdown," and ITS 3.8.8, "Inverters - Shutdown," of the ITS Conversion LAR.
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| ===Response===
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| 4/21/2022 9:35 AM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/21/2022 8:35 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=315 1/1
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| 6/16/22, 1:17 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1159 NRC Question KAB009 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/16/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/16/2022 10:04 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1159 1/1
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| 3/17/22, 5:24 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 97 NRC Question KAB010 Number Category Technical ITS 3.8 Section ITS 3.8.5 Number DOC LA-2 Number JFD Number JFD Bases Number Page Enc 2 Vol 13 pdf page 244 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.4.12, "Overpressure Mitigation System," provides the requirements for reactor coolant system (RCS)
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| Question pressure relief when in the specified conditions in Modes 4, 5, and 6 and requires depressurizing and establishing an RCS vent of 2.2 square inches within 24 hours when both power operated relief valves are inoperable. On CTS Discussion of Changes (DOC) page 3 of 5, DOC L02 states that this completion time is 12 hours instead of 24 hours. Explain why the completions times are different or revise DOC L02.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:23 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=97 1/1
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| 8/14/22, 10:10 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 78 NRC Question KAB010 Number Select Licensee Response Application Attachment 1 Attachment 1 - KAB010 LAR Markup.pdf (654KB)
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| Attachment 2 Response ITS 3.8.5, DOC L02, will be revised to state 24 hours consistent with ITS 3.4.12. See attached markup of Statement the FPL ITS Conversion license amendment request.
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| ==Attachment:==
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| : 1. KAB010 LAR Markups
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| ===Response===
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| 4/12/2022 12:15 PM Date/Time Closure Statement Question 4/12/2022 Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/12/2022 11:13 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=78 1/1
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| DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with the safe operation under the specified Condition, considering the OPERABLE status of the redundant systems and features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. The proposed ITS 3.8.5 ACTION A provides up to a 72-hour restoration time for an inoperable required battery charger. However, this time is contingent on a focused and tiered approach to assuring adequate battery capability is maintained. The priority for the operator is to minimize the battery discharge, which is required to be terminated within 2 hours (ITS 3.8.5 Required Action A.1). Presuming that the battery discharge (if occurring) can be terminated, and that the DC bus remains energized (as required by a separate LCO), there is reasonable basis for extending the restoration time for an inoperable charger beyond the 2-hour limit.
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| The second tiered action proposes 12 hours to establish that the battery has sufficient capacity to perform its assumed duty cycle (which may involve some recharging of lost capacity that occurred during the initial hours). Given the choice of a unit shutdown in this condition (as currently required) versus a 12-hour determination (at the end of which it is reasonable to assume the battery can be shown to have its assumed capacity) followed by a 72-hour restoration period, is an acceptable relaxation. Because the focus of this allowance is that the battery capacity be preserved and assured, the means of accomplishing this may be a spare battery charger employed within the initial 2 hours, or the degraded charger that continues to float the battery. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L02 (Category 3 - Relaxation of Completion Time) CTS 3.8.2.2 ACTION requires that with one or more of the required 125 volt battery banks or required associated full-capacity chargers inoperable or not capable of being powered from an OPERABLE EDG, the Reactor Coolant System (RCS) must be depressurized and vented within 8 hours through a 2.2 square inch vent. ISTS 3.8.5 does not include this Required Action. ITS LCO 3.4.12, "Overpressure Mitigation System," provides requirements for RCS pressure relief when in 24 MODES 4, 5, or 6 to depressurize and establish an RCS vent of 2.2 square inches within 12 hours if the other pressure relief methods are incapable of limiting pressure. This changes the CTS by relying on ITS LCO 3.4.12 to provide the Required Actions and allowing a longer Completion Time to depressurize the RCS and establish a 2.2 square inch RCS vent.
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| The purpose of CTS 3.8.2.2 ACTION is to provide remedial actions to be taken in response to the loss of a required DC train while in MODE 5 or 6. One of these remedial actions is to depressurize and vent the RCS through at least a 2.2 square inch vent, which is being proposed for deletion. This change is acceptable because the CTS 3.8.2.2 action to depressurize and vent the RCS is duplicative of the ITS LCO 3.4.12 Required Action to depressurize and vent the RCS. In addition, ITS 3.4.12 Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Time.
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| Turkey Point Unit 3 and Unit 4 Page 3 of 5
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| 5/31/22, 9:25 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 591 NRC Question KAB010 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/30/2022 9:19 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=591 1/1
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| 3/17/22, 5:24 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 101 NRC Question KAB011 Number Category Technical ITS 3.8 Section ITS 3.8.5 Number DOC LA-3 Number JFD Number JFD Bases Number Page Enc 2 Vol 13 pdf page 241 & 245 Enc 2 vol 14 Attachment 7 pdf page 129 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On CTS page 3/4 8-17, it is proposed that "immediately suspend all operations involving CORE Question ALTERATIONS" be deleted from the CTS 3.8.2.2 Action statement. On ITS 3.8.5 Discussion of Changes (DOC) page 4 of 5, DOC L03, with regard to the deletion of core alterations, discusses the standard review plan, CTS 3/4.9.3, "Decay Time," removal of crane limitations from CTS, and then states that the change is acceptable because it allows for positive reactivity additions that do not result in loss of required SDM or boron concentration assuring continued safe operation. In addition, Enclosure 2, Volume 14, Attachment 7 of this license amendment proposes to relocate the entirety of CTS 3/4.9.3, decay time. PTN's current licensing basis as reflected in UFSAR 14.2.1, analyzes a drop of a fuel assembly in containment and assumes a delay of 72 hours before spent fuel movement and that all the fuel rods in a single assembly are damaged . The justification provided in DOC L03 does not explain how the FHA, as reflected in UFSAR 14.2.1, will remain bounding with the deletion of core alterations.
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| In order to delete core alterations from CTS 3.8.2.2 and not include it in ITS 3.8.5, provide a description of the limitations and controls that would prevent movement of any unirradiated fuel assembly, source, reactivity control component, or other component affecting reactivity within the reactor vessel capable of damaging a fuel assembly prior to the 72 hour decay time assumed in the FHA or demonstrate that the dropping of any unirradiated fuel assembly, sources, reactivity control component, or other component affecting reactivity within the reactor vessel onto irradiated fuel assemblies prior to the 72 hour decay time assumed in the FHA will not result in a radioactive release from the irradiated fuel.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:24 PM Added https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=101 1/2
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| 3/17/22, 5:24 PM Turkey Point ITS Conversion Database Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=101 2/2
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| 8/3/22, 5:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 327 NRC Question KAB011 Number Select Licensee Response Application Attachment Attachment 1 - KAB011 LAR Markup.pdf (664KB) 1 Attachment 2
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| Response The Applicability of CTS 3.8.2.2, as retained in ITS 3.8.5, requires three trains of the DC electrical power Statement subsystem to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies. Thus, this requirement applies regardless of whether irradiated fuel assemblies are moved prior to or after the 72-hour decay period assumed in the fuel handling accident (FHA). Therefore, FPL has determined that the discussion in ITS 3.8.5, DOC L03, related to the 72-hour decay period is not germane to the deletion of CORE ALTERATIONS in the CTS 3.8.2.2 Action as it relates to movement of irradiated fuel assemblies. CTS 3/4.9.3, Decay Time, does not constrain or address movement of components other than irradiated fuel in the reactor vessel. Therefore, this discussion will be removed from DOC L03.
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| The limitation that would prevent movement of any unirradiated fuel assembly, source, reactivity control component, or other component affecting reactivity within the reactor vessel capable of damaging a fuel assembly prior to the 72-hour decay time assumed in the FHA is the physical time constraint necessary to remove the reactor vessel head and internals and expose the irradiated fuel after a shutdown. CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the Reactor Coolant System, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours. Therefore, CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is precluded.
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| The retention of CORE ALTERATIONS is unnecessary since the ITS 3.8.5 ACTIONS continue to require suspension of irradiated fuel assemblies, which is specified in the Applicability. ITS 3.8.5, DOC L03, will be modified (markup attached) to include this information. An excerpt from ITS 3.8.5, DOC L03, is included below, with the additional information italicized.
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| The purpose of the CTS 3.8.2.2 ACTION is to minimize the possibility of an event that may need the DC source to mitigate the consequences of the event. CORE ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed and only applies in MODE 6. There is only one accident considered during MODE 6 that involves CORE ALTERATIONS: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building. Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident. ITS 3.8.5 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.5, Required Action B.2.1 (for one or more inoperable DC electrical power trains). Therefore, because the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of a DC source is covered by the ITS Required Actions, deleting the reference to "CORE ALTERATIONS" is acceptable. Additionally, CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the Reactor Coolant System, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours.
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| ITS 3.8.5, Required Action B.2.1, requires the suspension of irradiated fuel movement, including the unlikely event of irradiated fuel assembly movement within the reactor vessel, prior to the 72-hour decay period. Therefore, the portion of ITS 3.8.5, DOC L03, which discusses "decay time" is proposed for deletion.
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| A markup of the affected ITS 3.8.5 DOC pages is attached.
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| ==Attachment:==
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| : 1. KAB011 LAR Markups
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| ===Response===
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| 4/21/2022 2:55 PM Date/Time https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=327 1/2
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| 8/3/22, 5:31 PM Turkey Point ITS Conversion Database Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/21/2022 1:53 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=327 2/2
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| DISCUSSION OF CHANGES ITS 3.8.5, DC SOURCES - SHUTDOWN This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| L03 (Category 4 - Relaxation of Required Action) CTS 3.8.2.2 ACTION states, in ITS 3.8.5 retains the part, that with one or more of the required 125 volt battery banks or required requirement to suspend associated full-capacity chargers inoperable or not capable of being powered movement of irradiated fuel assemblies in ITS 3.8.5, from an OPERABLE EDG, immediately suspend all operations involving CORE Required Action B.2.1 (for ALTERATIONS, positive reactivity changes, or movement of irradiated fuel. ITS one or more inoperable DC Required Actions B.1, B.2.1, and B.2.2 provide Actions to be performed under electrical power trains).
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| Therefore, because the only similar conditions. These ITS Required Actions state to declare affected required CORE ALTERATION feature(s) inoperable, or to suspend movement of irradiated fuel assemblies and analyzed in the safety suspend operations involving positive reactivity additions that could result in loss analysis and potentially affected by a loss of a DC of required SHUTDOWN MARGIN (SDM) or boron concentration. This changes source is covered by the ITS the CTS Actions by deleting the requirement to suspend CORE ALTERATIONS Required Actions, deleting and to clarify to only suspend positive reactivity additions when it could result in the reference to "CORE ALTERATIONS" is loss of required SDM or boron concentration.
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| acceptable. Additionally, CORE ALTERATIONS that The purpose of the CTS 3.8.2.2 ACTION is to minimize the possibility of an event may be capable of damaging a fuel assembly prior to the that may need the DC source to mitigate the consequences of the event. CORE 72-hour decay period is ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, improbable because the sources, reactivity control components, or other components affecting reactivity, physical time required to within the reactor vessel with the head removed and fuel in the vessel." CORE perform plant shutdown, cooldown, depressurize the ALTERATIONS only occur when the reactor vessel head is removed and only Reactor Coolant System, and applies in MODE 6. There is only one accident considered during MODE 6 that the additional operations involves CORE ALTERATIONS: a fuel handling accident. According to the required to expose the irradiated fuel (e.g., Standard Review Plan, a fuel handling accident is initiated by the dropping of an containment entry, removal of irradiated fuel assembly, either in the containment or in the fuel building.
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| vessel head, removal of Suspension of CORE ALTERATIONS, except for suspension of movement of vessel internals, etc.) is greater than 72 hours. irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident.
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| CTS 3/4.9.3 requires that the reactor be subcritical for at least 72 hours during movement of irradiated fuel in the reactor vessel and if the reactor is subcritical for less than 72 hours to suspend all operations involving movement of irradiated fuel in the reactor vessel. This decay time (72 hours) is consistent with the assumptions used in the safety analyses, and ensures that the release of fission product radioactivity, subsequent to a fuel handling accident, results in radiological doses that are well within the values specified in 10 CFR 50.67 (Accident Source Term) and Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors." In addition, CTS 3/4.9.3 bases states that recently irradiated fuel is defined as fuel that has occupied part of a critical reactor core within the previous 72 hours. In addition, the limitations on crane travel were removed from CTS by the installation of a single-failure-proof crane.
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| CTS 3.8.2.2 ACTION also requires that with less than the above minimum required DC electrical power sources OPERABLE, immediately suspend all operations involving positive reactivity changes while ITS Required Actions B.2.2 requires only suspending operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. This change is acceptable because it allows for positive reactivity additions that do not result in loss of required SDM or boron concentration (e.g., water addition or temperature change) assuring continued safe operation. This change is designated as less Turkey Point Unit 3 and Unit 4 Page 4 of 5
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| 6/2/22, 3:47 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 695 NRC Question KAB011 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/2/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 1:24 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=695 1/1
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| 3/30/22, 9:50 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 105 NRC Question KAB012 Number Category Technical ITS 3.8 Section ITS 3.8.7 Number DOC A-2 Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Select Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC In ITS 3.8.7 discussion of changes (DOC) page 1 of 3, DOC A02 states, "CTS LCO 3.8.2.1 Action c states, in Question part, that with one AC Vital Bus ... ." However, CTS LCO 3.8.3.1 ACTION c, seems to be the correct reference. Revise DOC A02 to be consistent with CTS or explain why it is appropriate to reference CTS LCO 3.8.2.1.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:27 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=105 1/1
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| 8/14/22, 10:11 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 202 NRC Question Number KAB012 Select Application Licensee Response Attachment 1 Attachment 1 - KAB012 LAR Markup.pdf (649KB)
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| Attachment 2 Response Statement ITS 3.8.7, DOC A02, will be revised to appropriately reference CTS LCO 3.8.3.1 (see attached).
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| ==Attachment:==
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| : 1. KAB012 LAR Markups Response Date/Time 4/15/2022 3:40 PM Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/15/2022 2:45 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=202 1/1
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| DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable 3 because they do not result in technical changes to the CTS.
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| A02 CTS LCO 3.8.2.1 ACTION c states, in part, that with one AC Vital Bus either not energized from its associated Inverter, or with the inverter not connected to its associated DC Bus, re-energize the AC Vital Bus from its associated inverter connected to its associated DC Bus within 24 hours. ITS Limiting Condition for Operation (LCO) 3.8.7 ACTION A states with one inverter inoperable, restore the Inverter to OPERABLE status within 24 hours. Required Action A is modified by a note that states, "Enter applicable Condition and Required Actions of LCO 3.8.9, 'Distribution Systems - Operating,' with any AC vital bus de-energized."
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| This changes the CTS by adding a note that references the requirements for ITS LCO 3.8.9.
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| This change is acceptable because it does not change the technical requirements of the CTS. The ITS rules of usage require all conditions for a system, subsystem, train, component, or device to be entered when a system, subsystem, train, component, or device become inoperable. ITS LCO 3.8.7 Condition A is for one required inverter inoperable and LCO 3.8.9 must be entered if an AC Vital bus is inoperable. The ITS Condition A note provides no specific technical requirements and acts only as a reminder to enter LCO 3.8.9 if an AC Vital bus has become de-energized. The ITS requirements are consistent with the ISTS wording for these requirements. This change is designated as administrative because the technical requirements of the specifications have not changed.
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| MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.3.1 states, in part, that the following electrical busses*
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| shall be energized in the specified manner, listing the 120 volt AC Vital Panels as Items d through k, with the manner of energization being the associated inverter connected to the specified DC bus (e.g., its associated inverter connected to DC Turkey Point Unit 3 and Unit 4 Page 1 of 3
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| 5/18/22, 6:04 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 411 NRC Question KAB012 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/18/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/18/2022 5:01 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=411 1/1
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| 3/18/22, 11:13 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 109 NRC Question KAB013 Number Category Technical ITS 3.8 Section ITS 3.8.7 Number DOC A-2 Number JFD Number JFD Bases Number Page Enclosure 2 Vol. 13 page 306 Number(s)
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| NRC Reviewer Select Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC In ITS 3.8.7 discussion of changes (DOC) page 1 of 3, DOC A02 states, "The ITS [improved technical Question specifications] requirements are consistent with the ISTS [improved standard technical specifications]
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| wording for these requirements." While this is a true statement, DOC A02 is supposed to discuss the current technical specifications (CTS) requirements in relation to the requirement in the ITS. Revise DOC A02 to discuss the CTS in relation to the ITS or explain this statement in relation to CTS.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:29 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=109 1/1
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| 8/14/22, 10:11 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 206 NRC Question KAB013 Number Select Licensee Response Application Attachment Attachment 1 - KAB013 LAR Markup.pdf (639KB) 1 Attachment 2
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| Response CTS 3.8.3.1, DOC A02 (ITS 3.8.7, "Inverters - Operating"), addresses the proposed adoption of an ITS Note Statement that would act as an operator aid by referencing ITS 3.8.9, "Distribution Systems - Operating," when a required inverter is inoperable. This is appropriate since an inoperable inverter could affect the OPERABILITY of a supported Distribution System train. The sentence in DOC A02 comparing the ITS and ISTS is deleted (see attached). The sentence is not required to support justification of the change to adopt the subject ITS Note. The intent of the referenced sentence was to discuss the relationship between the ISTS and the ITS, which is unnecessary because the ITS markup illustrates this relationship. CTS 3.8.3.1, DOC A02, retains the statement, "The ITS Condition A note provides no specific technical requirements and acts only as a reminder to enter LCO 3.8.9 if an AC Vital bus has become de-energized."
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| CTS LCO 3.8.3.1, ACTION c contains two conditions: an AC vital panel not energized, or an inverter not connected to its associated DC bus. The condition associated with an AC vital panel not energized is being relocated to ITS LCO 3.8.9. The addition of ITS LCO 3.8.7, Required Action A.1 Note, directs the user to the location of the previous CTS 3.8.3.1, ACTION c Condition, AC vital panel not energized, and the associated Required Action is located in the ITS to ensure that the vital bus is re-energized within two hours.
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| ==Attachment:==
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| : 1. KAB013 LAR Markups
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| ===Response===
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| 4/15/2022 3:50 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/15/2022 2:50 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=206 1/1
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| DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| A02 CTS LCO 3.8.2.1 ACTION c states, in part, that with one AC Vital Bus either not energized from its associated Inverter, or with the inverter not connected to its associated DC Bus, re-energize the AC Vital Bus from its associated inverter connected to its associated DC Bus within 24 hours. ITS Limiting Condition for Operation (LCO) 3.8.7 ACTION A states with one inverter inoperable, restore the Inverter to OPERABLE status within 24 hours. Required Action A is modified by a note that states, "Enter applicable Condition and Required Actions of LCO 3.8.9, 'Distribution Systems - Operating,' with any AC vital bus de-energized."
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| This changes the CTS by adding a note that references the requirements for ITS LCO 3.8.9.
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| This change is acceptable because it does not change the technical requirements of the CTS. The ITS rules of usage require all conditions for a system, subsystem, train, component, or device to be entered when a system, subsystem, train, component, or device become inoperable. ITS LCO 3.8.7 Condition A is for one required inverter inoperable and LCO 3.8.9 must be entered if an AC Vital bus is inoperable. The ITS Condition A note provides no specific technical requirements and acts only as a reminder to enter LCO 3.8.9 if an AC Vital bus has become de-energized. The ITS requirements are consistent with the ISTS wording for these requirements. This change is designated as administrative because the technical requirements of the specifications have not changed.
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| MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.3.1 states, in part, that the following electrical busses*
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| shall be energized in the specified manner, listing the 120 volt AC Vital Panels as Items d through k, with the manner of energization being the associated inverter connected to the specified DC bus (e.g., its associated inverter connected to DC Turkey Point Unit 3 and Unit 4 Page 1 of 3
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| 5/19/22, 9:39 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 419 NRC Question KAB013 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/18/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/18/2022 6:15 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=419 1/1
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| 3/18/22, 11:13 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 113 NRC Question KAB014 Number Category Technical ITS 3.8 Section ITS 3.8.7 Number DOC L-1 Number JFD Number JFD Bases Number Page Enclosure 2 Vol. 13 page 307 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC In ITS 3.8.7 discussion of changes (DOC) page 2 of 3, DOC L01 states, "Once these limits to Question operation are exceeded, CTS [current technical specifications] ACTION A is entered to provide a reasonable time to energize the specified bus(s) in the manner specified, while CTS ACTION B provides a reasonable time to place the unit in a safe condition." While this is a true statement, DOC L01 is supposed to discuss the changes to CTS ACTION C in relation to the requirements in the ISTS as shown in ITS. Revise DOC L01 to discuss CTS ACTION C or explain how this statement applies to CTS ACTION C.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/17/2022 Added By Caroline Tilton Date Modified Modified By Date 3/17/2022 4:31 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=113 1/1
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| 8/14/22, 10:12 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 210 NRC Question KAB014 Number Select Application Licensee Response Attachment 1 Attachment 1 - KAB014 LAR Markup.pdf (659KB)
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| Attachment 2 Response ITS 3.8.7, DOC L01, will be modified (see attached) to address the ITS relationship to the change in Statement end state.
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| ==Attachment:==
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| : 1. KAB014 LAR Markups
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| ===Response===
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| 4/15/2022 3:55 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/15/2022 2:54 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=210 1/1
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| DISCUSSION OF CHANGES ITS 3.8.7, INVERTERS - OPERATING Bus 3B). In addition, footnote **** states that a back-up inverter may be used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time. ITS 3.8.7 does not contain this level of detail information. This changes the CTS by moving the level of detail of inverter designators and alignment to the DC bus and details that a back-up inverter may be used to replace the normal inverter to the ITS Bases.
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| The removal of these details related to system design from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.3.1 ACTION c requires, in part, that with the inverter not connected to its associated DC bus, to reenergize the A.C. vital panel from an inverter connected to its associated DC bus within 24 hours or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours and in COLD SHUTDOWN within the following 30 hours. ITS 3.8.7 ACTION B requires that with the Required Action and associated Completion Time (Restore inverter to OPERABLE status within 24 hours or in accordance with the Risk Informed Completion Time Program) of Condition A not met, to be in MODE 3 in 12 hours and MODE 4 in 18 hours. In addition, a Note is added to prevent the use of ITS LCO 3.0.4.a. This changes the CTS by requiring a less restrictive end state in the required actions, MODE 4 (HOT SHUTDOWN) instead of MODE 5 (COLD c, in part, is to ensure the SHUTDOWN).
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| unit is placed in a safe condition (end state of MODE The purpose of the CTS 3.8.3.1 ACTIONS is to limit the time the unit can remain
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| : 5) if an affected AC vital panel remains disconnected operating with busses not energized in the manner specified. Once these limits from its associated inverter to operation are exceeded, CTS ACTION A is entered to provide a reasonable beyond the specified time to energize the specified bus(s) in the manner specified, while CTS Completion Time of 24 hours.
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| ITS 3.8.7, Condition B, ACTION B provides a reasonable time to place the unit in a safe condition. End ensures the unit is placed in states are usually defined based on placing the unit into a MODE or condition in a safe condition if an which the Technical Specification LCO is not applicable. MODE 5 is the current inoperable inverter is not end state for LCOs that are applicable in MODES 1 through 4. This change is restored to OPERABLE status within 24 hours, but acceptable because the risk of the transition from MODE 1 to MODES 4 or 5 with an end state of MODE 4. depends on the availability of alternating current (AC) sources and the ability to Note that ITS 3.8.9, remove decay heat such that remaining in MODE 4 may be safer. During the "Distribution Systems -
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| Operating," addresses a de- realignment from MODE 4 to MODE 5, there is an increased potential for loss of energized or otherwise shutdown cooling and loss of inventory events. Decay heat removal following a inoperable AC vital bus. loss-of-offsite power event in MODE 5 is dependent on AC power for shutdown cooling whereas, in MODE 4, the turbine driven auxiliary feedwater (AFW) pump will be available. Therefore, transitioning to MODE 5 is not always the appropriate end state from a risk perspective. Thus, for specific TS conditions, Westinghouse Topical Report WCAP-16294-A R1 (ADAMS Accession No.
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| Turkey Point Unit 3 and Unit 4 Page 2 of 3
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| 7/6/22, 5:18 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 599 NRC Question KAB014 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 5/31/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/31/2022 2:59 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=599 1/1
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| 3/22/22, 9:56 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 133 NRC Question KAB015 Number Category Technical ITS 3.8 Section ITS 3.8.4 Number DOC Number JFD Number JFD Bases Number Page Various - See request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On CTS page 3/4 8-14, CTS surveillance requirement (SR) 4.8.2.1.a.3 states, If two battery Question chargers are connected to the battery bank, verify each battery charger is supplying a minimum of 10 amperes, or demonstrate that the battery charger supplying less than 10 amperes will accept and supply the D.C. bus load independent of its associated battery charger, in accordance with the surveillance frequency control program. The license amendment proposes to convert CTS SR 4.8.2.1.a.3 into ITS 3.8.4 Action D. Proposed ITS 3.8.4 Action D is entered when one of two battery chargers connected to the same battery bank is supplying less than 10 amps. Required Action D.1 requires demonstrating that the battery charger supplying less than 10 amps will accept and supply the DC bus load independent of its associated battery charger within 7 days. Additionally, an optional risk-informed completion time (RICT) is proposed.
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| A Discussion of Changes was not provided for the change to the CTS, and the corresponding Justification of Deviations number 4 for ITS 3.8.4 Action D does not provide a justification for the RICT; it simply states, ITS 3.8.4 ACTIONS C and D have been added that reflects the PTN CTS. Due to these additions the subsequent ACTIONS have been arranged in sequence.
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| (a) Proposed ITS 3.8.4 Required Action D.1 is to perform a test within 7 days, not to restore inoperable components (i.e., demonstrating that the battery chargers ability to independently accept and supply the DC bus load). In accordance with TSTF-505, Revision 2, a RICT is not appropriate when the ACTION is the completion of a test because PRA cannot calculate the difference in risk in this situation. Additionally, ITS Action A allows application of a RICT when one required battery charger on one train is inoperable. Therefore, provide sufficient technical justification why it is acceptable to include ITS 3.8.4 Action D within the scope of the RICT program and that it does not https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=133 1/3
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| 3/22/22, 9:56 AM Turkey Point ITS Conversion Database meet any of the exclusion criteria in Section 2.3 (Scope) of TSTF-505, Revision 2.
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| Alternatively, remove the RICT from ITS 3.8.4 Action D.
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| (b) If ITS 3.8.4 Action D is retained in the RICT program under part (a) above, the licensee should confirm that the proposed expansion of the RICT program is consistent with the guidance of NEI 06-09-A and continues to meet the five key safety principles in RG 1.177, Revision 2. For the proposed expansion of the RICT program, address the following conditions for a RICT program in NRCs safety evaluation for NEI 06-09-A (ADAMS Accession No. ML071200238).
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| - Describe the proposed new Required Action and justify that the PRA models used for estimating the RICT (e.g., internal events, internal flooding, fire PRAs) are consistent with the licensing basis assumptions (e.g., for the proposed expansion of the RICT program, provide information like that in Table E1-1, In Scope TS/LCO Conditions to Corresponding PRA Functions, in Enclosure 1 of the original TSTF505 LAR, as supplemented). Otherwise, provide an appropriate disposition or programmatic restriction. If the design success criteria and PRA success criteria are different, describe the plant-specific analyses used to support the PRA success criteria. As applicable, identify appropriate surrogate SSCs/operator actions modeled in the PRA and why the proposed surrogates adequately capture the configuration risk of the proposed expansion of the RICT program.
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| - Provide the calculated RICT for the proposed new Required Action (e.g., for the proposed expansion of the RICT program, provide the RICT like that in Table E1-2, Unit 3 In Scope TS/LCO Conditions RICT Estimate, in Enclosure 1 of the original TSTF505 LAR).
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| - Provide a summary of any changes to the PRA model/methods since the original TSTF505 LAR that have not been evaluated and closed consistent with the RG 1.200 guidance (e.g., provide information like that in Enclosure 2, Information Supporting Consistency with Regulatory Guide 1.200, Revision 2, of the original TSTF505 LAR, as supplemented).
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| - Provide the baseline CDF and LERF, if changed significantly from the information approved in Enclosure 5, Baseline CDF and LERF, of the original TSTF-505 LAR, as supplemented.
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| - Assess key assumptions and sources of uncertainty and associated impact on the new RICTs (e.g., for the proposed expansion of the RICT program, provide information like that in Table E9-1 of Enclosure 9, Key Assumptions and Sources of Uncertainty, of the original TSTF505 LAR, as supplemented).
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| - Any new examples of risk management actions (RMAs) not described in Enclosure 12, Risk Management Action Examples, of the original TSTF505 LAR, as supplemented, or of a type that examples are requested of in the general TSTF-505 guidance.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=133 2/3
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| 3/22/22, 9:56 AM Turkey Point ITS Conversion Database Modified By Date 3/22/2022 8:55 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=133 3/3
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| 8/14/22, 10:13 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 218 NRC Question KAB015 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response FPL has determined that CTS 4.8.2.1.a.3 should not be converted to an Action in the ITS; which precludes Statement the requirement to justify the RICT. Revision 1 of the ITS Conversion LAR has deleted proposed ACTION D and, instead, proposes to relocate CTS 4.8.2.1.a.3 to the Technical Requirements Manual (TRM). Please refer to ITS 3.8.4 DOC LA04. The battery charger testing requirement retained in ITS SR 3.8.4.2 (CTS 4.8.2.1.c.3) is adequate to ensure the required battery charger can perform its required support function.
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| Additionally, plant procedures will prompt an Operability determination if degraded performance is detected on a battery charger while operating in parallel with another battery charger and load sharing.
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| Therefore, this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The SRs retained in ITS 3.8.4 continue to assure that the necessary quality of systems and components is maintained and that the limiting conditions for operation will be met pursuant to 10 CFR 50.36(c)(3).
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| The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, Electrical Power Systems, Revision 1, of the ITS Conversion LAR.
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| | |
| ===Response===
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| 4/15/2022 4:05 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/15/2022 3:04 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=218 1/1
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| 6/1/22, 9:18 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 603 NRC Question KAB015 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/31/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/31/2022 3:52 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=603 1/1
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| 3/22/22, 10:02 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 137 NRC Question KAB016 Number Category Technical ITS 3.8 Section ITS 3.8.4 Number DOC Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On current technical specifications (CTS) page 3/4 8-14, CTS surveillance requirement (SR) 4.8.2.1 Question requires for each 125-volt battery bank and its associated full capacity charger(s) shall be demonstrated OPERABLE, in accordance with the surveillance frequency control program by verifying that:
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| : 1. The parameters in Table 4.8-2 meet the Category A limits, and
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| : 2. The total batter terminal voltage is greater than or equal to 129 volts on float charge and the battery charger(s) output voltage is 129 volts, and
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| : 3. If two battery chargers are connected to the battery bank, verify each battery charger is supplying a minimum of 10 amperes, or demonstrate that the battery charger supplying less than 10 amperes will accept and supply the D.C. bus load independent of its associated battery charger.
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| The proposed change converts CTS SR 4.8.2.1.a.3 into improved technical specifications (ITS) 3.8.4 Condition D, Required Action D.1, and a 7-day completion time. Specifically, on ITS 3.8.4 Insert page 3.8.4-1b, proposed ITS 3.8.4 Condition D is entered when one of two battery chargers connected to the same battery bank is supplying less than 10 amps and requires demonstrating that the battery charger supplying less than 10 amps will accept and supply the DC bus load independent of its associated battery charger within 7 days or in accordance with the RICT program.
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| This proposed change does not keep the current SR in CTS (i.e., SR 4.8.2.1.a.3), rathe it changes the SR to a Condition (i.e., ITS 3.8.4 Condition D) which is not in ISTS revision 5. A Discussion of Changes was not provided for the change to the CTS, and the corresponding Justification of Deviations number 4 for ITS 3.8.4 Action D does not provide a justification for the 7-day CT; it simply states, ITS 3.8.4 ACTIONS C and D have been added that reflects the PTN CTS. Due to these additions the subsequent ACTIONS have been arranged in sequence.
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| Furthermore, CTS SR 4.8.2.1.a.3 alone does not make the battery charger operable. It is recognized in the ITS 3.8.4 Bases for Action D.1 that:
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| https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=137 1/2
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| 3/22/22, 10:02 AM Turkey Point ITS Conversion Database A battery charger may be considered acceptable when supplying less than 10 amps provided: 1) the battery charger's ability to independently accept and supply the D.C. bus has been verified within the previous 7 days and, 2) D.C. output voltage is minimum established float voltage volts. [i.e.,
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| 129 volts]
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| However, the ITS 3.8.4 Bases cannot change or add requirements to the ITSs.
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| Therefore, provide the following additional information for this proposed change:
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| : 1. The technical basis for changing CTS SR 4.8.2.1.a.3 into ITS 3.8.4 Condition D and associated Required Action and completion time.
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| : 2. The current surveillance frequency for CTS 4.8.2.1.a.3.
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| : 3. The technical basis for determining that the 7-day completion time is a reasonable time to demonstrate the chargers ability to accept and supply the DC loads.
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| : 4. Explain how the battery chargers are operable without being able to maintain float voltage, or revise ITS 3.8.4 Required Action D.1 to include the float voltage requirement.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 9:01 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=137 2/2
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| 8/14/22, 10:13 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 222 NRC Question KAB016 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response FPL has determined that CTS 4.8.2.1.a.3 should not be converted to an Action in the ITS; which precludes Statement providing: 1) a technical basis for changing CTS SR 4.8.2.1.a.3 into ITS 3.8.4 Condition D and associated Required Action and completion time; and 2) a technical basis for determining that the 7-day completion time is a reasonable time to demonstrate the chargers ability to accept and supply the DC loads. The current Frequency for CTS 4.8.2.1.a.3 as specified in the Surveillance Frequency Control Program is 31 days. Revision 1 of the ITS Conversion LAR has deleted proposed ACTION D and, instead, proposes to relocate CTS 4.8.2.1.a.3, and the associated Frequency, to the Technical Requirements Manual (TRM).
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| Please refer to ITS 3.8.4 DOC LA04. The battery charger testing requirement retained in ITS SR 3.8.4.2 (CTS 4.8.2.1.c.3) is adequate to ensure the required battery charger can perform its required support function and includes, in part, the requirement for the required battery charger to maintain greater than or equal to the minimum established float current. Plant procedures will prompt an Operability determination if degraded performance is detected on a battery charger while operating in parallel with another battery charger and load sharing. Therefore, this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The SRs retained in ITS 3.8.4 continue to assure that the necessary quality of systems and components is maintained and that the limiting conditions for operation will be met pursuant to 10 CFR 50.36(c)(3).
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| The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, Electrical Power Systems, Revision 1, of the ITS Conversion LAR.
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| ===Response===
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| 4/15/2022 4:10 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/15/2022 3:11 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=222 1/1
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| 6/1/22, 9:18 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 607 NRC Question KAB016 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 5/31/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/31/2022 4:01 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=607 1/1
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| 3/22/22, 11:22 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 141 NRC Question KAB017 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC CTS 4.8.2.1, page 3/4 8-14, CTS 4.8.2.1.b.3 requires no visible corrosion at either terminals or connectors, Question or verify battery connection resistance is within the limits specified. On CTS 4.8.2.1 page 3/4 8-15, CTS 4.8.2.1.c.2 requires the cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material. CTS 4.8.2.1.c.4 requires battery connection resistance is within the limits specified. All these three requirements reference, "See ITS 5.5.16." In addition, on page 3/4 8-16, CTS Table 4.8-2 float voltage and table notation (6) also reference, "See ITS 5.5.16." CTS Proposed ITS 5.5.16 is the Surveillance Frequency Control Program. Explain each reference to ITS 5.5.16 or correct the program references.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 10:05 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=141 1/1
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| 8/14/22, 10:14 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 82 NRC Question KAB017 Number Select Licensee Response Application Attachment Attachment 1 - KAB017 LAR Markup.pdf (738KB) 1 Attachment 2
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| Response During development of the PTN ITS Conversion license amendment request, the battery program of ITS Statement 5.5.16 was renumbered as ITS 5.5.14 but the CTS markup of the battery Technical Specification was not updated accordingly. The ITS 3.8.6 references to ITS 5.5.16 on CTS Pages 3/4 8-14 (1 reference), 3/4 8-15 (2 references), and 3/4 8-16 (2 references) will be updated to correctly refer to the Battery Monitoring and Maintenance Program of ITS 5.5.14. During development of the KAB017 response, FPL also noted that similar CTS page markups associated with ITS 3.8.4 also referred to ITS 5.5.16 for the battery program.
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| Subsequently, ITS 3.8.4 references to ITS 5.5.16 on CTS Pages 3/4 8-14 (1 reference) and 3/4 8-15 (2 references) will also be updated to correctly refer to the Battery Monitoring and Maintenance Program of ITS 5.5.14. A markup of the affected CTS 4.8.2.1 ITS Conversion Revision 1 license amendment request pages associated with ITS 3.8.4 and ITS 3.8.6 is attached.
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| ==Attachment:==
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| : 1. KAB017 LAR Markups
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| ===Response===
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| 4/12/2022 12:25 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 11:23 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=82 1/1
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| CTS A01 ITS 3.8.4 D.C. SOURCES LIMITING CONDITION FOR OPERATION A03 ACTION: (Continued) unit DC electrical power trains 72 hours for Required Action A.3 L02 ACTION A, b. With one of the required battery banks inoperable, or with none of the full-capacity chargers ACTION B, ACTION C associated with a battery bank OPERABLE, restore all battery banks to OPERABLE status and at least one charger associated with each battery bank to OPERABLE status within two hours* or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY A04 within the next 12 hours and in COLD SHUTDOWN within the following 30 hours. This ACTION ACTION D applies to both units simultaneously. MODE 4 18 L03 SURVEILLANCE REQUIREMENTS Add proposed Required Action A.1 and A.2 L02 4.8.2.1 Each 125-volt battery bank and its associated full capacity charger(s) shall be demonstrated OPERABLE:
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| : a. In accordance with the Surveillance Frequency Control Program by verifying that:
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| : 1) The parameters in Table 4.8-2 meet the Category A limits, and See ITS 3.8.6 SR 3.8.4.1 2) The total battery terminal voltage is greater than or equal to 129 volts on float charge and the battery charger(s) output voltage is 129 volts, and minimum established float voltage LA03
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| : 3) If two battery chargers are connected to the battery bank, verify each battery charger is supplying a minimum of 10 amperes, or demonstrate that the battery charger supplying less than 10 amperes will accept and supply the D.C. bus load independent of its associated battery charger. LA04
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| : b. In accordance with the Surveillance Frequency Control Program and within 7 days after a battery discharge with battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts, by verifying that:
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| : 1) The parameters in Table 4.8-2 meet the Category B limits, See ITS 3.8.6
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| : 2) The average electrolyte temperature of every sixth cell is above 60F, and
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| : 3) There is no visible corrosion at either terminals or connectors, or verify battery connection resistance is:
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| See ITS 5.5.16 Battery Connection Limit (Micro-Ohms) 3B, 4A inter-cell / termination < 29 14 inter-cell (brace locations) < 30 transition cables < 125 or total battery connections < 1958 Battery Connection Limit (Micro-Ohms) 3A, 4B, D-52 inter-cell / termination < 35 inter-cell (brace locations) < 40 transition cables < 125 or total battery connections < 2463
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| : c. In accordance with the Surveillance Frequency Control Program by verifying that:
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| : 1) The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration, L01 ACTION B *Can be extended to 24 hours if the opposite unit is in MODE 5, 6, or defueled and each of the remaining required battery chargers is capable of being powered from its associated diesel generator(s).
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| TURKEY POINT - UNITS 3 & 4 3/4 8-14 AMENDMENT NOS. 289 AND 283 Page 2 of 3
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| CTS A01 ITS 3.8.4 D.C. SOURCES SURVEILLANCE REOUIREMENTS (Continued) See ITS 5.5.16
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| : 2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material, 14 SR 3.8.4.2 3) Each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at 129 volts for at least 8 hours, and each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at 129 LA05 volts for at least 8 hours, and the minimum established float voltage Add proposed second option for SR 3.8.4.2
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| : 4) Battery Connection resistance is: L04 Battery Connection Limit (Micro-Ohms) 3B, 4A inter-cell / termination < 29 inter-cell (brace locations) < 30 transition cables < 125 or See ITS total battery connections < 1958 5.5.16 14 Battery Connection Limit (Micro-Ohms) 3A, 4B, D-52 inter-cell / termination < 35 inter-cell (brace locations) < 40 transition cables < 125 or total battery connections < 2463 Add proposed SR 3.8.4.3 Note 2 A05 SR 3.8.4.3 d. In accordance with the Surveillance Frequency Control Program, during shutdown**, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.
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| : e. At least once per 12 months, during shutdown**, by giving performance discharge tests of battery capacity to any battery that shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% [7% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of rated capacity from its average on previous performance tests, or is below 90% [93% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating. See ITS 3.8.6
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| : f. In accordance with the Surveillance Frequency Control Program, during shutdown**, by verifying that the battery capacity is at least 80% [87% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating when subjected to a performance discharge test.
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| SR 3.8.4.3 Once per 60-month interval this performance discharge test may be performed in lieu of the Note 1 battery service test required by Specification 4.8.2.1.d.
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| The modified L05 A05 SR 3.8.4.3 **Except that the spare battery bank D-52, and any other battery out of service when spare battery bank D-52 is Note 2 in service may be tested with simulated loads during operation.
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| TURKEY POINT - UNITS 3 & 4 3/4 8-15 AMENDMENT NOS. 263 AND 258 Page 3 of 3
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| ITS ITS 3.8.6 A01 D.C. SOURCES LIMITING CONDITION FOR OPERATION See ITS ACTION: (Continued) 3.8.4
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| : b. With one of the required battery banks inoperable, or with none of the full-capacity chargers associated with a battery bank OPERABLE, restore all battery banks to OPERABLE status and at least one charger associated with each battery bank to OPERABLE status within two hours* or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours and in COLD SHUTDOWN within the following 30 hours. This ACTION applies to both units simultaneously.
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| SURVEILLANCE REQUIREMENTS 4.8.2.1 Each 125-volt battery bank and its associated full capacity charger(s) shall be demonstrated OPERABLE:
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| : a. In accordance with the Surveillance Frequency Control Program by verifying that:
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| See ITS SR 3.8.6.1 1) The parameters in Table 4.8-2 meet the Category A limits, and 3.8.4 SR 3.8.6.2
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| : 2) The total battery terminal voltage is greater than or equal to 129 volts on float charge and the battery charger(s) output voltage is 129 volts, and
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| : 3) If two battery chargers are connected to the battery bank, verify each battery charger is supplying a minimum of 10 amperes, or demonstrate that the battery charger supplying less than 10 amperes will accept and supply the D.C. bus load independent of its associated battery charger.
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| : b. In accordance with the Surveillance Frequency Control Program and within 7 days after a battery discharge with battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts, by verifying that: L02 SR 3.8.6.3 SR 3.8.6.5
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| : 1) The parameters in Table 4.8-2 meet the Category B limits, See ITS SR 3.8.6.4 2) The average electrolyte temperature of every sixth cell is above 60F, and 5.5.16
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| : 3) There is no visible corrosion at either terminals or connectors, or verify battery connection resistance is: 14 Battery Connection Limit (Micro-Ohms) 3B, 4A inter-cell / termination < 29 inter-cell (brace locations) < 30 transition cables < 125 or total battery connections < 1958 Battery Connection Limit (Micro-Ohms) 3A, 4B, D-52 inter-cell / termination < 35 inter-cell (brace locations) < 40 transition cables < 125 or total battery connections < 2463
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| : c. In accordance with the Surveillance Frequency Control Program by verifying that:
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| : 1) The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration,
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| *Can be extended to 24 hours if the opposite unit is in MODE 5, 6, or defueled and each of the remaining See ITS 3.8.4 required battery chargers is capable of being powered from its associated diesel generator(s).
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| TURKEY POINT - UNITS 3 & 4 3/4 8-14 AMENDMENT NOS. 289 AND 283 Page 2 of 5
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| ITS ITS 3.8.6 A01 D.C. SOURCES See ITS 5.5.16 SURVEILLANCE REOUIREMENTS (Continued) 14
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| : 2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material,
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| : 3) Each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at 129 volts for at least 8 hours, and each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at 129 volts for at least 8 hours, and See ITS
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| : 4) Battery Connection resistance is: 3.8.4 Battery Connection Limit (Micro-Ohms) 3B, 4A inter-cell / termination < 29 See ITS inter-cell (brace locations) < 30 5.5.16 transition cables < 125 14 or total battery connections < 1958 Battery Connection Limit (Micro-Ohms) 3A, 4B, D-52 inter-cell / termination < 35 inter-cell (brace locations) < 40 transition cables < 125 or See ITS total battery connections < 2463 3.8.4
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| : d. In accordance with the Surveillance Frequency Control Program, during shutdown**, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.
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| Add proposed SR 3.8.6.6 Note A04 SR 3.8.6.6, e. At least once per 12 months, during shutdown**, by giving performance discharge tests of second Frequency battery capacity to any battery that shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% [7% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of rated capacity from its LA01 average on previous performance tests, or is below 90% [93% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating.
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| Add proposed SR 3.8.6.6 Note A04 SR 3.8.6.6, first f. In accordance with the Surveillance Frequency Control Program, during shutdown**, by verifying Frequency that the battery capacity is at least 80% [87% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturers rating when subjected to a performance discharge test.
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| Once per 60-month interval this performance discharge test may be performed in lieu of the battery service test required by Specification 4.8.2.1.d.
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| See ITS 3.8.4 Add proposed SR 3.8.6.6 third Frequency L03 Add proposed SR 3.8.6.6 Note A04 SR 3.8.6.6 **Except that the spare battery bank D-52, and any other battery out of service when spare battery bank D-52 is Note in service may be tested with simulated loads during operation.
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| TURKEY POINT - UNITS 3 & 4 3/4 8-15 AMENDMENT NOS. 263 AND 258 Page 3 of 5
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| ITS ITS 3.8.6 A01 TABLE 4.8-2 BATTERY SURVEILLANCE REQUIREMENTS L01 CATEGORY A (1)
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| CATEGORY B (2)
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| L04 PARAMETER LIMITS FOR EACH LIMITS FOR EACH ALLOWABLE(3)
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| DESIGNATED PILOT CONNECTED CELL VALUE FOR EACH L05 CELL CONNECTED CELL SR 3.8.6.3 Electrolyte >Minimum level >Minimum level Above top of LA02 Level indication mark, indication mark, plates, and < 1/4 above and < 1/4 above and not maximum level maximum level overflowing L06 indication mark indication mark Greater than or equal to the minimum established design limits SR 3.8.6.2, Float Voltage 2.13 volts 2.13 volts(6) 2.07 volts See ITS SR 3.8.6.5 2.07 5.5.16 Not more than SR 3.8.6.1 0.020 below the 14 Specific average of all Gravity (4) 1.200(5) 1.195 connected cells L07 Average of all Average of all Connected cells connected cells
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| > 1.205 1.195(5)
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| TABLE NOTATIONS (1) For any Category A parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that within 24 hours all the Category B measurements are taken and found to be within their allowable values, and provided all Category A and B parameter(s) are restored to within limits within the next 6 days.
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| L01 (2) For any Category B parameter(s) outside the limit(s) shown, the battery may be considered OPERABLE provided that the Category B parameters are within their allowable values and provided the Category B parameter(s) are restored to within limits within 7 days.
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| (3) Any Category B parameter not within its allowable value indicates an inoperable battery.
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| (4) Corrected for electrolyte temperature and level. L07 SR 3.8.6.1 (5) Or battery charging current is less than 2 amps when on charge.
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| See ITS (6) Corrected for average electrolyte temperature. 5.5.16 14 TURKEY POINT - UNITS 3 & 4 3/4 8-16 AMENDMENT NOS. 138 AND 133 Page 4 of 5
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| 5/31/22, 9:26 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 595 NRC Question KAB017 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 5/30/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 5/30/2022 9:45 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=595 1/1
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| 3/22/22, 11:23 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 145 NRC Question KAB018 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC Page ITS 3.8.6 discussion of changes (DOC) page 1 of 8, DOC A02 states, "ITS Limiting Question Condition for Operation (LCO) 3.8.6 requires the Battery parameters for Train A and Train B batteries to be within limits when the associated DC electrical power trains are required to be OPERABLE." However, on ITS 3.8.6 page 3.8.6-1, LCO 3.8.6 states, "Battery parameters for the 125 VDC electrical power subsystem shall be within limits." ISTS 3.8.3 states, "Battery parameters for Train A and Train B batteries electrical power subsystem shall be within limits." DOC A02 discusses the ITS 3.8.6 LCO but states the ISTS 3.8.6 LCO. Therefore, revise DOC A02 to reflect either ITS 3.8.6 and its LCO or ISTS 3.8.6 and its LCO or explain why it is appropriate to reference the ISTS 3.8.6 LCO of Train A and Train B as the ITS 3.8.6 LCO.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 10:08 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=145 1/1
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| 8/14/22, 10:16 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 86 NRC Question KAB018 Number Select Licensee Response Application Attachment Attachment 1 - KAB018 LAR Markup.pdf (624KB) 1 Attachment 2
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| Response CTS markup DOC A02 for ITS 3.8.6 will be revised to represent the proposed wording of ITS 3.8.6. The Statement subject sentence in DOC A02 will state, "ITS Limiting Condition for Operation (LCO) 3.8.6 requires the Battery parameters for the 125 VDC electrical power subsystem to be within limits when the associated DC electrical power trains are required to be OPERABLE."
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| A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB018 LAR Markups
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| | |
| ===Response===
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| 4/12/2022 12:30 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 11:31 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=86 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| the 125 VDC electrical power subsystem A02 CTS 3.8.2.1 is applicable during MODES 1, 2, 3, and 4. CTS 3.8.2.2 is applicable during MODES 5 and 6. ITS Limiting Condition for Operation (LCO) 3.8.6 requires the Battery parameters for Train A and Train B batteries to be within limits when the associated DC electrical power trains are required to be OPERABLE. This changes the CTS by replacing the actual MODES with the phrase "When the associated DC electrical power trains are required to be OPERABLE."
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| The purpose of ITS 3.8.6 is to provide battery parameter requirements for safety related batteries. This change combines CTS 3.8.2.1 and CTS 3.8.2.2 requirements for the 125 VDC battery parameters into one Specification. There are no technical changes because of this change since it converts the requirements into the format of the ITS. The proposed LCO states that the required battery's parameters shall be within limits. The proposed Applicability ensures the battery parameter requirements are met when the associated battery is required to be OPERABLE. Any technical changes to the battery parameters are discussed in a Discussion of Change (DOC) specifically associated with that change. Any changes to the LCO and Applicability of the 125 VDC batteries are discussed in the DOCs for ITS 3.8.4 and ITS 3.8.5. This change is designated as administrative because it does not result in technical changes to the CTS.
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| A03 CTS 3.8.2.1 contains a table that describes battery degradation levels where separate actions are taken for each battery depending on the level of degradation. ITS 3.8.6 ACTIONS Note states that separate condition entry is allowed for each battery. This changes the CTS by explicitly stating the intent of CTS.
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| The purpose of ITS 3.8.6 is to provide battery parameter requirements for safety related batteries. As in CTS, exceeding the battery parameter limits in ITS 3.8.6 is indicative of a degradation of battery capacity but the battery may still be capable of performing its specified safety function (i.e., OPERABLE).
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| Compliance with the Required Actions within the associated Completion Times provides assurance that there is still sufficient battery capacity to perform its specified safety function without considering the battery inoperable. As in CTS, if the battery parameter condition degrades such that the parameter is outside the Conditions allowed or the Required Actions are not accomplished within the associated Completion Time the battery is considered inoperable and the Turkey Point Unit 3 and Unit 4 Page 1 of 9
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| 6/1/22, 11:50 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 623 NRC Question KAB018 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 10:22 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=623 1/1
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| 3/22/22, 11:23 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 149 NRC Question KAB019 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 3 of 8, DOC LA02 states that the minimum Question established design limits for battery electrolyte level will be placed in the ITS Bases and that this changes the CTS by moving the specified limits for this surveillance requirement to the ITS Bases. However, the NRC staff cannot find a discussion of the specified electrolyte level limits in CTS Table 4.8-2 in the ITS 3.8.6 Bases. Explain what information is being placed in the ITS Bases and at what location in the ITS Bases.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 10:16 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=149 1/1
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| 8/14/22, 10:15 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 234 NRC Question KAB019 Number Select Licensee Response Application Attachment Attachment 1 - KAB019 LAR Markup.pdf (606KB) 1 Attachment 2
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| Response Following a review of the ITS 3.8.6 Bases, FPL proposes to include the battery electrolyte limits relocated Statement from CTS Table 4.8-2 to the ITS Bases of Surveillance Requirement (SR) 3.8.6.3. The following statement will be added to the SR 3.8.6.3 Bases: "The minimum established design limits for battery electrolyte level are greater than the minimum level indication mark and less than 1/4 inch above maximum level indication mark." A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB019 LAR Markups
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| ===Response===
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| 4/16/2022 9:30 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/16/2022 8:32 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=234 1/1
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| Battery Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS (continued)
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| SR 3.8.6.3 The limit specified for electrolyte level ensures that the plates suffer no The minimum established physical damage and maintains adequate electron transfer capability.
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| design limits for battery [ The Frequency of 31 days is consistent with IEEE-450 (Ref. 1).
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| electrolyte level are greater 1 than the minimum level indication mark and less than OR 1/4 inch above maximum level indication mark. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| SR 3.8.6.4 This Surveillance verifies that the pilot cell temperature is greater than or equal to the minimum established design limit (i.e., [40]°F). Pilot cell 60 1 electrolyte temperature is maintained above this temperature to assure the battery can provide the required current and voltage to meet the design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. [ The Frequency of 31 days is consistent with IEEE-450 (Ref. 1). 1 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 5 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-7 Rev. 5.0 3
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| 6/1/22, 3:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 627 NRC Question KAB019 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 11:44 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=627 1/1
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| 3/22/22, 11:24 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 153 NRC Question KAB020 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.6 discussion of changes (DOC) page 3 of 8, DOC LA02 references CTS Table 4.8.2 Question which doesn't exist in CTS and references CTS Table 4.8-2. Revise DOC LA02 to be consistent with CTS or explain why it is appropriate to reference CTS Table 4.8.2.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 10:21 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=153 1/1
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| 8/14/22, 10:17 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 90 NRC Question KAB020 Number Select Licensee Response Application Attachment Attachment 1 - KAB020 LAR Markup.pdf (661KB) 1 Attachment 2
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| Response ITS 3.8.6, DOC LA02, will be revised to refer to CTS Table 4.8-2. A markup of the affected ITS 3.8.6 DOC ITS Statement Conversion Revision 1 license amendment request page (ITS 3.8.6 DOC page 3 of 9) is attached.
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| ==Attachment:==
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| : 1. KAB020 LAR Markups
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| ===Response===
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| 4/12/2022 12:35 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 11:36 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=90 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS The removal of these details, which are related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform a performance discharge test of battery capacity to any battery that shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of service life expected for the application that continues to assure protection of public health and safety. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 4.8.2.1.b.1 requires verifying that the parameters in Table 4.8-2 meet the Category B. CTS Table 4.8-2 includes the electrolyte level Category B limits for each connected cell that must be verified of that the battery electrolyte level is > the minimum level indication mark, and 1/4 inch above maximum level indication mark in accordance with the Surveillance Frequency Control Program (SFCP). ITS SR 3.8.6.3 requires a similar Surveillance and specifies the acceptance criteria as "greater than or equal to the minimum established design limits." The minimum established design limits for battery electrolyte level will be placed in the ITS Bases. This changes the CTS by moving the specified limits for this SR to the ITS Bases.
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| The removal of these details related to SR limits from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of 4.8-2 public health and safety. This Category B value of CTS Table 4.8.2 represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5.
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| This program provides for the evaluation of changes to ensure the Bases are properly controlled. Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65.
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| This relocation will continue to assure that the battery is maintained at current levels of performance, and that operators appropriately focus on monitoring the battery parameters for degradation. This change is designated as a less restrictive removal of detail change because the Surveillance limits are being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.8.2.1 and CTS 3.8.2.2 provide ACTIONS and associated Completion Times for when a 125 V battery is inoperable due to battery parameters not within limits. In addition, CTS Turkey Point Unit 3 and Unit 4 Page 3 of 9
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| 6/1/22, 3:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 631 NRC Question KAB020 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 11:56 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=631 1/1
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| 3/22/22, 11:24 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 157 NRC Question KAB021 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 4 of 8, DOC L01 references the Actions of CTS Question 3.8.1.2, "AC Sources Shutdown," and states that the actions provide a finite period for continued operation when a battery is inoperable due to battery parameters not within limits.
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| CTS 3.8.1.2 is for AC sources and provides no actions for DC sources such as batteries. In addition, DOC L01 references CTS Table 4.8.2 which doesn't exist in CTS. Should DOC L01 reference CTS Table 4.8-2? Explain why CTS 3.8.1.2 is referenced and correct reference to CTS Table 4.8.2 or explain why it is appropriate to reference CTS Table 4.8.2.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 10:22 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=157 1/1
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| 8/14/22, 10:18 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 94 NRC Question KAB021 Number Select Licensee Response Application Attachment Attachment 1 - KAB021 LAR Markup.pdf (654KB) 1 Attachment 2
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| Response ITS 3.8.6, DOC L01, will be revised to refer to CTS Table 4.8-2 and change the current CTS 3.8.1.2 reference Statement to the correct reference of CTS 3.8.2.2. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page (ITS 3.8.6 DOC page 4 of 9) is attached.
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| ==Attachment:==
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| : 1. KAB021 LAR Markups
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| ===Response===
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| 4/12/2022 1:10 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:09 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=94 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS 4.8-2 Table 4.8.2 provides in the form of Notes (1), (2), and (3), ACTIONS and associated Completions Times when Category A or Category B parameter limits or allowable values are exceeded. In lieu of these current Actions under these conditions, ITS 3.8.6 ACTIONS provide compensatory Required Actions and associated Completion Times when battery parameters are not within limits. This changes the CTS by replacing the current ACTIONS with new compensatory ACTIONS for battery parameters not within limits. 3.8.2.2 The purpose of CTS 3.8.2.1 and CTS 3.8.1.2 ACTIONS are to provide a finite period for continued operation when a battery is inoperable due to battery parameters not within limits. ITS 3.8.6 ACTIONS also allow a certain amount of time to restore battery parameters to within limits before declaring the associated battery inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to correct degraded conditions. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features including the capacity and capability of remaining systems or features, time for repairs or replacement, and the low probability of a Design Basis Accident (DBA) occurring during the Completion Time. ACTIONS have been added to allow a short period to restore parameters to within limits. ITS 3.8.6, ACTION A, covers the condition of one or more batteries with one or more battery cells float voltage less than the specified limit and requires the performance of SR 3.8.4.1 (Verify battery terminal voltage is greater than or equal to the minimum established float voltage) within 2 hours, the performance of SR 3.8.6.1 (Verify each battery float current is 2 amps) within 2 hours, and restoration of the affected cell voltage to within limits within 24 hours. ITS 3.8.6, ACTION B, covers the condition of one or more batteries with float current not within the specified limit and requires the performance of SR 3.8.4.1 within 2 hours and restoration of the battery float current to within limits within 12 hours. ITS 3.8.6, ACTION C, covers the condition of one or more batteries with one or more cells electrolyte level less than minimum established design limits and requires the restoration of electrolyte level to above top of plates within 8 hours, verification that there is no evidence of leakage within 12 hours, and restoration of electrolyte level to greater than or equal to the minimum established design limits within 31 days. ITS 3.8.6, ACTION C Note, requires Required Action C.2 to be completed if electrolyte level was below the top of plates. Because with electrolyte level below the top of the plates there is a potential for dryout and plate degradation, this Note requires verification of no evidence of leakage even if the level is increased above the top of the plates allowing the Condition to be exited. ITS 3.8.6, Required Action C.1 Note, states that Required Actions C.1 and C.2 are only applicable if electrolyte level was below the top of the plates allowing 31 days to restore electrolyte level to greater than or equal to the minimum established design level. ITS 3.8.6, ACTION D, covers the condition of one or more batteries with pilot cell electrolyte temperature less than the minimum established design limits and requires the restoration of battery pilot cell temperature to greater than or equal to minimum established design limits within 12 hours. ITS 3.8.6, ACTION E, covers the condition of one or more batteries in redundant trains with battery parameters not within limits and requires restoration of the battery parameters for two batteries to Turkey Point Unit 3 and Unit 4 Page 4 of 9
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| 6/1/22, 3:38 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 635 NRC Question KAB021 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 12:20 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=635 1/1
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| 3/22/22, 11:28 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 161 NRC Question KAB022 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 5 of 8, DOC L02 states that ITS SR 3.8.6.1 Question requires verification that each battery float current is < 2 amps every 7 days. On ITS 3.8.6 page 3.8.6-3, SR 3.8.6.1 requires verification of each required battery float current is < 2 amps in accordance with the Surveillance Frequency program." Explain why the discussion in DOC L02 does not align with SR 3.8.6.1 in ITS 3.8.6 or correct this inconsistency.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 10:25 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=161 1/1
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| 8/14/22, 10:18 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 98 NRC Question KAB022 Number Select Licensee Response Application Attachment Attachment 1 - KAB022 LAR Markup.pdf (652KB) 1 Attachment 2
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| Response ITS 3.8.6, DOC L02, will be revised to refer to the Surveillance Frequency Control Program as stated in SR Statement 3.8.6.1, removing the reference to 7 days. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page (ITS 3.8.6 DOC page 5 of 9) is attached.
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| ==Attachment:==
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| : 1. KAB022 LAR Markups
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| ===Response===
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| 4/12/2022 1:15 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:15 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=98 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS within limits within 2 hours. ITS 3.8.6, ACTION F, covers the conditions when a Required Action and associated Completion Time of any of the above ACTIONS cannot be met, if one or more batteries with one or more battery cells float voltage and float current are not within limits, or if battery parameters are not within limits for any reason other than Condition A, B, C, D, or E; and requires the immediate declaration that the associated battery is inoperable. The allowances are considered acceptable because only a short period is allowed with battery parameters not within limits. In addition, when one or more batteries in redundant trains have battery parameters not within limit, only 2 hours is allowed to restore at least two battery's parameters before declaring the battery(ies) inoperable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L02 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.2.1.b requires the performance of several Surveillances within 7 days after a battery discharge (battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts. ITS 3.8.6 does not require these Surveillances to be performed after a battery discharge or overcharge. This changes the CTS by not including a specific Surveillance Requirement to perform these tests after a discharge or overcharge.
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| at a periodic frequency in The purpose of the CTS 4.8.2.1.b Frequency is to ensure the batteries remain accordance with the OPERABLE after a severe battery discharge or overcharge. This change is Surveillance Frequency acceptable because other proposed Surveillance Requirements continue to Control Program ensure an acceptable level of equipment reliability. ITS SR 3.8.6.1 requires verification that each battery float current is 2 amps every 7 days. The float current requirements are based on the float current indicative of a charged battery. Therefore, this Surveillance will detect a discharge condition of the battery. In addition, ITS 5.5.14, "Battery Monitoring and Maintenance Program,"
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| requires a program for battery maintenance based on the recommendations of IEEE 450-2010. The requirement to perform these battery preventative maintenance activities are consistent with IEEE 450-2010, and as such, will be maintained in the plant procedures implementing ITS 5.5.15. This change is designated as less restrictive because Surveillances will be performed less frequently under ITS than under CTS.
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| L03 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.2.1.e requires an increased Frequency (Annually) from that in CTS 4.8.2.1.f, in accordance with the SFCP (60 months), for battery performance tests if the battery shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of its expected service life. ITS SR 3.8.6.6 provides two Frequencies when a battery has reached 85% of its expected service life based on whether the battery's remaining capacity is less than 100% or not. If the battery's remaining capacity is less than 100% of the manufactures rating the required discharge test is performed every 12 months (annually). If the battery's remaining capacity is greater than or equal to 100% of the manufactures rating, then the required discharge test is performed every 24 months. This changes the CTS by relaxing the Frequency of required discharge tests when the battery has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of its expected service life.
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| Turkey Point Unit 3 and Unit 4 Page 5 of 9
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| 6/1/22, 3:39 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 639 NRC Question KAB022 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 12:32 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=639 1/1
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| 3/22/22, 11:57 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 165 NRC Question KAB023 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 5 of 8, DOC L02 states that ITS 5.5.14, "Battery Question Monitoring and Maintenance Program," is based on the recommendations of IEEE 450-2010 and then states that the requirement to perform these battery preventative maintenance activities will be maintained in the plant procedures implementing ITS 5.5.15. However, ITS 5.5.15 is the control room envelope (CRE) habitability program. Explain the reference to ITS 5.5.15 and how it applies or correct DOC L02.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 10:56 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=165 1/1
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| 8/14/22, 10:19 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 102 NRC Question KAB023 Number Select Licensee Response Application Attachment Attachment 1 - KAB023 LAR Markup.pdf (731KB) 1 Attachment 2
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| Response ITS 3.8.6 DOC L02 reference to ITS 5.5.15 is incorrect and will be revised to reference ITS 5.5.14, which is Statement the Battery Monitoring and Maintenance Program. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page associated with ITS 3.8.6 is attached.
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| ==Attachment:==
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| : 1. KAB023 LAR Markups
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| ===Response===
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| 4/12/2022 1:20 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:18 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=102 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS within limits within 2 hours. ITS 3.8.6, ACTION F, covers the conditions when a Required Action and associated Completion Time of any of the above ACTIONS cannot be met, if one or more batteries with one or more battery cells float voltage and float current are not within limits, or if battery parameters are not within limits for any reason other than Condition A, B, C, D, or E; and requires the immediate declaration that the associated battery is inoperable. The allowances are considered acceptable because only a short period is allowed with battery parameters not within limits. In addition, when one or more batteries in redundant trains have battery parameters not within limit, only 2 hours is allowed to restore at least two battery's parameters before declaring the battery(ies) inoperable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| L02 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.2.1.b requires the performance of several Surveillances within 7 days after a battery discharge (battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts. ITS 3.8.6 does not require these Surveillances to be performed after a battery discharge or overcharge. This changes the CTS by not including a specific Surveillance Requirement to perform these tests after a discharge or overcharge.
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| The purpose of the CTS 4.8.2.1.b Frequency is to ensure the batteries remain OPERABLE after a severe battery discharge or overcharge. This change is acceptable because other proposed Surveillance Requirements continue to ensure an acceptable level of equipment reliability. ITS SR 3.8.6.1 requires verification that each battery float current is 2 amps every 7 days. The float current requirements are based on the float current indicative of a charged battery. Therefore, this Surveillance will detect a discharge condition of the battery. In addition, ITS 5.5.14, "Battery Monitoring and Maintenance Program,"
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| requires a program for battery maintenance based on the recommendations of 5.5.14 IEEE 450-2010. The requirement to perform these battery preventative maintenance activities are consistent with IEEE 450-2010, and as such, will be maintained in the plant procedures implementing ITS 5.5.15. This change is designated as less restrictive because Surveillances will be performed less frequently under ITS than under CTS.
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| L03 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.8.2.1.e requires an increased Frequency (Annually) from that in CTS 4.8.2.1.f, in accordance with the SFCP (60 months), for battery performance tests if the battery shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of its expected service life. ITS SR 3.8.6.6 provides two Frequencies when a battery has reached 85% of its expected service life based on whether the battery's remaining capacity is less than 100% or not. If the battery's remaining capacity is less than 100% of the manufactures rating the required discharge test is performed every 12 months (annually). If the battery's remaining capacity is greater than or equal to 100% of the manufactures rating, then the required discharge test is performed every 24 months. This changes the CTS by relaxing the Frequency of required discharge tests when the battery has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of its expected service life.
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| Turkey Point Unit 3 and Unit 4 Page 5 of 9
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| 6/1/22, 3:41 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 651 NRC Question KAB023 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 1:50 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=651 1/1
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| 3/29/22, 6:03 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 169 NRC Question KAB024 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 5 of 8, DOC L03 states the purpose of CTS Question 4.8.2.3.2.e is to verify the battery capacity is acceptable on batteries that show signs of degradation or have reached 85% of the service life. CTS 4.8.2.3.2.e does not seem to exist in CTS. Explain why its appropriate to reference CTS 4.8.2.3.2.e or correct DOC L03.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 10:58 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=169 1/1
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| 8/14/22, 10:19 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 106 NRC Question KAB024 Number Select Licensee Response Application Attachment Attachment 1 - KAB024 LAR Markup.pdf (731KB) 1 Attachment 2
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| Response ITS 3.8.6 DOC L03 reference to CTS 4.8.2.3.2.e is incorrect and will be corrected to referenced CTS Statement 4.8.2.1.e. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page associated with ITS 3.8.6 is attached.
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| ==Attachment:==
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| : 1. KAB024 LAR Markups
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| ===Response===
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| 4/12/2022 1:25 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:23 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=106 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS 4.8.2.1.e The purpose of CTS 4.8.2.3.2.e is to verify the battery capacity is acceptable on batteries that show signs of degradation or have reached 85% of the service life.
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| ITS 3.8.6.6 provides an alternative Frequency if the battery that has reached 85% of its service life but has not shown signs of degradation and has a capacity of greater than or equal to 100% of the manufactures rating. This relaxed frequency is acceptable because the battery has not shown signs of degradation, retains greater than or equal to the manufacturers rated capacity, and is being tested at a more frequent periodicity than a battery that has not reached 85%
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| [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the service life expected. Also, IEEE 450-2010 states that if the battery has reached 85% of service life, delivers a capacity of 100% or greater of the manufacturers rated capacity, and has shown no signs of degradation, performance testing at two-year intervals is acceptable until the battery shows signs of degradation.
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| This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.
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| L04 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.a.1 requires verifying the battery parameters in Table 4.8.2 meet Category A limits In accordance with the SFCP. CTS Table 4.8.2 Category A contains the parameter
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| 'Electrolyte Level' with the limit for each designated pilot cell set at "> Minimum level indication mark, and 1/4" above maximum level indication mark."
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| CTS 4.8.2.1.b.1 requires verifying the parameters in Table 4.8-2 meet Category B limits in accordance with the SFCP. CTS Table 4.8.2, Category B, contains the parameter 'Electrolyte Level' with the limit for each connected cell set at "> Minimum level indication mark, and 1/4" above maximum level indication mark." In addition, the Category B electrolyte level Allowable Value for each connected cell (which includes the pilot cells) is above the top of plates, and not overflowing. ITS SR 3.8.6.3 requires verifying each battery connected cell electrolyte level is greater than or equal to minimum established design limits in accordance with the SFCP. This changes the CTS by deleting the requirement to verify the pilot cells electrolyte level is within limits in accordance with the SFCP.
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| The purpose of CTS Category A limit on pilot cell electrolyte level and its related Frequency is to represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. The definition of LCO presented in 10 CFR 50.36 states that LCOs are "the lowest functional capability or performance levels of equipment required for safe operation of the facility." As such, the Category A value for cell electrolyte level does not reflect the 10 CFR 50.36 criteria for LCOs. ITS 5.5.14, "Battery Monitoring and Maintenance Program," requires a program providing controls for battery restoration and maintenance that shall be in accordance with IEEE 450-2010 as endorsed by Regulatory Guide (RG) 1.129, "Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants,"
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| Revision 3, with exceptions and other provisions. IEEE 450-2010 contains, in part, guidance on monitoring electrolyte level with the intention of providing recommended maintenance, test schedules, and testing procedures that can be used to optimize the life and performance of permanently installed, vented lead-acid storage batteries used for standby power applications. These values and actions associated with restoration are being replaced by a Turkey Point Unit 3 and Unit 4 Page 6 of 9
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| 6/1/22, 4:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 655 NRC Question KAB024 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 3:21 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=655 1/1
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| 3/22/22, 12:08 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 173 NRC Question KAB025 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 6 of 8, DOC L04 has multiple references to CTS Question Table 4.8.2 which doesn't exist in CTS. Revise DOC L04 to be consistent with CTS or explain why it is appropriate to reference CTS Table 4.8.2.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 11:00 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=173 1/1
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| 8/14/22, 10:20 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 110 NRC Question KAB025 Number Select Licensee Response Application Attachment Attachment 1 - KAB025 LAR Markup.pdf (185KB) 1 Attachment 2
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| Response ITS 3.8.6 DOC L04 references to CTS Table 4.8.2 are incorrect and will be revised to reference CTS Table Statement 4.8-2. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page associated with ITS 3.8.6 is attached.
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| | |
| ==Attachment:==
| |
| : 1. KAB025 LAR Markups
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| | |
| ===Response===
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| 4/12/2022 1:30 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:27 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=110 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS The purpose of CTS 4.8.2.3.2.e is to verify the battery capacity is acceptable on batteries that show signs of degradation or have reached 85% of the service life.
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| ITS 3.8.6.6 provides an alternative Frequency if the battery that has reached 85% of its service life but has not shown signs of degradation and has a capacity of greater than or equal to 100% of the manufactures rating. This relaxed frequency is acceptable because the battery has not shown signs of degradation, retains greater than or equal to the manufacturers rated capacity, and is being tested at a more frequent periodicity than a battery that has not reached 85%
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| [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the service life expected. Also, IEEE 450-2010 states that if the battery has reached 85% of service life, delivers a capacity of 100% or greater of the manufacturers rated capacity, and has shown no signs of degradation, performance testing at two-year intervals is acceptable until the battery shows signs of degradation.
| |
| This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.
| |
| L04 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.a.1 requires verifying the battery parameters in Table 4.8.2 meet Category A limits In accordance with the SFCP. CTS Table 4.8.2 Category A contains the parameter
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| 'Electrolyte Level' with the limit for each designated pilot cell set at "> Minimum 4.8-2 level indication mark, and 1/4" above maximum level indication mark."
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| CTS 4.8.2.1.b.1 requires verifying the parameters in Table 4.8-2 meet Category B limits in accordance with the SFCP. CTS Table 4.8.2, Category B, contains the parameter 'Electrolyte Level' with the limit for each connected cell set at "> Minimum level indication mark, and 1/4" above maximum level indication mark." In addition, the Category B electrolyte level Allowable Value for each connected cell (which includes the pilot cells) is above the top of plates, and not overflowing. ITS SR 3.8.6.3 requires verifying each battery connected cell electrolyte level is greater than or equal to minimum established design limits in accordance with the SFCP. This changes the CTS by deleting the requirement to verify the pilot cells electrolyte level is within limits in accordance with the SFCP.
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| The purpose of CTS Category A limit on pilot cell electrolyte level and its related Frequency is to represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. The definition of LCO presented in 10 CFR 50.36 states that LCOs are "the lowest functional capability or performance levels of equipment required for safe operation of the facility." As such, the Category A value for cell electrolyte level does not reflect the 10 CFR 50.36 criteria for LCOs. ITS 5.5.14, "Battery Monitoring and Maintenance Program," requires a program providing controls for battery restoration and maintenance that shall be in accordance with IEEE 450-2010 as endorsed by Regulatory Guide (RG) 1.129, "Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants,"
| |
| Revision 3, with exceptions and other provisions. IEEE 450-2010 contains, in part, guidance on monitoring electrolyte level with the intention of providing recommended maintenance, test schedules, and testing procedures that can be used to optimize the life and performance of permanently installed, vented lead-acid storage batteries used for standby power applications. These values and actions associated with restoration are being replaced by a Turkey Point Unit 3 and Unit 4 Page 6 of 9
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| 6/1/22, 4:35 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 659 NRC Question KAB025 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 3:31 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=659 1/1
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| 3/22/22, 12:10 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 177 NRC Question KAB026 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 7 of 8, DOC L05 has multiple references to CTS Question Table 4.8.2 which doesn't exist in CTS. Revise DOC L05 to be consistent with CTS or explain why it is appropriate to reference CTS Table 4.8.2.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 11:02 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=177 1/1
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| 8/14/22, 10:20 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 114 NRC Question KAB026 Number Select Licensee Response Application Attachment Attachment 1 - KAB026 LAR Markup.pdf (133KB) 1 Attachment 2
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| Response ITS 3.8.6 DOC L05 references to CTS Table 4.8.2 are incorrect and will be revised to reference CTS Table Statement 4.8-2. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page associated with ITS 3.8.6 is attached.
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| ==Attachment:==
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| : 1. KAB026 LAR Markups
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| | |
| ===Response===
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| 4/12/2022 1:30 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:29 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=114 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS licensee-controlled program, required and described in Technical Specification Section 5.5, "Programs and Manuals," and titled the "Battery Monitoring and Maintenance Program." This provides adequate assurance that necessary battery parameter values will continue to be controlled and actions will be implemented if the battery parameter values are not met. Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.
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| L05 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.b.1 requires verifying the battery parameters in Table 4.8.2 meet Category B limits in accordance with the SFCP. CTS Table 4.8.2, Category B, contains the 4.8-2 parameter 'Electrolyte Level' with an Allowable Value for each connected cell of "Above top of plates, and not overflowing." In addition, Note (3) states that with any Category B parameter not within its Allowable Value indicates an inoperable battery. ITS SR 3.8.6.3 requires verifying each battery connected cell electrolyte level is greater or equal to minimum established design limits in accordance with the SFCP. ITS 3.8.6, Required Action C.1, requires restoration of battery's electrolyte level to above the top of the plates within 8 hours or Condition F is entered with a Required Action to declare the associated battery inoperable immediately. This changes the CTS by relaxing the requirement of immediately declaring the battery inoperable and allows 8 hours to restore the battery parameter to within limits before declaring the battery inoperable.
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| The purpose of CTS Category B Allowable Value on each connected cell for electrolyte level and its related Frequency is to ensure that the plates suffer no physical damage and maintain adequate electron transfer capability to ensure the battery can perform its specified safety function and maintain a margin of safety. Electrolyte level cannot decrease to below the top of the plates or be overflowing unless it has exceeded the limits prescribed in ITS SR 3.8.6.3. If battery electrolyte level is found outside the minimum established design limits ITS 3.8.6, Condition C, is entered with Required Action C.1 requiring restoring electrolyte level to above the top of the plates within 8 hours or declaring the battery inoperable. With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. ITS 5.5.14, Battery Monitoring and Maintenance Program," requires a program providing controls for battery restoration and maintenance that shall be in accordance with IEEE 450-2010 as endorsed by RG 1.129, Revision 3, with exceptions and other provisions.
| |
| IEEE 450-2010 contains, in part, guidance on monitoring electrolyte level with the intention of providing recommended maintenance, test schedules, and testing procedures that can be used to optimize the life and performance of permanently installed, vented lead-acid storage batteries used for standby power applications.
| |
| New Required Actions C.1 and C.2 restore the electrolyte level and ensure that the cause of the loss of electrolyte level is not due to a leak in the battery cell jar.
| |
| These changes, with the additional requirements in the Battery Monitoring and Maintenance Program, are adequate to ensure that minimum electrolyte levels are maintained. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.
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| Turkey Point Unit 3 and Unit 4 Page 7 of 9
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| 6/1/22, 5:38 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 663 NRC Question KAB026 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 3:39 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=663 1/1
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| 3/22/22, 12:12 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 181 NRC Question KAB027 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 7 of 8, DOC L05 states that the ITS 5.5.14 battery Question monitoring and maintenance program requires a program providing controls for battery restoration and maintenance, in accordance with IEEE 450-2010 as endorsed by Regulatory Guide 1.129, Revision 3 with exceptions. However, there doesn't not appear to be exceptions in proposed ITS 5.5.14. Explain which exceptions apply to ITS 5.5.14.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 11:11 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=181 1/1
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| 8/14/22, 10:21 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 238 NRC Question KAB027 Number Select Licensee Response Application Attachment Attachment 1 - KAB027 LAR Markup.pdf (118KB) 1 Attachment 2
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| Response There are no exceptions to IEEE 450-2010 as endorsed by Regulatory Guide 1.129, Revision 3. The Statement reference to exceptions is not included in the ITS 5.5.14 markup. ITS 5.5 Justification for Deviation (JFD) 7 below provides discussion in this regard (emphasis added). Therefore, the phrase "with exceptions" contained in ITS 3.8.6, DOC L05 will be deleted. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page associated with ITS 3.8.6 is attached.
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| ISTS 5.5.16 is modified in ITS 5.5.14 to reference IEEE 450-2010, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," and Revision 3 of Regulatory Guide (RG) 1.129, "Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants," instead of IEEE 450-2002 and Revision 2 of RG 1.129. RG 1.129, Revision 3 endorses the use of IEEE 450-2010 and eliminates the need for the exceptions specified in ISTS 5.5.16.a; therefore, the exceptions of ISTS 5.5.16.a are not included in ITS 5.5.14. Section 5.4.2 of IEEE 450-2010 states, in part, that specific gravity readings are not recommended to be taken on a regular basis. PTN batteries are lead-calcium type batteries and therefore, specific gravities do not have to be obtained at each discharge test; therefore, ISTS 5.5.16.b.5 is not included in ITS 5.5.14. Use of IEEE 450-2010 and RG 1.129, Revision 3 in the Battery Monitoring and Maintenance Program has been previously approved in Donald C. Cook Nuclear Plant Amendments 343 and 325 dated February 5, 2019 for Units 1 and 2, respectively (NRC ADAMS Accession No. ML18346A358).
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| ===Response===
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| 4/16/2022 9:35 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/16/2022 8:36 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=238 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS licensee-controlled program, required and described in Technical Specification Section 5.5, "Programs and Manuals," and titled the "Battery Monitoring and Maintenance Program." This provides adequate assurance that necessary battery parameter values will continue to be controlled and actions will be implemented if the battery parameter values are not met. Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.
| |
| L05 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.b.1 requires verifying the battery parameters in Table 4.8.2 meet Category B limits in accordance with the SFCP. CTS Table 4.8.2, Category B, contains the parameter 'Electrolyte Level' with an Allowable Value for each connected cell of "Above top of plates, and not overflowing." In addition, Note (3) states that with any Category B parameter not within its Allowable Value indicates an inoperable battery. ITS SR 3.8.6.3 requires verifying each battery connected cell electrolyte level is greater or equal to minimum established design limits in accordance with the SFCP. ITS 3.8.6, Required Action C.1, requires restoration of battery's electrolyte level to above the top of the plates within 8 hours or Condition F is entered with a Required Action to declare the associated battery inoperable immediately. This changes the CTS by relaxing the requirement of immediately declaring the battery inoperable and allows 8 hours to restore the battery parameter to within limits before declaring the battery inoperable.
| |
| The purpose of CTS Category B Allowable Value on each connected cell for electrolyte level and its related Frequency is to ensure that the plates suffer no physical damage and maintain adequate electron transfer capability to ensure the battery can perform its specified safety function and maintain a margin of safety. Electrolyte level cannot decrease to below the top of the plates or be overflowing unless it has exceeded the limits prescribed in ITS SR 3.8.6.3. If battery electrolyte level is found outside the minimum established design limits ITS 3.8.6, Condition C, is entered with Required Action C.1 requiring restoring electrolyte level to above the top of the plates within 8 hours or declaring the battery inoperable. With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. ITS 5.5.14, Battery Monitoring and Maintenance Program," requires a program providing controls for battery restoration and maintenance that shall be in accordance with IEEE 450-2010 as endorsed by RG 1.129, Revision 3, with exceptions and other provisions.
| |
| IEEE 450-2010 contains, in part, guidance on monitoring electrolyte level with the intention of providing recommended maintenance, test schedules, and testing procedures that can be used to optimize the life and performance of permanently installed, vented lead-acid storage batteries used for standby power applications.
| |
| New Required Actions C.1 and C.2 restore the electrolyte level and ensure that the cause of the loss of electrolyte level is not due to a leak in the battery cell jar.
| |
| These changes, with the additional requirements in the Battery Monitoring and Maintenance Program, are adequate to ensure that minimum electrolyte levels are maintained. This change is designated as less restrictive because Surveillances which are required in the CTS will not be required in the ITS.
| |
| Turkey Point Unit 3 and Unit 4 Page 7 of 9
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| 7/1/22, 9:59 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1387 NRC Question KAB027 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/30/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/30/2022 4:11 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1387 1/1
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| 3/22/22, 12:14 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 185 NRC Question KAB028 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 7 of 8, DOC L06 references CTS Table 4.8.2 Question which doesn't exist in CTS. Revise DOC L06 to be consistent with CTS or explain why it is appropriate to reference CTS Table 4.8.2.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 11:13 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=185 1/1
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| 8/14/22, 10:22 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 118 NRC Question KAB028 Number Select Licensee Response Application Attachment Attachment 1 - KAB028 LAR Markup.pdf (172KB) 1 Attachment 2
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| Response ITS 3.8.6 DOC L06 references to CTS Table 4.8.2 are incorrect and will be revised to reference CTS Table Statement 4.8-2. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page associated with ITS 3.8.6 is attached.
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| ==Attachment:==
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| : 1. KAB028 LAR Markups
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| ===Response===
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| 4/12/2022 1:35 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:33 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=118 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS L06 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)
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| CTS 4.8.2.1.a.1 requires verifying the battery parameters in Table 4.8.2 meet Category A limits in accordance with the SFCP. CTS Table 4.8.2, Category A, contains the parameter 'Float Voltage' with a limit for each designated pilot cell of 4.8-2 " 2.13 volts." ITS SR 3.8.6.2 requires the verification that each pilot cell voltage is 2.07 V. ITS 3.8.6, ACTION A, addresses the condition in which one or more batteries with one or more battery cells float voltage less than 2.07 V. Once ACTION A has been entered, the battery cell is considered degraded and the Required Actions are to perform SR 3.8.4.1 and SR 3.8.6.1 within 2 hours. This changes the CTS by reducing the acceptance criteria for pilot cell voltage limits from 2.13 V to 2.07 V.
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| The purpose of the proposed Surveillance limit in ITS SR 3.8.6.2 is to ensure the cell voltages are greater than or equal to the short-term absolute minimum voltage. A cell voltage of 2.07 V or below under float conditions may indicate internal cell problems while prolonged operation of cells below 2.13 V has the potential to reduce the life expectancy of cells. This change is acceptable because it has been determined that the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by reducing the acceptance criteria for pilot cell voltage limits from 2.13 V to 2.07 V. At this lower voltage, the cell can still perform its function. The battery is considered OPERABLE when the battery voltage on float is greater than or equal to the minimum establish voltage of ITS SR 3.8.4.1. This change is acceptable since ITS 5.5.14, "Battery Monitoring and Maintenance Program," has been added and requires actions to be taken to restore battery cells with float voltage < 2.13 V. This program will help ensure the cell voltage will not approach the limit of 2.07 V and that the minimum established voltage of ITS SR 3.8.4.1 is maintained. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.
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| L07 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.a.1 requires the verification that the pilot cell specific gravity is within the Category A limits of Table 4.8-2, as modified by footnote (4) and CTS 4.8.2.1.b.1 requires the verification that the connected cell specific gravity is within the Category B limits of Table 4.8-2, as modified by footnote (4). As indicated in CTS Table 4.8-2 (footnote (4)), the specific gravity limit must be corrected for electrolyte temperature and level. ITS 3.8.6 does not include these Surveillances. This changes the CTS by deleting the Surveillances to verify battery cell specific gravity.
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| The purpose of CTS 4.8.2.1.a.1, and 4.8.2.1.b.1 is to ensure the state of charge of each battery cell. This change is acceptable because the deleted SRs are not necessary to verify that the equipment used to meet the LCO can perform its required functions. Appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. While the specified Surveillances have been deleted, the alternative Surveillances of CTS Table 4.8-2, footnote (5) to verify battery float current is < 2 amps is retained in ITS as SR 3.8.6.1, with Turkey Point Unit 3 and Unit 4 Page 8 of 9
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| 6/1/22, 5:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 667 NRC Question KAB028 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 4:20 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=667 1/1
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| 3/22/22, 12:17 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 189 NRC Question KAB029 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 discussion of changes (DOC) page 8 of 8, DOC L06 states, "This change is Question acceptable because it has been determined that the relaxed SR [surveillance requirement]
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| acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions." Title 10 of the Code of Federal Regulations section 50.36 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. Therefore, the acceptance criteria for the SR is required to be set such that it assures the necessary quality of the systems and components (i.e., battery and battery cells) and that the limiting conditions for operation are met. Explain what is meant by the above sentence in DOC L06 and how the acceptance criteria of each battery pilot cell float voltage of > 2.07 will assure the necessary quality of the pilot battery cell and battery.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 11:15 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=189 1/1
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| 8/14/22, 10:22 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 242 NRC Question KAB029 Number Select Licensee Response Application Attachment Attachment 1 - KAB029 LAR Markup.pdf (158KB) 1 Attachment 2
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| Response The statement, "The change is acceptable because it has been determined that the relaxed SR acceptance Statement criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions," will be deleted. A markup of the affected ITS 3.8.6 DOC ITS Conversion Revision 1 license amendment request page associated with ITS 3.8.6 is attached.
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| As discussed in ITS 3.8.6, DOC L06, the battery pilot cell float voltage of 2.07 volts is the allowable value for each cell and when < 2.07 volts is indicative of battery cell problems, whereas prolonged operation <
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| 2.13 volts may reduce life expectancy. At 2.07 volts, the cell can perform its specified safety function. The value of 2.13 volts is intended for monitoring the long-term health of the cell. In addition, ITS 5.5.14, "Battery Monitoring and Maintenance," requires actions to be taken to restore the battery cell with float voltage < 2.13.
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| ==Attachment:==
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| : 1. KAB029 LAR Markups
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| ===Response===
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| 4/16/2022 9:40 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/16/2022 8:39 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=242 1/1
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| DISCUSSION OF CHANGES ITS 3.8.6, BATTERY PARAMETERS L06 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)
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| CTS 4.8.2.1.a.1 requires verifying the battery parameters in Table 4.8.2 meet Category A limits in accordance with the SFCP. CTS Table 4.8.2, Category A, contains the parameter 'Float Voltage' with a limit for each designated pilot cell of
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| " 2.13 volts." ITS SR 3.8.6.2 requires the verification that each pilot cell voltage is 2.07 V. ITS 3.8.6, ACTION A, addresses the condition in which one or more batteries with one or more battery cells float voltage less than 2.07 V. Once ACTION A has been entered, the battery cell is considered degraded and the Required Actions are to perform SR 3.8.4.1 and SR 3.8.6.1 within 2 hours. This changes the CTS by reducing the acceptance criteria for pilot cell voltage limits from 2.13 V to 2.07 V.
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| The purpose of the proposed Surveillance limit in ITS SR 3.8.6.2 is to ensure the cell voltages are greater than or equal to the short-term absolute minimum voltage. A cell voltage of 2.07 V or below under float conditions may indicate internal cell problems while prolonged operation of cells below 2.13 V has the potential to reduce the life expectancy of cells. This change is acceptable because it has been determined that the relaxed SR acceptance criteria are not necessary for verification that the equipment used to meet the LCO can perform its required functions. This changes the CTS by reducing the acceptance criteria for pilot cell voltage limits from 2.13 V to 2.07 V. At this lower voltage, the cell can still perform its function. The battery is considered OPERABLE when the battery voltage on float is greater than or equal to the minimum establish voltage of ITS SR 3.8.4.1. This change is acceptable since ITS 5.5.14, "Battery Monitoring and Maintenance Program," has been added and requires actions to be taken to restore battery cells with float voltage < 2.13 V. This program will help ensure the cell voltage will not approach the limit of 2.07 V and that the minimum established voltage of ITS SR 3.8.4.1 is maintained. This change is designated as less restrictive because less stringent SRs are being applied in the ITS than were applied in the CTS.
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| L07 (Category 5 - Deletion of Surveillance Requirement) CTS 4.8.2.1.a.1 requires the verification that the pilot cell specific gravity is within the Category A limits of Table 4.8-2, as modified by footnote (4) and CTS 4.8.2.1.b.1 requires the verification that the connected cell specific gravity is within the Category B limits of Table 4.8-2, as modified by footnote (4). As indicated in CTS Table 4.8-2 (footnote (4)), the specific gravity limit must be corrected for electrolyte temperature and level. ITS 3.8.6 does not include these Surveillances. This changes the CTS by deleting the Surveillances to verify battery cell specific gravity.
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| The purpose of CTS 4.8.2.1.a.1, and 4.8.2.1.b.1 is to ensure the state of charge of each battery cell. This change is acceptable because the deleted SRs are not necessary to verify that the equipment used to meet the LCO can perform its required functions. Appropriate equipment continues to be tested in a manner and at a Frequency necessary to give confidence that the equipment can perform its assumed safety function. While the specified Surveillances have been deleted, the alternative Surveillances of CTS Table 4.8-2, footnote (5) to verify battery float current is < 2 amps is retained in ITS as SR 3.8.6.1, with Turkey Point Unit 3 and Unit 4 Page 8 of 9
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| 6/1/22, 5:33 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 671 NRC Question KAB029 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 4:29 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=671 1/1
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| 3/22/22, 12:18 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 193 NRC Question KAB030 Number Category Technical ITS 3.8 Section ITS 3.8.6 Number DOC Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.6 Bases page B 3.8.6-5, ", or failure of SR 3.6.6" is a proposed insert to the Question discussion. However, SR 3.6.6 is an incomplete surveillance requirement number for ITS 3.6.6, "Containment Spray and Cooling systems." Explain which surveillance requirement is being inserted and why.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/22/2022 Added By Caroline Tilton Date Modified Modified By Date 3/22/2022 11:17 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=193 1/1
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| 8/14/22, 10:23 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 122 NRC Question KAB030 Number Select Licensee Response Application Attachment Attachment 1 - KAB030 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response ITS 3.8.6 Bases for ACTION F.1 insertion that states ", or failure of SR 3.6.6" is incorrect and will be revised Statement to state ", or failure of SR 3.8.6.6." A markup of the affected ITS 3.8.6 Bases ITS Conversion Revision 1 license amendment request page associated with ITS 3.8.6 is attached.
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| ==Attachment:==
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| : 1. KAB030 LAR Markups
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| ===Response===
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| 4/12/2022 1:40 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:37 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=122 1/1
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| Battery Parameters B 3.8.6 BASES ACTIONS (continued)
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| E.1 trains With one or more batteries in redundant subsystems with battery 4 parameters not within limits there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer Completion Times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one subsystem 4 train within 2 hours.
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| F.1 With one or more batteries with any battery parameter outside the allowances of the Required Actions for Condition A, B, C, D, or E, sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding battery must be declared inoperable.
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| Additionally, discovering one or more batteries in one subsystem with one 4 or more battery cells float voltage less than [2.07] V and float current 1
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| , or failure of greater than [2] amps indicates that the battery capacity may not be 4 SR 3.6.6 sufficient to perform the intended functions. The battery must therefore be declared inoperable immediately.
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| SURVEILLANCE SR 3.8.6.1 REQUIREMENTS 3.8.6.6 Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.
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| The float current requirements are based on the float current indicative of a charged battery. Use of float current to determine the state of charge of the battery is consistent with IEEE-450 (Ref. 1). [ The 7 day Frequency is consistent with IEEE-450 (Ref. 1). 1 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.6-5 Rev. 5.0 3
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| 6/1/22, 6:09 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 675 NRC Question KAB030 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/1/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/1/2022 4:54 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=675 1/1
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| 3/25/22, 3:38 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 197 NRC Question KAB031 Number Category Editorial ITS 3.8 Section ITS 3.8.8 Number DOC LA-1 Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.8 discussion of changes (DOC) page 2 of 5, DOC LA01 states that CTS 3.8.23.2 Question footnote ... " However, CTS 3.8.23.2 does not exist, CTS 3.8.3.2 appears to be the correct reference. Provide a revised DOC with the correct reference to the CTS or explain how CTS 3.8.23.2 is the correct reference.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:10 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=197 1/1
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| 8/14/22, 10:23 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 126 NRC Question KAB031 Number Select Licensee Response Application Attachment Attachment 1 - KAB031 LAR Markups.pdf (79KB) 1 Attachment 2
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| Response ITS 3.8.8, DOC LA01, will be revised to correctly refer to CTS 3.8.3.2. A markup of the affected ITS 3.8.8 Statement DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB031 LAR Markups
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| ===Response===
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| 4/12/2022 1:45 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/12/2022 12:43 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=126 1/1
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| DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN MODES 5 or 6, LCO 3.0.3 is not applicable and would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with the ITS 3.8.8 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary because defaulting to LCO 3.0.3 would require the reactor to be shut down but would not require suspension of activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires the equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only in MODES 5 and 6.
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| M02 CTS 4.8.3.2 requires that specified busses shall be determined energized in the required manner by verifying correct breaker alignment and indicated voltage on the busses. ITS Surveillance Requirement (SR) 3.8.8.1 requires the verification of correct inverter voltage, frequency, and alignments to required AC vital buses.
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| This changes the CTS by requiring the specific verification of the inverter voltage, frequency, and alignment.
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| The purpose of CTS 4.8.3.2 is to ensure the instrumentation channels are provided with the proper voltage when powered by the associated inverter. This change is acceptable because the Surveillance will continue to verify OPERABILITY of the required inverters by verifying proper voltage and frequency are supplied to the instrumentation channels that provide inputs to the Reactor Trip System and Engineered Safety Features Actuation System. This change is designated as more restrictive because the ITS requires verification of the correct inverter voltage, frequency, and alignment where the CTS does not provide explicit requirements for the inverter.
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| RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.23.2 footnote ** states that a backup inverter may be used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time. ITS 3.8.8 requires, in part, the inverters to be OPERABLE. This changes the CTS by moving this level of detail information into the ITS Bases.
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| The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change Turkey Point Unit 3 and Unit 4 Page 2 of 4
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| 6/2/22, 10:00 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 679 NRC Question KAB031 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/2/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 8:54 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=679 1/1
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| 3/25/22, 3:39 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 201 NRC Question KAB032 Number Category Technical ITS 3.8 Section ITS 3.8.8 Number DOC LA-2 Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.8 discussion of changes (DOC) page 3 of 5, DOC LA02 states that the CTS 3.8.3.2 Question limiting condition for operation (LCO) requirement for the inverters to be connected to their respective DC buses is a level of detail that is being moved into the ITS Bases. However, the NRC staff cannot find a discussion of the inverter connection to its respective DC buses in the ITS 3.8.8 Bases LCO section. Explain how the ITS 3.8.8 Bases LCO section contains this information.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:11 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=201 1/1
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| 8/14/22, 10:24 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 246 NRC Question KAB032 Number Select Licensee Response Application Attachment 1 Attachment 1 - KAB032 LAR Markups.pdf (609KB)
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| Attachment 2 Response The ITS 3.8.8 LCO Bases will be revised to add the detail associated with DOC LA02. The following Statement italicized phrase is added:
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| OPERABILITY of the inverters requires that the AC vital bus be powered by the inverter and the inverter input connected to its respective DC bus.
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| A markup of the affected ITS 3.8.8 Bases ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB032 LAR Markups
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| ===Response===
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| 4/16/2022 9:45 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/16/2022 8:44 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=246 1/1
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| Inverters - Shutdown B 3.8.8 BASES APPLICABLE SAFETY ANALYSES (continued) significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.
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| The shutdown Technical Specification requirements are designed to ensure that the unit has the capability to mitigate the consequences of certain postulated accidents. Worst case DBAs which are analyzed for operating MODES are generally viewed not to be a significant concern during shutdown MODES due to the lower energies involved. The Technical Specifications therefore require a lesser complement of electrical equipment to be available during shutdown than is required during operating MODES. More recent work completed on the potential risks associated with shutdown, however, have found significant risk associated with certain shutdown evolutions. As a result, in addition to the requirements established in the Technical Specifications, the industry has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an Industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. This may require the availability of additional equipment beyond that required by the shutdown Technical Specifications.
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| The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). and the inverter input connected to its respective DC bus LCO The inverter[s] ensure the availability of electrical power for the 1 instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. The battery powered inverter[s] provide[s] 1 uninterruptible supply of AC electrical power to the AC vital bus[es] even if the 4.16 kV safety buses are de-energized. OPERABILITY of the DOC LA02 inverter[s] requires that the AC vital bus be powered by the inverter. This 1 ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling 1
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| recently irradiated fuel]).
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| APPLICABILITY The inverter[s] required to be OPERABLE in MODES 5 and 6 and during 1
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| movement of [recently] irradiated fuel assemblies provide assurance that:
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| : a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,
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| : b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 1 critical reactor core within the previous [X] days)] are available, Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.8-2 Rev. 5.0 3
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| 6/2/22, 10:11 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 683 NRC Question KAB032 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/2/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 9:05 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=683 1/1
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| 3/25/22, 3:39 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 205 NRC Question KAB033 Number Category Technical ITS 3.8 Section ITS 3.8.8 Number DOC L-1 Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.4.12, "Overpressure Mitigation System," provides the requirements for reactor coolant Question system (RCS) pressure relief when in the specified conditions in Modes 4, 5, and 6 and requires depressurizing and establishing a RCS vent of > 2.2 square inches within 24 hours when two power operated relief valves are inoperable. On ITS 3.8.8 Discussion of Changes (DOC) page 3 of 5, DOC L01 states that this completion time is 12 hours instead of 24 hours.
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| Explain why the completions times are different or revise DOC L01.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:12 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=205 1/1
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| 8/14/22, 10:25 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 130 NRC Question KAB033 Number Select Licensee Response Application Attachment Attachment 1 - KAB033 LAR Markups.pdf (659KB) 1 Attachment 2
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| Response ITS 3.8.8, DOC L01, will be revised to state 24 hours consistent with ITS 3.4.12. A markup of the affected Statement ITS 3.8.8 DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB033 LAR Markups
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| ===Response===
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| 4/12/2022 1:45 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/12/2022 12:45 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=130 1/1
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| DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.3.2 states, in part, that as a minimum, the following electrical busses shall be energized in the specified manner, listing two 120-volt AC vital busses for the unit and energized from their associated inverters**
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| connected to their respective DC busses. ITS 3.8.8 LCO states that two inverters shall be OPERABLE. This changes the CTS by moving this level of detail information into the ITS Bases.
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| The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.8.3.2 ACTION requires, in part, that with any of the above required electrical busses not energized in the required manner, the Reactor Coolant System (RCS) must be depressurized and vented within 8 hours through at least a 2.2 square inch vent. ISTS 3.8.8 does not include this Required Action. ITS LCO 3.4.12, "Overpressure Mitigation System," provides requirements for RCS pressure relief when in MODES 4, 5, 24 or 6, to depressurize and establish an RCS vent of 2.2 square inches within 12 hours if the other pressure relief methods are incapable of limiting pressure.
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| This changes the CTS by relying on ITS LCO 3.4.12 to provide the Required Actions and allowing a longer Completion Time to depressurize the RCS and establish a 2.2 square inch RCS vent.
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| The purpose of CTS 3.8.3.2 ACTION is to provide remedial actions to be taken with any of the above required electrical busses not energized in the required manner while in MODE 5 or 6. One of these remedial actions is to depressurize and vent the RCS through at least a 2.2 square inch vent, which is being proposed for deletion. This change is acceptable because the CTS 3.8.3.2 ACTION to depressurize and vent the RCS is duplicative of the ITS LCO 3.4.12 Required Action to depressurize and vent the RCS. In addition, ITS 3.4.12 Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 3 of 4
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| 7/6/22, 5:45 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 691 NRC Question KAB033 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/2/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 10:17 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=691 1/1
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| 3/25/22, 3:40 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 209 NRC Question KAB034 Number Category Technical ITS 3.8 Section ITS 3.8.8 Number DOC L-2 Number JFD Number JFD Bases Number Page Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On CTS page 3/4 8-23, it is proposed that operations involving "CORE ALTERATIONS" be deleted from Question the CTS 3.8.3.2 Action statement. On ITS 3.8.8 Discussion of Changes (DOC) page 4 of 5, DOC L02, with regard to the deletion of core alterations, discusses the standard review plan and then states that suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, would not prevent or impair the mitigation of a fuel handling accident.
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| In order to delete CORE ALTERATIONS from CTS 3.8.3.2 and not include it in ITS 3.8.8,, provide a description of the limitations and controls that would prevent movement of any unirradiated fuel assembly, source, reactivity control component, or other component affecting reactivity within the reactor vessel capable of damaging a fuel assembly prior to the 72 hour decay time assumed in the Fuel Handling Accident (FHA) or demonstrate that the dropping of any unirradiated fuel assembly, sources, reactivity control component, or other component affecting reactivity within the reactor vessel onto irradiated fuel assemblies prior to the 72 hour decay time assumed in the FHA will not result in a radioactive release from the irradiated fuel. See the NRC staff letter, "Plant-Specific Adoption of Travelers TSTF-51, Revision 2, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations, TSTF-471, Revision 1, Eliminate use of Term Core Alterations in Actions and Notes, and TSTF-286, Revision 2, Operations Involving Positive Reactivity Additions dated October 4, 2018, for further information (ADAMS Accession No. ML17346A587).
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=209 1/2
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| 3/25/22, 3:40 PM Turkey Point ITS Conversion Database Date 3/25/2022 12:14 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=209 2/2
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| 8/14/22, 10:25 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 226 NRC Question KAB034 Number Select Licensee Response Application Attachment Attachment 1 - KAB034 LAR Markups.pdf (653KB) 1 Attachment 2
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| Response The Applicability of CTS 3.8.3.2, as shown in ITS 3.8.8, requires two inverters to be OPERABLE in MODES 5 Statement and 6, and during movement of irradiated fuel assemblies. Thus, this requirement applies regardless of whether irradiated fuel assemblies are moved prior to or after the 72-hour decay period assumed in the fuel handling accident (FHA). In addition, CTS 3/4.9.3, Decay Time, does not constrain or address movement of components other than irradiated fuel in the reactor vessel.
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| The limitation that would prevent movement of any unirradiated fuel assembly, source, reactivity control component, or other component affecting reactivity within the reactor vessel capable of damaging a fuel assembly prior to the 72-hour decay time assumed in the FHA is the physical time constraint necessary to remove the reactor vessel head and internals and expose the irradiated fuel after a shutdown. CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the Reactor Coolant System, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours. Therefore, CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is precluded.
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| The retention of CORE ALTERATIONS is unnecessary since the ITS 3.8.8 ACTIONS continue to require suspension of movement of irradiated fuel assemblies (ITS 3.8.8, Required Action A.2.1), which is specified in the Applicability. ITS 3.8.8, DOC L02, will be modified (markup attached) to include this information. An excerpt from ITS 3.8.8, DOC L02, is included below, with the additional information italicized.
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| The purpose of the CTS 3.8.3.2 ACTION is to provide remedial actions to be taken with any of the above required electrical busses not energized in the required manner. CORE ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed and only applies in MODE 6. There is only one accident considered during MODE 6 that involves CORE ALTERATIONS: a fuel handling accident.
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| According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building. Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, would not prevent or impair the mitigation of a fuel handling accident. ITS 3.8.8 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.8, Required Action A.2.1 (for an inoperable inverter). Therefore, because the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of an inverter is covered by the ITS Required Actions, deleting the reference to "CORE ALTERATIONS" is acceptable. Additionally, CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the Reactor Coolant System, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours.
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| A markup of the affected ITS 3.8.8 DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB034 LAR Markups
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| ===Response===
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| 4/15/2022 4:20 PM Date/Time Closure Statement Question https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=226 1/2
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| 8/14/22, 10:25 PM Turkey Point ITS Conversion Database Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/15/2022 3:20 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=226 2/2
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| DISCUSSION OF CHANGES ITS 3.8.8, INVERTERS - SHUTDOWN L02 (Category 4 - Relaxation of Required Action) CTS 3.8.3.2 ACTION states, in part, that that with any of the above required electrical busses not energized in the required manner, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel.
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| ITS 3.8.8, Required Actions A.1, A.2.1, and A.2.2, provide Actions to be performed under similar conditions. These ITS Required Actions state to declare affected required feature(s) inoperable, or to suspend movement of irradiated fuel assemblies and suspend operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN (SDM) or boron concentration. This changes the CTS Actions by deleting the requirement to suspend CORE ALTERATIONS and to clarify to only suspend positive reactivity additions when it could result in loss of required SDM or boron concentration.
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| The purpose of the CTS 3.8.3.2 ACTION is to minimize the possibility of an event ITS 3.8.8 retains the that may need a required electrical bus to mitigate the consequences of the requirement to suspend event. CORE ALTERATIONS is defined in CTS 1.9, in part, as "the movement of movement of irradiated fuel any fuel, sources, reactivity control components, or other components affecting assemblies in ITS 3.8.8, Required Action A.2.1 (for an reactivity, within the reactor vessel with the head removed and fuel in the vessel."
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| inoperable inverter). CORE ALTERATIONS only occur when the reactor vessel head is removed and Therefore, because the only only applies in MODE 6. There is only one accident considered during MODE 6 CORE ALTERATION analyzed in the safety that involves CORE ALTERATIONS: a fuel handling accident. According to the analysis and potentially Standard Review Plan, a fuel handling accident is initiated by the dropping of an affected by a loss of an irradiated fuel assembly, either in the containment or in the fuel building.
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| inverter is covered by the ITS Required Actions, deleting Suspension of CORE ALTERATIONS, except for suspension of movement of the reference to "CORE irradiated fuel, would not prevent or impair the mitigation of a fuel handling ALTERATIONS" is accident.
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| acceptable. Additionally, CORE ALTERATIONS that may be capable of damaging CTS 3.8.3.2 ACTION also requires that with less than the above minimum a fuel assembly prior to the required electrical busses, immediately suspend all operations involving positive 72-hour decay period is improbable because the reactivity changes while ITS 3.8.8, Required Actions A.2.2, requires only the physical time required to suspension of positive reactivity additions that could result in loss of required perform plant shutdown, SDM or boron concentration. This change is acceptable because it allows for cooldown, depressurize the Reactor Coolant System, and positive reactivity additions that do not result in loss of required SDM or boron the additional operations concentration (e.g., water addition or temperature change) assuring continued required to expose the safe operation.
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| irradiated fuel (e.g.,
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| containment entry, removal of vessel head, removal of With the addition of the option to declare required features inoperable with the vessel internals, etc.) is associated inverter(s) inoperable, appropriate restrictions will be implemented in greater than 72 hours. accordance with the affected required features LCOs' Required Actions.
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| However, in many instances, this option may involve undesired administrative efforts. Therefore, the allowance for suspending movement of irradiated fuel assemblies and suspending operations involving positive reactivity additions that could result in loss of required SDM or boron concentration are sufficiently conservative actions. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 4 of 4
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| 6/2/22, 3:50 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 699 NRC Question KAB034 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/2/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 1:26 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=699 1/1
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| 3/25/22, 3:41 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 213 NRC Question KAB035 Number Category Technical ITS 3.8 Section ITS 3.8.9 Number DOC LA-2 Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC CTS page 3/4 8-19, Discussion of Changes (DOC) LA02 points to the spare battery bank D-52 Question requirement in CTS 3.8.3.1 limiting conditions for operation (LCO) l, m, n, and o for the 125 volt DC bus(es). However, DOC LA02 does not discuss the spare battery bank D-52 requirement for the 125 volt DC bus(es). Explain how DOC LA02 applies to the spare battery bank D-52 requirement for the 125 volt DC bus(es) in CTS 3.8.3.1 LCO l, m, n, and o or provide a new DOC that discusses this change to the CTS.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:44 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=213 1/1
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| 8/14/22, 10:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 263 NRC Question KAB035 Number Select Licensee Response Application Attachment Attachment 1 - KAB035 LAR Markup.pdf (735KB) 1 Attachment 2
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| Response FPL reviewed DOC LA02 and agrees that this DOC does not discuss in adequate detail how the spare battery Statement bank D-52 requirement for the 125 volt DC bus(es) in CTS 3.8.3.1 LCO l, m, n, and o. A new DOC, LA04, is attached to provide the discussion. Also attached is a markup of the CTS page and ITS Bases page that will be revised in conjunction with the addition of DOC LA04.
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| ==Attachment:==
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| : 1. KAB035 LAR Markup
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| ===Response===
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| 4/18/2022 3:10 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/18/2022 2:10 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=263 1/1
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| CTS A01 ITS 3.8.9 ONSITE POWER DISTRIBUTION LA02 LIMITING CONDITION FOR OPERATION (Continued)
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| See ITS 3.8.7 LCO 3.8.9.d, j. 120 Volt AC Vital Panel 3P09 and 3P24 energized from its associated inverter connected to D.C.
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| LCO 3.8.9.e Bus 4A.**** or Class 1E constant voltage transformer L01 LCO 3.8.9.d, k. 120 Volt AC Vital Panel 4P09 and 4P24 energized from its associated inverter connected to D.C.
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| LCO 3.8.9.e Bus 4A.**** See ITS 3.8.7 LCO 3.8.9.c l. 125 Volt D.C. Bus 3D01 energized from an associated battery charger and from Battery Bank 3A or spare battery bank D-52, or L02 LCO 3.8.9.c m. 125 Volt D.C. Bus 3D23 energized from an associated battery charger and from Battery Bank 3B or spare battery bank D-52, LCO 3.8.9.c n. 125 Volt D.C. Bus 4D01 energized from an associated battery charger and from Battery Bank 4B or spare battery bank D-52, and or LCO 3.8.9.c o. 125 Volt D.C. Bus 4D23 energized from an associated battery charger and from Battery Bank 4A or spare battery bank D-52 LA02 Applicability APPLICABILITY: MODES 1, 2, 3, and 4. LA04 ACTION:
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| L03 Required Action A.1 NOTE: Enter applicable ACTIONS of LCO 3.8.2.1, D.C. Sources - Operating, for DC trains made Note inoperable by inoperable AC power distribution system.
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| or more LA03 Action A a. With one of the required trains (3.8.3.1a., b., and c) of A.C. emergency busses not fully energized (except for the required LCs and MCCs associated with the opposite unit), reenergize the train within 8 hours or in accordance with the Risk Informed Completion Time Program, or be in at L04 Action E least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Add proposed Required Action E.2 and Note LA03
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| : b. With any of the required LCs and/or MCCs associated with the opposite unit inoperable, restore the inoperable LC or MCC to OPERABLE status in accordance with Table 3.8-1 or Table 3.8-2 as applicable or place the unit in at least HOT STANDBY within 6 hours and in COLD SHUTDOWN within the following 30 hours. L03 or more LA01 or Class 1E constant voltage transformer Action B See ITS c. With one A. C. vital panel either not energized from its associated inverter, or with the inverter not 3.8.7 connected to its associated D.C. bus: (1) Reenergize the A.C. vital panel within 2 hours or in L01 accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY Action F within the next 12 hours and in COLD SHUTDOWN within the following 30 hours; and (2) reenergize the A.C. vital panel from an inverter connected to its associated D.C. bus See ITS 3.8.7 Add proposed Required Action F.2 and Note L05 See ITS 3.8.7
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| ****A back-up inverter may be used to replace the normal inverter, provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.
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| TURKEY POINT - UNITS 3 & 4 3/4 8-19 AMENDMENT NOS. 287 AND 281 Page 2 of 5
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| DISCUSSION OF CHANGES ITS 3.8.9, DISTRIBUTION SYSTEMS - OPERATING which requires the associated LC and MCC to be energized. Individual LCs and MCCs, which help comprise the AC and DC distribution systems, that are not listed in ITS Bases Table B 3.8.9-1 will not result in a complete loss of a redundant safety function necessary to shut down the reactor and maintain it in a safe condition. Therefore, should one or more of these buses become inoperable due to a failure not affecting the OPERABILITY of a bus listed in ITS Bases Table B 3.8.9-1 (e.g., a breaker supplying a single distribution panel fails open), the individual loads on the bus would be declared inoperable, and the appropriate Conditions and Required Actions of the LCOs governing the individual loads would be entered. Also, this change is acceptable because this type of procedural detail will be adequately controlled in the TRM. Changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because specific AC Electrical Power Distribution System LCs and MCCs and associated ACTIONS are being removed from the Technical Specifications.
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| Add DOC LA04 LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS LCO 3.8.3.1 requires the 120 VAC vital panels to be energized from the associated inverters connected to a DC bus. CTS 3.8.3.1, ACTION c, states, in part, that with one AC vital panel either not energized from its associated inverter, or with the inverter not connected to its associated DC bus to reenergize the AC vital panel. There is no other LCO requirement for the inverters to be OPERABLE or actions if inoperable. In the ITS, the inverters are in a separate Specification (ITS 3.8.7 for MODES 1, 2, 3, and 4 or ITS 3.8.8 for the MODES 5 and 6, and during movement of irradiated fuel assemblies). The 120 VAC vital panels are in separate Specifications under the same conditions (ITS 3.8.9 and ITS 3.8.10, respectively). CTS 3.8.3.1, Action c, requires that when a 120 Volt AC vital panel is either not energized from its associated inverter, or with the inverter not connected to its associated DC bus to 1) reenergize the AC vital panel within 2 hours or in accordance with the Risk Informed Completion Time Program, and
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| : 2) reenergize the AC vital panel from an inverter connected to its associated DC bus within 24 hours or in accordance with the Risk Informed Completion Time Program. ITS LCO 3.8.9, in part, requires four unit AC vital electrical power distribution subsystems and required opposite unit AC vital electrical power distribution subsystems to support high head safety injection subsystem, CREVS, CREATCS, and EDG automatic load sequencers. ITS 3.8.9 ACTION B requires, with one or more AC vital electrical power distribution subsystems inoperable, to restore the AC vital electrical power distribution subsystem(s) to OPERABLE status within 2 hours or in accordance with the Risk Informed Completion Time Program. ITS 3.8.7 ACTION A requires, with one required inverter inoperable, to restore the inverter to OPERABLE status within 24 hours or in accordance with the Risk Informed Completion Time Program. This changes the CTS by allowing the 120 VAC vital buses to be considered OPERABLE when powered from a source other than the inverter connected to a DC bus.
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| Turkey Point Unit 3 and Unit 4 Page 6 of 11
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| LA04 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS LCO 3.8.3.1.l, m, n, and o, states, in part, that each 125 Volt D.C. Bus (3D01, 3D23, 4D01, and 4D23) must be energized from an associated battery charger and from its associated Battery Bank (3A, 3B, 4B, or 4A, respectively) or spare battery bank D-52. ITS LCO 3.8.9 states, "The following electrical power distribution trains and subsystems shall be OPERABLE: . . . ."
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| ITS LCO 3.8.9 item c. includes in ITS LCO 3.8.9 OPERABILITY requirements four DC electrical power distribution trains. This changes the CTS by moving the specific detail of what constitutes an OPERABLE DC electrical power distribution train from the CTS to the ITS Bases.
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| The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.8.9 retains the requirement for the required DC electrical power distribution trains to be OPERABLE. In addition, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. The Technical Specification Bases Control Program in Chapter 5 controls changes to the Bases, requiring an evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| Distribution Systems - Operating B 3.8.9 BASES APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient 2
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| SAFETY analyses in the FSAR, Chapter [6] (Ref. 1), and in the FSAR, U 2 1 14 ANALYSES Chapter [15] (Ref. 2), assume ESF systems are OPERABLE. The AC, 3
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| DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.
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| The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution systems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit.
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| This includes maintaining power distribution systems OPERABLE during accident conditions in the event of:
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| : a. An assumed loss of all offsite power or all onsite AC electrical power 1 and
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| : b. A worst case single failure.
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| The distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
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| buses and panels LCO The required power distribution subsystems listed in Table B 3.8.9-1 1 ensure the availability of AC, DC, and AC vital bus electrical power for the systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated DBA. The AC, DC, and AC vital bus electrical power buses and panels distribution subsystems are required to be OPERABLE. 1 Maintaining the Train A and Train B AC, DC, and AC vital bus electrical buses and panels power distribution subsystems OPERABLE ensures that the redundancy 1 incorporated into the design of ESF is not defeated. Therefore, a single failure within any system or within the electrical power distribution subsystems will not prevent safe shutdown of the reactor.
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| trains OPERABLE AC electrical power distribution subsystems require the 1 (D52) associated buses, load centers, motor control centers, and distribution trains panels to be energized to their proper voltages. OPERABLE DC electrical power distribution subsystems require the associated buses and
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| , spare battery, or charger (normal or backup) distribution panels to be energized to their proper voltage from either the 1 associated battery or charger. OPERABLE vital bus electrical power distribution subsystems require the associated buses to be energized to their proper voltage from the associated [inverter via inverted DC voltage, via the static switch inverter using internal AC source, or Class 1E constant voltage 2 transformer].
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| via the maintenance bypass switch INSERT 2 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-2 Rev. 5.0 1
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| 6/3/22, 9:58 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 707 NRC Question KAB035 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/2/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 4:11 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=707 1/1
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| 3/25/22, 3:41 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 217 NRC Question KAB036 Number Category Editorial ITS 3.8 Section ITS 3.8.9 Number DOC LA-2 Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 discussion of changes (DOC) page 4 of 7, DOC L02 states, "In the ISTS Bases, Question the 125 VDC bus remains OPERABLE if ... battery of charger. This changes the CTS by ...
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| from a either..." ISTS 3.8.9 states, "OPERABLE DC... buses... energized... from either the associated battery or charger." Provide a revised DOC L02 correcting the battery "of" charger and from "a" either, or explain why this wording is correct.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:46 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=217 1/1
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| 8/14/22, 10:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 134 NRC Question KAB036 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). ITS 3.8.9, DOC L02, has been modified in Revision 1 of the LAR such that the identified editorials have been corrected. The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, Distribution Systems - Operating, Revision 1, of the ITS Conversion LAR.
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| | |
| ===Response===
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| 4/12/2022 1:50 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:49 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=134 1/1
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| 6/3/22, 9:58 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 711 NRC Question KAB036 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| | |
| ===Response===
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| Statement
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| | |
| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/2/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 4:14 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=711 1/1
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| 3/25/22, 3:42 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 221 NRC Question KAB037 Number Category Technical ITS 3.8 Section ITS 3.8.9 Number DOC L-2 Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 discussion of changes (DOC) page 4 of 7, DOC L02 discusses the change to Question CTS 3.8.3.1 LCO requirement l, m, n, and o for the "125 volt DC" bus(es) to be energized from an associated battery charger and battery bank or the spare battery bank. The second paragraph in DOC L02 begins by discussing the CTS LCO 3.8.3.1 requirements for ensuring the "120 VDC vital panel are energized and specifying how the panels are to be energized" and then discusses the 120 VAC vital panels and their power sources. CTS 3.8.3.1 does not have requirements for "120 VDC vital panel," therefore, it is unclear to the NRC staff what "120 VDC vital panel" is being discussed. In addition, it is not clear to the NRC staff why the 120 VAC vital panels are the reason for the change to the requirements in CTS 3.8.3.1 LCO l, m, n, and o for the 125 VDC bus(es). Provide clarification for the change to the 125 volt DC bus requirements in CTS 3.8.3.1 LCO l, m, n, and o.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:48 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=221 1/1
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| 8/14/22, 10:27 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 267 NRC Question KAB037 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). ITS 3.8.9, DOC L02, has been modified, along with the associated CTS 3.8.3.1 markup, in Revision 1 of the LAR such that the ITS 3.8.9, DOC L02, discussion has been corrected. The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, Distribution Systems - Operating, Revision 1, of the ITS Conversion LAR.
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| | |
| ===Response===
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| 4/18/2022 3:15 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/18/2022 2:14 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=267 1/1
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| 6/3/22, 9:59 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 715 NRC Question KAB037 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/2/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 4:20 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=715 1/1
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| 3/25/22, 3:43 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 225 NRC Question KAB038 Number Category Technical ITS 3.8 Section ITS 3.8.9 Number DOC L-4 Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 discussion of changes (DOC) page 5 of 7, DOC L04 states, " The purpose of CTS Question 3.8.3.1 ACTIONS is to limit the time the unit can remain operating with different combinations of AC emergency buses. Once these limits are exceeded, ACTION F is entered to provide a reasonable time to place the unit in a safe condition." This statement implies CTS Action F.
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| However, CTS 3.8.3.1 does not have an Action F. Provide a revised L04 stating which Action F is being referenced or explain which CTS Action F is being referenced and why it applies.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:50 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=225 1/1
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| 8/14/22, 10:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 138 NRC Question KAB038 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). ITS 3.8.9, DOC L04, has been modified, along with the associated CTS and ITS markups, in Revision 1 of the LAR such that the ITS 3.8.9, DOC L04, now refers to ITS 3.8.9, ACTION E, which contains the requirements for placing the unit in a safe condition.
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| The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, Distribution Systems - Operating, Revision 1, of the ITS Conversion LAR.
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| | |
| ===Response===
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| 4/12/2022 1:55 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:54 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=138 1/1
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| 6/3/22, 10:00 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 719 NRC Question KAB038 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/2/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 4:35 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=719 1/1
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| 3/25/22, 3:43 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 229 NRC Question KAB039 Number Category Editorial ITS 3.8 Section ITS 3.8.9 Number DOC L-5 Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 discussion of changes (DOC) page 6 of 7, DOC L05 states that CTS .8.3.1 Question ACTION c ... " However, CTS .8.3.1 does not exist, CTS 3.8.3.1 appears to be the correct reference. Provide a revised DOC L05 with the correct reference to the CTS or explain how CTS .8.3.1 is the correct reference.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:52 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=229 1/1
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| 8/14/22, 10:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 142 NRC Question KAB039 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). ITS 3.8.9, DOC L05, has been modified in Revision 1 of the LAR such that the ITS 3.8.9, DOC L05, now refers to CTS 3.8.3.1. The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, Distribution Systems - Operating, Revision 1, of the ITS Conversion LAR.
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| | |
| ===Response===
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| 4/12/2022 2:00 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 12:58 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=142 1/1
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| 6/3/22, 10:00 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 723 NRC Question KAB039 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/2/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 4:39 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=723 1/1
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| 3/25/22, 3:44 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 233 NRC Question KAB040 Number Category Editorial ITS 3.8 Section ITS 3.8.9 Number DOC Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 Insert Page B 3.8.9-1a, insert 1 states, "For each unit there are three safety Question related 4.16 kV switchgear, two of which are fed separately from the double secondary windings of its unit auxiliary transformer under normal operating conditions." This sentence is duplicated. Correct insert 1 or explain why the sentence should be duplicated.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:53 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=233 1/1
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| 8/14/22, 10:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 146 NRC Question KAB040 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). ITS 3.8.9 Insert Page B 3.8.9-1a, Insert 1, has been modified in Revision 1 of the LAR such that the duplicated sentence has been removed. The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, Distribution Systems - Operating, Revision 1, of the ITS Conversion LAR.
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| | |
| ===Response===
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| 4/12/2022 2:05 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 1:04 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=146 1/1
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| 6/3/22, 10:05 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 727 NRC Question KAB040 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/2/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 4:48 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=727 1/1
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| 3/25/22, 3:44 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 237 NRC Question KAB041 Number Category Editorial ITS 3.8 Section ITS 3.8.9 Number DOC Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 Bases page B 3.8.9-6, the discussion of Action E states, "The 2 hour Completion Question Time... Regulatory Guide 1.93 (Ref. 3)." It's proposed that "4" be inserted into the sentence such that it appears to change the reference from 3 to 43 as opposed to changing the reference to 4. Correct the reference for Regulatory Guide 1.93 or explain why it should be reference 43.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:55 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=237 1/1
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| 8/14/22, 10:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 150 NRC Question KAB041 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). ITS 3.8.9 Bases Page B 3.8.9-6 has been modified in Revision 1 of the LAR such that the "3" in the original Regulatory Guide 1.93 reference is shown as deleted (lined-through and changed to red text). The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, Distribution Systems - Operating, Revision 1, of the ITS Conversion LAR.
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| | |
| ===Response===
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| 4/12/2022 2:05 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 1:06 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=150 1/1
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| 6/16/22, 1:24 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1163 NRC Question KAB041 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/16/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/16/2022 10:06 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1163 1/1
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| 3/25/22, 3:45 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 241 NRC Question KAB042 Number Category Technical ITS 3.8 Section ITS 3.8.9 Number DOC Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 Bases page B 3.8.9-7, the ITS 3.8.9 Bases Action section changes from a Question discussion of Action F to Action H. It appears that a discussion for Action G is missing.
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| Provide a discussion for Action G or explain where the Action G is discussed in the Bases for ITS 3.8.9.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:56 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=241 1/1
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| 8/14/22, 10:30 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 154 NRC Question KAB042 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). ITS 3.8.9 Bases Page B 3.8.9-7 has been modified in Revision 1 of the LAR such that all Actions are discussed (note that the latter Actions in Revision 1 of the ITS Conversion LAR have been renumbered). The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, Distribution Systems -
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| Operating, Revision 1, of the ITS Conversion LAR.
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| ===Response===
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| 4/12/2022 2:10 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 1:09 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=154 1/1
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| 6/3/22, 10:43 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 735 NRC Question KAB042 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/3/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 9:37 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=735 1/1
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| 3/25/22, 3:45 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 245 NRC Question KAB043 Number Category Technical ITS 3.8 Section ITS 3.8.9 Number DOC Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 Insert Page B 3.8.9-7, insert 6 states, "Another alternate Completion Time for the Question D.C. bus is 24 hours..." On ITS 3.8.9 Bases page B 3.8.9-7, it is proposed that insert 6 be placed at the end of discussion for Action H. Action H has one completion time with a time period of immediately thus, the 24 hours discussed in insert 6 is not applicable to Action H.
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| Insert 6 is applicable to Action E which is discussed on ITS 3.8.9 Bases pages B 3.8.9-5 and B 3.8.9-6. Revise ITS 3.8.9 Bases such that insert 6 is placed in Action E's discussion or explain why it is appropriate in its current location.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:57 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=245 1/1
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| 8/14/22, 10:30 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 158 NRC Question KAB043 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). ITS 3.8.9 Insert Page B 3.8.9-7, Insert 6, has been deleted in Revision 1 of the LAR. The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, Distribution Systems - Operating, Revision 1, of the ITS Conversion LAR.
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| | |
| ===Response===
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| 4/12/2022 2:25 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 1:25 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=158 1/1
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| 6/3/22, 12:01 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 739 NRC Question KAB043 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/3/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 10:06 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=739 1/1
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| 3/25/22, 3:46 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 249 NRC Question KAB044 Number Category Technical ITS 3.8 Section ITS 3.8.9 Number DOC Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On CTS page 3/4 8-18, CTS 3.8.3.1 footnote *** applies to 480 volt motor control center bus D Question and states, "Electrical bus can be energized from either train of its unit and swing function to opposite train must be OPERABLE for the Unit(s) in MODES 1, 2, 3, and 4." On ITS 3.8.9 Insert Page B 3.8.9-9a, insert 7 states that footnotes
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| * and *** apply to the 480 VAC motor control center D. However, the information contained in CTS footnote *** is not in either of the proposed insert 7 footnotes
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| * and ***. Revise ITS 3.8.9 Bases insert 7 to apply the information contained in CTS footnote *** to 480 VAC motor control center D or explain why the information no longer applies to 480 VAC motor control center D.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:58 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=249 1/1
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| 8/14/22, 10:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 279 NRC Question KAB044 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response ITS 3.8.9 Bases has been revised to include the principle of CTS 3.8.3.1 footnote *** in Revision 1 of PTN Statement ITS Conversion LAR and will continue to apply to 480VAC motor control center (MCC) D. The combination of ITS Bases 3.8.9 Insert 1 and Insert 2A in the aggregate clarifies that 480VAC MCC D can be energized from either train via the 480VAC swing load center (LC) bus and that the swing function must be available to the opposite train when redundant required features are powered from the swing MCC, otherwise, the swing bus and associated safety related loads are inoperable. Additionally, ITS 3.8.9 applies in MODES 1, 2, 3, and
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| : 4. Therefore, the *** footnote, as relocated into the Bases, continues to apply when the unit(s) are in MODE 1, 2, 3 or 4. Insert 1 of the ITS Bases 3.8.9 Background section states, in part [emphasis added]:
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| The fifth safety related 480V LC in each unit is a swing LC, which can swing between Train A and B of its associated unit Upon loss of normal power to the swing LC bus, the bus will automatically transfer to the redundant AC electrical power distribution train, if available, to maintain continuity of power to the loads The fourth vital MCC (MCC D) is connected to the unit swing LC, and thus, is considered a swing MCC.
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| Insert 2A of the ITS Bases 3.8.9 LCO section states, in part [emphasis added]:
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| Redundant required features (i.e., redundant trains, subsystems, or components required by the supported system Specifications) may be supplied from the same AC electrical power distribution train via a swing bus (i.e., swing LC or associated swing MCC) and not violate electrical separate criteria provided automatic transfer capability is available to the other AC electrical power distribution train. If the automatic transfer capability is not available when redundant required features are powered from the same AC electrical power distribution train, the swing bus and associated safety related loads are inoperable.
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| ===Response===
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| 4/19/2022 8:50 AM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/19/2022 7:51 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=279 1/1
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| 6/3/22, 12:00 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 743 NRC Question KAB044 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/3/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 10:34 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=743 1/1
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| 3/25/22, 3:46 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 253 NRC Question KAB045 Number Category Technical ITS 3.8 Section ITS 3.8.9 Number DOC Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On CTS page 3/4 8-1, CTS 3.8.1.1 limiting conditions for operation (LCO) b.1)f) states, Question "Energized MCC bus (MCC 3A vital section for EDG 3A, MCC 3K for EDG 3B)," and LCO b.2)d) states, "Energized MCC bus (MCC 4J for EDG 4A, MCC 4K for EDG 4B)." On ITS 3.8.9 Insert Page B 3.8.9-9a, insert 7 states that footnote *** applies to the 480 VAC motor control center (MCC) 3A, 3K, 4J, and 4K. ITS 3.8.9 Bases insert 7 footnote *** states, "For MCC buses, vital sections only." It appears that ITS 3.8.9 Bases insert 7 footnote *** does not align with CTS 3.8.1.1 LCOs b.1)f) and b.2)d) in that it applies the "vital sections only" to more than 480 VAC MCC 3A. Revise ITS 3.8.9 Bases insert 7 to align with CTS 3.8.1.1 LCOs b.1)f) and b.2)d) or explain why ITS 3.8.9 Bases insert 7 footnote *** applies to 480 VAC motor control centers 3K, 4J, and 4K.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 12:59 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=253 1/1
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| 8/14/22, 10:31 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 283 NRC Question KAB045 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response In Revision 1 of the PTN ITS Conversion LAR, CTS 3.8.1.1 limiting conditions for operation (LCO) b.1)f) and Statement LCO b.2)d) are no longer addressed in ITS Section 3.8.9 but are addressed in ITS Section 3.8.1.
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| In ITS Section 3.8.1 CTS 3.8.1.1 LCO b.1)f) and LCO b.2)d) are relocated to the ITS bases as discussed in DOC LA03. The ITS Bases for ITS Section 3.8.1 states under the Background section that the EDGs auxiliaries are powered by motor control centers (MCCs) that are supplied from their respective EDGs; MCCs 3A and 3K for EDGs 3A and 3B, respectively, and MCCs 4J and 4K for EDGs 4A and 4B, respectively.
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| The Bases also states, under the LCO section, that each EDG must be capable of starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus on detection of bus undervoltage. This eliminates the need to specifically require the energization of specific MCCs in the CTS 3.8.1 LCO or the need to include the MCCs in ITS Section 3.8.9.
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| ===Response===
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| 4/19/2022 8:55 AM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/19/2022 7:53 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=283 1/1
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| 6/3/22, 12:00 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 747 NRC Question KAB045 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/3/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 10:48 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=747 1/1
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| 3/25/22, 3:47 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 257 NRC Question KAB046 Number Category Technical ITS 3.8 Section ITS 3.8.9 Number DOC Number JFD Number JFD Bases Number Page Various - see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.9 pages 3.8.9-1, 3.8.9-2, and Insert page 3.8.9-1, ITS Actions A, B, D, and E are Question entered when "one or more" AC buses, DC buses, or AC vital panels become inoperable. In accordance with TSTF-505, Revision 2 as discussed in Section 2.3 of the justification (Table 1, Conditions Requiring Additional Technical Justification, Note 1), some Conditions are applicable when an unspecified number of subsystems are inoperable, typically written as "One or more...". These Conditions currently apply when all subsystems to be operable to perform a function are inoperable, and application of a RICT in this situation is prohibited.
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| To address this the following modification should be made to the completion times potentially applicable when all required subsystems are inoperable.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Caroline Tilton Date Modified Modified By Date 3/25/2022 1:01 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=257 1/1
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| 3/25/22, 3:48 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 49 NRC Question KAB046 Number Select NRC Response Application Attachment 1
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| Attachment 2
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| Response [The original request continues in this response (I was too quick to submit - I apologize).]
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| Statement 72 hours {i.e., the existing completion time}
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| OR
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| ---------------NOTE-----------------
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| Not applicable when
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| [all/two/four/both, etc.] required
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| [channels/subsystems/trains, etc.]
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| are inoperable.
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| In accordance with the Risk Informed Completion Time Program This approach retains the existing licensing basis requirements and limits the use of a RICT to Conditions in which the function can still be performed. Therefore, revise ITS 3.8.9 Conditions A, B, D, and E to incorporate an appropriate version of the above note, or revise ITS 3.8.9 Conditions A, B, D, and E to retain the CTS wording of "one" inoperable AC bus, DC bus, or AC vital panel.
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| Note that NRC has approved simplified versions of this Note such as that in Peach Bottom Atomic Power Station TS 3.8.7 (ADAMS Accession number ML21074A411).
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| ===Response===
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| 3/25/2022 3:25 PM Date/Time Closure Statement Question Closure 3/25/2022 Date Notification Gregg Ellis Christina Long Added By Caroline Tilton Date 3/25/2022 1:04 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=49 1/1
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| 8/14/22, 10:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 287 NRC Question KAB046 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response ISTS 3.8.9, Condition E (Condition G in Revision 1 of the FPL ITS Conversion license amendment request)
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| Statement applies to a configuration where two or more electrical power distribution trains or subsystems are inoperable that result in a loss of safety function. For example, if "two or more" required AC electrical power distribution trains are inoperable such that a loss of safety function exists, both ITS 3.8.9 Condition A and Condition G would be entered. For a loss of safety function (Condition G), immediate entry into LCO 3.0.3 is required. In addition, the FPL Risk Informed Completion Time (RICT) Program, CTS 6.8.4.p.d (ITS 5.5.17.e), contains a prohibition that the RICT cannot be applied for configurations that result in a loss of safety function:
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| "Use of a RICT is not permitted for entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE."
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| As such, addition of the requested Note would be redundant to the RICT Program Completion Time of the specified ITS 3.8.9 Conditions. Therefore, no change to ITS 3.8.9 is proposed with respect to KAB046.
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| ===Response===
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| 4/19/2022 9:00 AM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/19/2022 8:00 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=287 1/1
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| 6/3/22, 2:26 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 751 NRC Question KAB046 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/3/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 1:21 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=751 1/1
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| 3/25/22, 4:10 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 261 NRC Question KAB047 Number Category Editorial ITS 3.8 Section ITS 3.8.1 Number DOC Number JFD Number JFD Bases Number Page ITS 3.8.1 page 3.8.1-4 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.1 page 3.8.1-4, ISTS 3.8.1 Required Action F.1 is changed to ITS 3.8.1 Required Question Action I. This is not consistent with the numbering of other proposed ITS 3.8.1 Actions that have only one Required Action, such as Required Action C.1 and H.1.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/25/2022 Added By Kristy Bucholtz Date Modified Modified By Date 3/25/2022 3:06 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=261 1/1
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| 8/14/22, 10:32 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 162 NRC Question KAB047 Number Select Licensee Response Application Attachment 1
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| Attachment 2
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| Response This was identified by FPL during development of Revision 1 to the FPL ITS Conversion license amendment Statement request (LAR). Note that Condition I has been renumbered as Condition H in Revision 1 of the FPL ITS Conversion LAR. The ITS 3.8.9 markup has been corrected in Revision 1 of the FPL ITS Conversion LAR to appropriately illustrate "H.1". The changes provided in Revision 1 of the ITS Conversion LAR address this RAI. Please refer to Enclosure 2, Volume 13, ITS 3.8.9, AC Sources - Operating, Revision 1, of the ITS Conversion LAR.
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| ===Response===
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| 4/12/2022 2:30 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 1:30 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=162 1/1
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| 6/3/22, 10:01 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 731 NRC Question KAB047 Number Select Application NRC Question Closure Attachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.
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| Question Closure 6/2/2022 Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 4:57 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=731 1/1
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| 3/28/22, 8:56 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 269 NRC Question KAB048 Number Category Editorial ITS 3.8 Section ITS 3.8.10 Number DOC LA-1 Number JFD Number JFD Bases Number Page Various see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.10 discussion of changes (DOC) page 3 of 6, DOC LA01 states, "CTS LCO 3.8.3.2 Question requires AC electrical buses..." However, on CTS page 3/4 8-23, CTS 3.8.3.2 states, "the following electrical buses..." and the buses that follow are both AC and DC. ITS 3.8.10 has requirements for both AC and DC buses. Revise DOC LA01 to be consistent with CTS 3.8.3.2 or explain why it should not be consistent.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/28/2022 Added By Kristy Bucholtz Date Modified Modified By Date 3/28/2022 7:54 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=269 1/1
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| 8/14/22, 10:33 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 271 NRC Question KAB048 Number Select Licensee Response Application Attachment Attachment 1 - KAB048 LAR Markups.pdf (641KB) 1 Attachment 2
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| Response ITS 3.8.10, DOC LA01, will be revised to be consistent with CTS 3.8.3.2 and ITS 3.8.10 wording. "AC" will Statement be removed from the DOC LA01 quote stated in KAB048 above such that all required electrical buses are inclusive in the DOC LA01 discussion. Note that FPL response to KAB053 further modifies ITS 3.8.10, DOC LA01, with respect to the use of terms such as trains, subsystems, and buses. Please refer to the FPL response to KAB053 for further changes to ITS 3.8.10, DOC LA01. A markup of the affected ITS 3.8.10 DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB048 LAR Markups
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| ===Response===
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| 4/18/2022 3:20 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/18/2022 2:19 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=271 1/1
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN This change is acceptable because notwithstanding performance of the other Required Actions, a required RHR subsystem may be inoperable. In this case, the other Required Actions do not adequately address the concerns relating to coolant circulation and heat removal and pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered. Therefore, Required Action A.2.4 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions. This change is designated as more restrictive because additional Required Actions may be taken in the ITS then are in the CTS.
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| RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.2 requires AC electrical power sources to be OPERABLE, listing the sources and subsystems. CTS LCO 3.8.3.2 requires AC electrical buses to be OPERABLE, listing the buses. ITS LCO 3.8.10 requires necessary portions of the AC, DC, and AC vital electrical power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE.
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| ITS Surveillance Requirement (SR) 3.8.10.1 requires the verification of correct breaker alignment and voltage to each required AC, DC, and vital AC electrical power distribution subsystem. The details of the buses are contained in the ITS Bases. This changes the CTS by removing the description of the minimum required buses from the CTS to the ITS Bases.
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| The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignment and voltage to required AC and DC electrical power distribution subsystems. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.3.2 Applicability includes a footnote *** that states "CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for Operation 3.8.3.1." ITS 3.8.10 does not include this caution. This changes the CTS by moving the caution to review the operating units' Technical Specifications from the CTS to the ITS Bases.
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| Turkey Point Unit 3 and Unit 4 Page 3 of 6
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| 6/3/22, 2:48 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 755 NRC Question KAB048 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/3/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 1:45 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=755 1/1
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| 3/28/22, 8:58 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 273 NRC Question KAB049 Number Category Editorial ITS 3.8 Section ITS 3.8.10 Number DOC L-1 Number JFD Number JFD Bases Number Page ITS 3.8.10 DOC page 4 of 6 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.10 discussion of changes (DOC) page 4 of 6, DOC L01 states, "In addition, CTS Question 3.8.2.3 ACTION... " However, CTS 3.8.2.3 does not exist, CTS 3.8.3.2 appears to be the correct reference. Provide a revised DOC L01 with the correct reference to the CTS or explain how CTS 3.8.2.3 is the correct reference.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/28/2022 Added By Kristy Bucholtz Date Modified Modified By Date 3/28/2022 7:57 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=273 1/1
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| 8/14/22, 10:33 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 166 NRC Question KAB049 Number Select Licensee Response Application Attachment Attachment 1 - KAB049 LAR Markups.pdf (646KB) 1 Attachment 2
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| Response ITS 3.8.10, DOC L01, will be revised to correctly refer to CTS 3.8.3.2. A markup of the affected ITS 3.8.10 Statement DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB049 LAR Markups
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| ===Response===
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| 4/12/2022 2:45 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/12/2022 1:45 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=166 1/1
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN The removal of this guidance for performing actions to review the operating units Technical Specifications from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirement to ensure all LCOs are met. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for ensuring Technical Specification requirements are reviewed are being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.3.2 states that as a minimum, the following electrical busses shall be energized in the specified manner with a specific manner of energization, then provides a list of buses with 3.8.3.2 a specific manner of energization listed for the 120 VAC vital buses and the 125 VDC buses. In addition, CTS 3.8.2.3 ACTION provides actions to perform if the buses are not energized in the required manner: ITS 3.8.10 states that the necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. This changes the CTS by specifying how the buses must be energized, stating that the buses must be OPERABLE, thus relying on the definition of OPERABLE/OPERABILITY to decide the manner of energization.
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| The purpose of CTS 3.8.3.2 is to provide an LCO for the onsite power distribution system when shutdown. This change is acceptable because the LCO requirements continue to ensure that the systems are maintained consistent with the safety analyses and licensing basis. The ITS definition of OPERABLE states that a system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s). In addition, ITS LCO 3.8.5, "DC Source - Shutdown," and ITS LCO 3.8.8, "Inverters - Shutdown," provide requirements for the source of power to the DC buses and 120 VAC vital panels.
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| This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.
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| L02 (Category 3 - Relaxation of Completion Time) CTS 3.8.3.2 ACTION requires, in part, that with any of the above required electrical buses not energized in the required manner, the Reactor Coolant System (RCS) must be depressurized and vented within 8 hours through at least a 2.2 square inch vent. ISTS 3.8.8 does not include this Required Action. ITS LCO 3.4.12, "Overpressure Mitigation Turkey Point Unit 3 and Unit 4 Page 4 of 6
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| 6/3/22, 3:00 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 759 NRC Question KAB049 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/3/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 1:53 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=759 1/1
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| 3/28/22, 9:02 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 277 NRC Question KAB050 Number Category Editorial ITS 3.8 Section ITS 3.8.10 Number DOC L-2 Number JFD Number JFD Bases Number Page ITS 3.8.10 DOC page 4 of 6 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.10 discussion of changes (DOC) page 4 of 6, DOC L02 states, "ITS 3.8.8 does not Question include this Required Action." While this is a correct statement, DOC L02 does not discuss its relation to ITS 3.8.10. Explain the relation of DOC L02 to ITS 3.8.10 or revise L02.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/28/2022 Added By Kristy Bucholtz Date Modified Modified By Date 3/28/2022 8:00 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=277 1/1
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| 8/14/22, 10:34 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 170 NRC Question KAB050 Number Select Licensee Response Application Attachment Attachment 1 - KAB050 LAR Markups.pdf (646KB) 1 Attachment 2
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| Response ITS 3.8.10, DOC L02, will be revised to correctly refer to ITS 3.8.10. A markup of the affected ITS 3.8.10 Statement DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB050 LAR Markups
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| ===Response===
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| 4/12/2022 3:05 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 4/12/2022 2:05 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=170 1/1
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN The removal of this guidance for performing actions to review the operating units Technical Specifications from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirement to ensure all LCOs are met. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for ensuring Technical Specification requirements are reviewed are being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.3.2 states that as a minimum, the following electrical busses shall be energized in the specified manner with a specific manner of energization, then provides a list of buses with a specific manner of energization listed for the 120 VAC vital buses and the 125 VDC buses. In addition, CTS 3.8.2.3 ACTION provides actions to perform if the buses are not energized in the required manner: ITS 3.8.10 states that the necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. This changes the CTS by specifying how the buses must be energized, stating that the buses must be OPERABLE, thus relying on the definition of OPERABLE/OPERABILITY to decide the manner of energization.
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| The purpose of CTS 3.8.3.2 is to provide an LCO for the onsite power distribution system when shutdown. This change is acceptable because the LCO requirements continue to ensure that the systems are maintained consistent with the safety analyses and licensing basis. The ITS definition of OPERABLE states that a system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s). In addition, ITS LCO 3.8.5, "DC Source - Shutdown," and ITS LCO 3.8.8, "Inverters - Shutdown," provide requirements for the source of power to the DC buses and 120 VAC vital panels.
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| This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.
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| L02 (Category 3 - Relaxation of Completion Time) CTS 3.8.3.2 ACTION requires, in part, that with any of the above required electrical buses not energized in the required manner, the Reactor Coolant System (RCS) must be depressurized and vented within 8 hours through at least a 2.2 square inch vent. ISTS 3.8.8 does 10 not include this Required Action. ITS LCO 3.4.12, "Overpressure Mitigation Turkey Point Unit 3 and Unit 4 Page 4 of 6
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| 6/3/22, 3:07 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 763 NRC Question KAB050 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/3/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 2:03 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=763 1/1
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| 3/28/22, 9:05 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 281 NRC Question KAB051 Number Category Technical ITS 3.8 Section ITS 3.8.10 Number DOC L-2 Number JFD Number JFD Bases Number Page ITS 3.8.10 DOC page 4 of 6 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.4.12, "Overpressure Mitigation System," provides the requirements for reactor coolant Question system (RCS) pressure relief when in the specified conditions in Modes 4, 5, and 6 and requires depressurizing and establishing an RCS vent of > 2.2 square inches within 24 hours when both power operated relief valves are inoperable. On ITS 3.8.10 Discussion of Changes (DOC) page 4 of 6, DOC L02 states that this completion time is 12 hours instead of 24 hours. Explain why the completions times are different or revise DOC L02.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/28/2022 Added By Kristy Bucholtz Date Modified Modified By Date 3/28/2022 8:04 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=281 1/1
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| 8/14/22, 10:34 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 174 NRC Question KAB051 Number Select Licensee Response Application Attachment Attachment 1 - KAB051 LAR Markups.pdf (665KB) 1 Attachment 2
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| Response ITS 3.8.10, DOC L02, will be revised to state 24 hours consistent with ITS 3.4.12. A markup of the affected Statement ITS 3.8.10 DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB051 LAR Markups
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| ===Response===
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| 4/12/2022 3:10 PM Date/Time Closure Statement Question Closure 4/12/2022 Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/12/2022 2:14 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=174 1/1
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN System," provides requirements for RCS pressure relief when in MODES 4, 5, or 6 to depressurize and establish an RCS vent of 2.2 square inches within 24 12 hours if the other pressure relief methods are incapable of limiting pressure.
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| This changes the CTS by relying on ITS LCO 3.4.12 to provide the Required Actions and allowing a longer Completion Time to depressurize the RCS and establish a 2.2 square inch RCS vent.
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| The purpose of CTS 3.8.3.2 Action is to provide remedial actions to be taken with any of the above required electrical buses not energized in the required manner while in MODE 5 or 6. One of these remedial actions is to depressurize and vent the RCS through at least a 2.2 square inch vent, which is being proposed for deletion. This change is acceptable because the CTS 3.8.3.2 ACTION to depressurize and vent the RCS is duplicative of the ITS LCO 3.4.12 Required Action to depressurize and vent the RCS. In addition, ITS 3.4.12 Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| L03 (Category 4 - Relaxation of Required Action) CTS 3.8.3.2 ACTION states, in part, that that with any of the above required electrical busses not energized in the required manner, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel.
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| ITS 3.8.10, Required Actions A.2.1 and A.2.2, provide Actions to be performed under similar conditions. These ITS Required Actions state to suspend movement of irradiated fuel assemblies and suspend operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN (SDM) or boron concentration. This changes the CTS Actions by deleting the requirement to suspend CORE ALTERATIONS and to clarify to only suspend positive reactivity additions when it could result in loss of required SDM or boron concentration.
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| The purpose of the CTS 3.8.3.2 ACTION is to minimize the possibility of an event that may need a required electrical bus to mitigate the consequences of the event. CORE ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel."
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| CORE ALTERATIONS only occur when the reactor vessel head is removed and only applies in MODE 6. There is only one accident considered during MODE 6 that involves CORE ALTERATIONS: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building.
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| Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, would not prevent or impair the mitigation of a fuel handling accident.
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| Turkey Point Unit 3 and Unit 4 Page 5 of 6
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| 6/3/22, 3:10 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 767 NRC Question KAB051 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/3/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/3/2022 2:08 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=767 1/1
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| 3/28/22, 9:46 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 285 NRC Question KAB052 Number Category Technical ITS 3.8 Section ITS 3.8.10 Number DOC L-3 Number JFD Number JFD Bases Number Page ITS 3.8.10 DOC page 5 of 6 Number(s)
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| NRC Reviewer Select Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On CTS page 3/4 8-23, it is proposed that operations involving "CORE ALTERAIONS" be deleted from the Question CTS 3.8.3.2 Action statement. On ITS 3.8.10 Discussion of Changes (DOC) page 5 of 6, DOC L03, with regard to the deletion of core alterations, discusses the standard review plan and then states that suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, would not prevent or impair the mitigation of a fuel handling accident (FHA).
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| In order to delete CORE ALTERATIONS from CTS 3.8.3.2 and not include it in ITS 3.8.10, provide a description of the limitations and controls that prevent movement of any unirradiated fuel assembly, source, reactivity control component, or other component affecting reactivitiy within the reactor vessel capable of damaging a fuel assembly prior to the 72 hour decay time assumed in the FHA or demonstrate that the dropping of any unirradiated fuel assembly, sources, reactivity control component, or other component affecting reactivity within the reactor vessel onto irradiated fuel assemblies prior to the 72 hour decay time assumed in the FHA will not result in a radioactive release from the irradiated fuel. See the NRC staff letter, "Plant-Specific Adoption of Travelers TSTF-51, Revision 2, "Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations," TSTF-471, Revision 1, "Eliminate use of Term Core Alterations in Actions and Notes," and TSTF-286, Revision 2, 'Operations Involving Positive Reactivity Additions,'" dated October 4, 2018, for further information (ADAMS Accession Number ML17346A587).
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| Attach File 1
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| Attach File 2
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| Issue Date 3/28/2022 Added By Kristy Bucholtz Date Modified Modified By Date 3/28/2022 8:30 AM Added Notification Gregg Ellis https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=285 1/2
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| 3/28/22, 9:46 AM Turkey Point ITS Conversion Database Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=285 2/2
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| 8/14/22, 10:35 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 230 NRC Question KAB052 Number Select Licensee Response Application Attachment Attachment 1 - KAB052 LAR Markups.pdf (626KB) 1 Attachment 2
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| Response The Applicability of CTS 3.8.3.2, as shown in ITS 3.8.10, requires the necessary portion of AC, DC, and AC Statement vital bus electrical power distribution subsystems to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies. Thus, this requirement applies regardless of whether irradiated fuel assemblies are moved prior to or after the 72-hour decay period assumed in the fuel handling accident (FHA). In addition, CTS 3/4.9.3, Decay Time, does not constrain or address movement of components other than irradiated fuel in the reactor vessel.
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| The limitation that would prevent movement of any unirradiated fuel assembly, source, reactivity control component, or other component affecting reactivity within the reactor vessel capable of damaging a fuel assembly prior to the 72-hour decay time assumed in the FHA is the physical time constraint necessary to remove the reactor vessel head and internals and expose the irradiated fuel after a shutdown. CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the RCS, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours. Therefore, CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is precluded.
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| The retention of CORE ALTERATIONS is unnecessary since the ITS 3.8.10 ACTIONS continue to require suspension of irradiated fuel assemblies (ITS 3.8.10, Required Action A.2.1), which is specified in the Applicability. ITS 3.8.10, DOC L03, will be modified (markup attached) to include this information. An excerpt from ITS 3.8.10, DOC L03, is included below, with the additional information italicized.
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| "The purpose of the CTS 3.8.3.2 ACTION is to minimize the possibility of an event that may need a required electrical bus to mitigate the consequences of the event. CORE ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed and only applies in MODE 6. There is only one accident considered during MODE 6 that involves CORE ALTERATIONS: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building. Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, would not prevent or impair the mitigation of a fuel handling accident. ITS 3.8.10 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.10, Required Action A.2.1 (for one or more inoperable electrical power distribution buses). Therefore, because the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of an electrical power distribution bus is covered by the ITS Required Actions, deleting the reference to "CORE ALTERATIONS" is acceptable. Additionally, CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the RCS, and the additional operations required to expose the irradiated fuel (e.g.,
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| containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours."
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| A markup of the affected ITS 3.8.10 DOC ITS Conversion Revision 1 license amendment request page is attached.
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| ==Attachment:==
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| : 1. KAB052 LAR Markups
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| ===Response===
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| 4/15/2022 5:10 PM Date/Time Closure Statement Question Closure https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=230 1/2
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| 8/14/22, 10:35 PM Turkey Point ITS Conversion Database Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 4/15/2022 4:08 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=230 2/2
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ITS 3.8.10 retains the requirement to suspend movement of irradiated fuel CTS 3.8.3.2 ACTION also requires that with less than the above minimum assemblies in ITS 3.8.10, required electrical busses, immediately suspend all operations involving positive Required Action A.2.1 (for reactivity changes while ITS 3.8.10, Required Action A.2.2, requires only one or more inoperable electrical power distribution suspending operations involving positive reactivity additions that could result in buses). Therefore, because loss of required SDM or boron concentration. This change is acceptable the only CORE because it allows for positive reactivity additions that do not result in loss of ALTERATION analyzed in the safety analysis and required SDM or boron concentration (e.g., water addition or temperature potentially affected by a loss change) assuring continued safe operation.
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| of an electrical power distribution bus is covered by the ITS Required Actions, This change is designated as less restrictive because less stringent Required deleting the reference to Actions are being applied in the ITS than were applied in the CTS.
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| "CORE ALTERATIONS" is acceptable. Additionally, CORE ALTERATIONS that may be capable of damaging a fuel assembly prior to the 72-hour decay period is improbable because the physical time required to perform plant shutdown, cooldown, depressurize the RCS, and the additional operations required to expose the irradiated fuel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.) is greater than 72 hours.
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| Turkey Point Unit 3 and Unit 4 Page 6 of 6
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| 6/2/22, 3:07 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 703 NRC Question KAB052 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/2/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/2/2022 1:27 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=703 1/1
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| 3/28/22, 9:47 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 289 NRC Question KAB053 Number Category Technical ITS 3.8 Section ITS 3.8.10 Number DOC Number JFD Number JFD Bases Number Page Various pages see request Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC On ITS 3.8.10 page 3.8.10-1, ITS 3.8.10 limiting conditions for operation (LCO) states, Question "...electrical power distribution subsystems..." and Condition A states, "...electrical power distribution buses..." On ITS 3.8.10 discussion of changes (DOCs) pages 1 through 6, multiple DOCs refer to "electrical power distribution subsystems," "electrical power distribution boards and panels," and "electrical power distribution buses." Additionally, on ITS 3.8.9 page 3.8.9-1, LCO states, "...electrical power distribution buses and panels..."
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| Revise ITS 3.8.10, ITS 3.8.9 and their DOCs so that they are consistent or explain why they should not be consistent with one another.
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| Attach File 1
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| Attach File 2
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| Issue Date 3/28/2022 Added By Kristy Bucholtz Date Modified Modified By Date 3/28/2022 8:41 AM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=289 1/1
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| 8/3/22, 5:37 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 347 NRC Question KAB053 Number Select Licensee Response Application Attachment Attachment 1 - KAB053 LAR Markup R2.pdf (2MB) 1 Attachment 2
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| Response In Revision 1 of the PTN ITS Conversion LAR, the electrical distribution systems have been designated as Statement the following:
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| * AC electrical power distribution trains;
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| * DC electrical power distribution trains; and
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| * AC Vital electrical power distribution subsystems.
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| ITS Section 3.8.10 and ITS 3.8.10 DOCs will be revised to incorporate these designations. See attached markups.
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| In Revision 1 of the PTN ITS Conversion LAR ITS 3.8.9, page 3.8.9-1, LCO 3.8.9, has been revised to state,"
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| The following electrical power distribution trains and subsystems shall be OPERABLE: . . . What follows are AC electrical power distribution trains, DC electrical power distribution trains, and AC vital electrical power distribution subsystems. Reference to electrical power distribution buses and panels has been removed.
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| During FPLs review of ITS 3.8.10, additional changes were identified and include deletion of Inserts 1, 2, and 3 in the ITS 3.8.10 Bases markup. ITS 3.8.10 Bases Insert 1 list the buses that shall be energized. The ITS Bases is not intended to specify requirements. In addition, listing specific buses that shall be energized conflicts with LCO 3.8.10, which requires the necessary portion of the AC and DC electrical power distribution trains, and AC vital electrical power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE. The specific list of buses in CTS 3.8.3.2 is not retained in the ITS 3.8.10 Bases but rather is being deleted as specified in DOC M01. ITS 3.8.10 Bases Insert 1 also contains footnote *, which specifies performing an engineering evaluation with conditions necessary to cross-tie 480V load centers when the opposite unit is in MODE 1, 2, 3, or 4. However, this footnote is unnecessary since an engineering evaluation has already been performed to determine the acceptability of closing cross-tie breakers on 480V load centers during shutdown conditions considering the opposite unit is in MODE 1, 2, 3, or 4 and incorporated in plant operational procedures, as applicable. Footnote
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| * is not retained in the ITS 3.8.10 Bases but rather is being deleted as specified in DOC A03. ITS 3.8.10 Bases Insert 2 provides a table of MCCs needed to support other components required during MODES 5 and 6.
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| This table relates to CTS LCO 3.8.1.2.b.6 that is not retained in the ITS 3.8.10 Bases but rather is proposed to be deleted as specified in DOC M01 because the LCO may require more electrical power distribution trains or subsystems to support equipment required to be OPERABLE. Therefore, to avoid a conflict with the requirements of LCO 3.8.10, which requires the necessary portion of the electrical distribution trains and subsystems to be OPERABLE to support equipment required to be OPERABLE, Inserts 1 and 2 to the ITS 3.8.10 Bases are deleted. Insert 3 relates to CTS 3.8.3.2, Applicability, footnote ***. This footnote is not retained in the ITS 3.8.10 Bases but rather is proposed to be deleted as specified in DOC A02. The purpose of the CTS 3.8.3.2 Applicability Note is to ensure appropriate action requirements are performed for equipment shared between both units when required for a specific MODE of operation. This Note is redundant to the generic requirement provided in CTS 3.0.5 (ITS LCO 3.0.10) and, therefore, is not necessary. Therefore, Insert 3 to the ITS 3.8.10 Bases is being deleted. Deletion of these Inserts eliminates unnecessary deviation from the ISTS 3.8.10 Bases. See attached markups.
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| Attachments
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| : 1. KAB053 LAR Markups
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| ===Response===
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| 5/3/2022 2:40 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=347 1/2
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| 8/3/22, 5:37 PM Turkey Point ITS Conversion Database Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 5/3/2022 1:41 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=347 2/2
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| ITS ITS 3.8.10 A01 A.C. SOURCES SHUTDOWN Add proposed LCO 3.8.10 M01 LIMITING CONDITION FOR OPERATION See ITS LCO 3.8.10 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE: 3.8.2
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| : a. One startup transformer and associated circuits, or an alternate circuit, between the offsite transmission network and the 4160 volt bus, A or B, and
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| : b. One diesel generator with:
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| : 1) For Unit 3 (3A or 3B)
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| A skid-mounted fuel tank and a day fuel tank, with an OPERABLE solenoid valve to permit gravity flow from the day tank to the skid mounted tank, with the two tanks together containing a minimum of 2000 gallons of fuel oil For Unit 4 (4A or 4B)
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| A day fuel tank containing a minimum volume of 230 gallons of fuel
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| : 2) A fuel storage system containing a minimum volume of fuel of 38,000 gallons (Unit 3).
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| 34,700 gallons (Unit 4)**
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| : 3) An associated fuel transfer pump** See ITS See ITS 3.8.3 3.8.2
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| : 4) For Unit 3 only, lubricating oil storage containing a minimum volume of 120 gallons of lubricating oil
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| : 5) For Unit 3 only capability to transfer lubricating oil from storage to the diesel generator unit and LA01
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| : 6) Energized MCC bus (as identified by Specification 3.8.1.1.b.).
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| See ITS M01 Applicability APPLICABILITY: MODES 5* and 6*. 3.8.2 During movement of irradiated fuel assemblies M02 ACTION:
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| Add proposed ACTIONS Note NOTE: Enter the ACTION of LCO 3.8.3.2, Onsite Power Distribution - Shutdown, with one required train de-energized as a result of inoperable offsite circuit.
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| With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, movement of irradiated fuel, or crane operation with loads over the fuel storage pool, and within 8 hours, depressurize and vent the Reactor Coolant System through a greater than or equal to 2.2 square inch vent. In addition, when in MODE 5 with the reactor coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor vessel flange, immediately initiate corrective action to restore the required sources to OPERABLE status as soon as possible and increase RCS inventory as soon as possible.
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| See ITS See ITS
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| * CAUTION - If the opposite unit is in MODES 1. 2. 3, or 4 see Specification 3.8.1.1 3.8.2 3.8.3
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| ** A temporary Class III fuel storage system containing a minimum volume of 38,000 gallons of fuel oil may be used for up to 10 days during the performance of Surveillance Requirement 4.8.1.1.2i.1 for the Unit 3 storage tank while Unit 3 is in Modes 5, 6, or defueled. If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively.
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| TURKEY POINT - UNITS 3 & 4 3/4 8-11 AMENDMENT NOS. 287 AND 281
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| 2022-03 PTN ITS Converson Rev. 1 Page 3034 of 3381 ITS ITS 3.8.10 A01 ONSITE POWER DISTRIBUTION SHUTDOWN LIMITING CONDITION FOR OPERATION Add proposed LCO 3.8.10 M01 LCO 3.8.10 3.8.3.2 As a minimum, the following electrical busses shall be energized in the specified manner: M01 LA01
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| : a. One train of A.C. emergency busses associated with the unit (3.8.3.1a. or b.) consisting of one 4160-volt and three 480-volt A.C. emergency busses load centers* and three (four for Unit 4 Train A) vital sections of motor control center busses, See ITS 3.8.8
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| : b. Two 120-volt A.C. vital busses for the unit energized from their associated inverters** connected to their respective D.C. busses, and See ITS 3.8.5 LA02
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| : c. Three 125-volt D.C. busses energized from their associated battery banks.
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| A02 Applicability APPLICABILITY MODES 5*** and 6***. M02 During movement of irradiated fuel assemblies ACTION:
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| Add proposed ACTIONS Note L01 With any of the above required electrical busses not energized in the required manner, immediately suspend all Action A operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel, initiate corrective action to energize the required electrical busses in the specified manner as soon as possible, and L02 within 8 hours, depressurize and vent the RCS through at least a 2.2 square inch vent.
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| Add proposed Required Actions A.2.1 and A.2.2 Add proposed Required Action A.1 SURVEI LLANCE REQUIREMENTS L03 M01 SR 3.8.10.1 4.8.3.2 The specified busses shall be determined energized in the required manner by verifying correct breaker alignment and indicated voltage on the busses in accordance with the Surveillance Frequency Control Program.
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| L01 Add proposed Required Action A.2.4 M03 LA01
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| * With the opposite unit in MODE 1, 2, 3, or 4, the 480-volt load centers can only be cross-tied upon issuance of an engineering evaluation to prevent exceeding required electrical components maximum design ratings and to ensure availability of the minimum required equipment. See ITS A03 3.8.8
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| ** A backup inverter may be used to replace the normal inverter provided the normal inverter on the same DC bus for the opposite unit is not replaced at the same time.
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| LA02
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| *** CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for Operation 3.8.3.1. A02 TURKEY POINT - UNITS 3 & 4 3/4 8-23 AMENDMENT NOS. 263 AND 258
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
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| These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
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| Insert A02 and A03 and DC electrical power MORE RESTRICTIVE CHANGES distribution trains M01 CTS 3.8.1.2.b.6 requires, in part, one Emergency Diesel Generator (EDG) with an energized motor control center (MCC) bus (as identified by Specification 3.8.1.1.b. CTS 3.8.3.2 states, in part, that as a minimum, the following AC buses shall be energized in the specified manner and then lists the applicable busses and how the buses are energized. ITS Limiting Condition for Operation (LCO) 3.8.10 states that the necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. In addition, an optional Required Action (ITS 3.8.10, Required Action A.1) has been added which allows the associated supported required feature(s) to be declared inoperable. This changes the CTS by requiring those necessary portions of electrical power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE, which could require more distribution buses or panels to be OPERABLE than is currently trains and required. In addition, an action has been added to allow an option to the existing actions. and DC electrical power distribution trains The purpose of CTS 3.8.1.2.b.6 and CTS 3.8.3.2 is to ensure that a minimum number of electrical buses are energized (i.e., OPERABLE). This change adds a requirement that the applicable portions of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE by the Technical Specifications. This added restriction conservatively assures the needed electrical power distribution boards and panels are OPERABLE, even if this results in both trains of one or more of the electrical power distribution systems being required. Because the ITS 3.8.10 electrical power distribution subsystem OPERABILITY requirements require the trains and necessary portions of the distribution subsystems to be OPERABLE to support equipment required to be OPERABLE, if a portion of the electrical power distribution subsystem cannot supply any required equipment, that electrical power distribution subsystem is inoperable. In this event, it may not be train or necessary to suspend irradiated fuel handling and positive reactivity additions.
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| Conservative actions can be assured if all required equipment without the necessary power is declared inoperable, and the associated ACTIONS of the individual equipment is taken (ITS 3.8.10, Required Action A.1). Therefore, along with the conservative additional requirements placed on the electrical Turkey Point Unit 3 and Unit 4 Page 1 of 6
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| A02 CTS 3.8.3.2 (ITS 3.8.10) is applicable in MODES 5 and 6. The CTS 3.8.3.2 Applicability is modified by a Note *** which states, "CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for Operation 3.8.3.1." ITS 3.8.10 does not contain a similar Note. This changes the CTS by deleting a requirement that is redundant to CTS 3.0.5, which is retained in ITS.
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| The purpose of the CTS 3.8.3.2 Applicability Note is to ensure appropriate action requirements are performed for equipment shared between both units when required for a specific MODE of operation. This Note is redundant to the generic requirement provided in CTS 3.0.5 (ITS LCO 3.0.10) and, therefore, is not necessary. CTS 3.0.5 states, in part, "Limiting Conditions for Operation including the associated ACTION requirements shall apply to each unit individually unless otherwise indicated This requirement is retained in ITS LCO 3.0.10. As a result, Technical Specification requirements are applicable to each unit and apply, based on the units applicable MODE, to the requirements associated with an LCO that refers to systems and components shared by both units, irrespective of whether an explicit statement is provided or not. The appropriate Technical Specification ACTIONS associated with shared systems will continue to be performed for each unit based on the units applicable MODE or specified condition per the requirements of ITS LCO 3.0.10. This change is designated as an administrative change and is acceptable because the change does not result in technical changes to the CTS.
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| A03 CTS 3.8.3.2 requires one train of A.C. emergency busses associated with the unit consisting of, in part, three 480-volt A.C. emergency busses load centers. The 480V load center requirement is modified by footnote
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| * which states, With the opposite unit in MODE 1, 2, 3, or 4, the 480-volt load centers can only be cross-tied upon issuance of an engineering evaluation to prevent exceeding required electrical components maximum design ratings and to ensure availability of the minimum required equipment. ITS LCO 3.8.10 requires the necessary portion of AC and DC electrical power distribution trains, and AC vital electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. This changes the CTS by not including the statement when 480V load centers can be cross-tied.
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| The purpose of the
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| * footnote associated with CTS 3.8.3.2 is to prevent exceeding required electrical components maximum design ratings and to ensure availability of the minimum required equipment if a 480V load center is cross-tied while the opposite unit is in MODE 1, 2, 3, or 4. This footnote is unnecessary since an engineering evaluation has already been performed to determine the acceptability of closing cross-tie breakers on 480V load centers during shutdown conditions considering the opposite unit is in MODE 1, 2, 3, or 4 and incorporated in plant operational procedures, as applicable. The evaluation determined the required electrical components maximum design ratings were not exceeded and the minimum required equipment continues to be available when required. This change is designated as an administrative change because the deleted requirement has already been accomplished and, thus, does not result in a technical change to the CTS.
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN trains and power distribution subsystems, Required Action A.1, which requires the associated supported equipment to be declared inoperable, is also added.
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| These changes are acceptable because the additions represent restrictions consistent with implicit assumptions for operation in shutdown conditions (required equipment receiving the necessary required power). This change is designated as more restrictive because it adds a new requirement to the CTS, where more buses may be required to be OPERABLE in ITS than in CTS.
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| M02 CTS 3.8.1.2 and CTS 3.8.3.2 are applicable in MODES 5 and 6. ITS 3.8.10 is applicable in MODES 5 and 6 and during movement of irradiated fuel assemblies and has an ACTIONS Note stating that LCO 3.0.3 is not applicable. This changes the CTS by adding the Applicability of "During movement of irradiated fuel assemblies," and adds a Note to the ACTIONS stating that LCO 3.0.3 is not applicable.
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| distribution trains and This change is acceptable because the proposed requirements are necessary to ensure the electrical power subsystems are OPERABLE to support equipment required to be OPERABLE during movement of irradiated fuel assemblies.
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| Movement of fuel normally occurs during MODES 5 and 6; however, it can also occur outside of containment in other plant MODES (MODES 1, 2, 3, and 4) or other conditions (i.e., reactor defueled). This addition to the applicability is needed to ensure the appropriate electrical distribution system requirements are specified during fuel handling and to ensure the appropriate actions are taken (i.e., stop fuel movement) when the minimum electrical supply is not available. In addition, this change adds a clarification Note stating that LCO 3.0.3 is not applicable because LCO 3.0.3 has no Required Actions that restore safety with respect to the movement of irradiated fuel. If moving irradiated fuel assemblies while in MODES 5 or 6, LCO 3.0.3 is not applicable because LCO 3.0.3 applicability is limited to MODES 1, 2, 3, and 4 only with a designated endpoint of MODE 5. In addition, if moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations and the inability to suspend movement in accordance with ITS 3.8.10 Required Actions would not be sufficient reason to require a reactor shutdown. This Note has been added for clarification and is necessary since defaulting to LCO 3.0.3 would require the reactor to be shut down, but would not require suspension of the activities with a potential for releasing radioactive materials. This change is designated as more restrictive because the ITS requires equipment to be OPERABLE during movement of irradiated fuel assemblies both inside and outside of the containment, not only when in MODES 5 and 6.
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| subsystems are M03 CTS 3.8.3.2 Action does not contain a Required Action to declare associated required residual heat removal subsystem(s) inoperable and not in operation.
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| or DC electrical power ITS 3.8.10, Required Action A.2.4, requires that when one or more required AC, distribution DC, or AC vital bus electrical power distribution buses inoperable to declare the trains associated required residual heat removal (RHR) subsystem(s) inoperable and not in operation unless the associated supported required feature(s) were declared inoperable. This changes the CTS by potentially requiring declaring the associated required residual heat removal subsystem(s) inoperable and not in operation when one or more required AC, DC, or AC vital bus electrical power distribution buses inoperable.
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| or DC electrical power subsystems are distribution trains Turkey Point Unit 3 and Unit 4 Page 2 of 6
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN This change is acceptable because notwithstanding performance of the other Required Actions, a required RHR subsystem may be inoperable. In this case, the other Required Actions do not adequately address the concerns relating to coolant circulation and heat removal and pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered. Therefore, Required Action A.2.4 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions. This change is designated as more restrictive because additional Required Actions may be taken in the ITS then are in the CTS.
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| RELOCATED SPECIFICATIONS None None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.2 requires AC electrical power sources to be OPERABLE, listing the sources and subsystems. CTS LCO 3.8.3.2 requires AC electrical buses to be OPERABLE, listing the buses. ITS LCO 3.8.10 requires necessary portions of the AC, DC, and AC vital electrical power distribution subsystems to be OPERABLE to support equipment required to be OPERABLE.
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| ITS Surveillance Requirement (SR) 3.8.10.1 requires the verification of correct breaker alignment and voltage to each required AC, DC, and vital AC electrical power distribution subsystem. The details of the buses are contained in the ITS Bases. This changes the CTS by removing the description of the minimum required buses from the CTS to the ITS Bases.
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| The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the electrical power distribution subsystems to be OPERABLE and requires the verification of correct breaker alignment and voltage to required AC and DC electrical power distribution subsystems. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.3.2 Applicability includes a footnote *** that states "CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding Limiting Condition for Operation 3.8.3.1." ITS 3.8.10 does not include this caution. This changes the CTS by moving the caution to review the operating units' Technical Specifications from the CTS to the ITS Bases.
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| Turkey Point Unit 3 and Unit 4 Page 3 of 6
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN The removal of this guidance for performing actions to review the operating units Technical Specifications from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirement to ensure all LCOs are met. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for ensuring Technical Specification requirements are reviewed are being removed from the Technical Specifications.
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| LESS RESTRICTIVE CHANGES L01 (Category 1 - Relaxation of LCO Requirements) CTS 3.8.3.2 states that as a minimum, the following electrical busses shall be energized in the specified manner with a specific manner of energization, then provides a list of buses with and DC a specific manner of energization listed for the 120 VAC vital buses and the electrical power 125 VDC buses. In addition, CTS 3.8.2.3 ACTION provides actions to perform if distribution trains the buses are not energized in the required manner: ITS 3.8.10 states that the necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE. This changes the CTS by specifying how the buses must be energized, stating that the buses must be OPERABLE, thus relying on the definition of OPERABLE/OPERABILITY to decide the manner of energization.
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| trains and subsystems The purpose of CTS 3.8.3.2 is to provide an LCO for the onsite power distribution system when shutdown. This change is acceptable because the LCO requirements continue to ensure that the systems are maintained consistent with the safety analyses and licensing basis. The ITS definition of OPERABLE states that a system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s). In addition, ITS LCO 3.8.5, "DC Source - Shutdown," and ITS LCO 3.8.8, "Inverters - Shutdown," provide requirements for the source of power to the DC buses and 120 VAC vital panels.
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| This change is designated as less restrictive because less stringent LCO requirements are being applied in the ITS than were applied in the CTS.
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| L02 (Category 3 - Relaxation of Completion Time) CTS 3.8.3.2 ACTION requires, in part, that with any of the above required electrical buses not energized in the required manner, the Reactor Coolant System (RCS) must be depressurized and vented within 8 hours through at least a 2.2 square inch vent. ISTS 3.8.8 does not include this Required Action. ITS LCO 3.4.12, "Overpressure Mitigation Turkey Point Unit 3 and Unit 4 Page 4 of 6
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN System," provides requirements for RCS pressure relief when in MODES 4, 5, or 6 to depressurize and establish an RCS vent of 2.2 square inches within 12 hours if the other pressure relief methods are incapable of limiting pressure.
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| This changes the CTS by relying on ITS LCO 3.4.12 to provide the Required Actions and allowing a longer Completion Time to depressurize the RCS and establish a 2.2 square inch RCS vent.
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| The purpose of CTS 3.8.3.2 Action is to provide remedial actions to be taken with any of the above required electrical buses not energized in the required manner while in MODE 5 or 6. One of these remedial actions is to depressurize and vent the RCS through at least a 2.2 square inch vent, which is being proposed for deletion. This change is acceptable because the CTS 3.8.3.2 ACTION to depressurize and vent the RCS is duplicative of the ITS LCO 3.4.12 Required Action to depressurize and vent the RCS. In addition, ITS 3.4.12 Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of an event occurring during the allowed Completion Time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
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| L03 (Category 4 - Relaxation of Required Action) CTS 3.8.3.2 ACTION states, in part, that that with any of the above required electrical busses not energized in the required manner, immediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, or movement of irradiated fuel.
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| ITS 3.8.10, Required Actions A.2.1 and A.2.2, provide Actions to be performed under similar conditions. These ITS Required Actions state to suspend movement of irradiated fuel assemblies and suspend operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN (SDM) or boron concentration. This changes the CTS Actions by deleting the requirement to suspend CORE ALTERATIONS and to clarify to only suspend positive reactivity additions when it could result in loss of required SDM or boron concentration.
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| The purpose of the CTS 3.8.3.2 ACTION is to minimize the possibility of an event that may need a required electrical bus to mitigate the consequences of the event. CORE ALTERATIONS is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel."
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| CORE ALTERATIONS only occur when the reactor vessel head is removed and only applies in MODE 6. There is only one accident considered during MODE 6 that involves CORE ALTERATIONS: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building.
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| Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, would not prevent or impair the mitigation of a fuel handling accident.
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| Turkey Point Unit 3 and Unit 4 Page 5 of 6
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| DISCUSSION OF CHANGES ITS 3.8.10, DISTRIBUTION SYSTEMS - SHUTDOWN CTS 3.8.3.2 ACTION also requires that with less than the above minimum required electrical busses, immediately suspend all operations involving positive reactivity changes while ITS 3.8.10, Required Action A.2.2, requires only suspending operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. This change is acceptable because it allows for positive reactivity additions that do not result in loss of required SDM or boron concentration (e.g., water addition or temperature change) assuring continued safe operation.
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| This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 6 of 6
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| CTS Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown and DC electrical power distribution trains 3.8.1.2, LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power 3.8.3.2 DOC M01 distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.
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| Applicability APPLICABILITY: MODES 5 and 6, DOC M02 During movement of [recently] irradiated fuel assemblies. 1 ACTIONS
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| ------------------------------------------------------------NOTE-----------------------------------------------------------
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| DOC M02 LCO 3.0.3 is not applicable.
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| or DC electrical power distribution trains CONDITION REQUIRED ACTION COMPLETION TIME Action A. One or more required A.1 Declare associated Immediately DOC M01 AC, DC, or AC vital bus supported required electrical power feature(s) inoperable.
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| distribution subsystems 2 inoperable. buses OR A.2.1 Suspend movement of Immediately subsystems [recently] irradiated fuel 1 assemblies.
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| DOC L03 AND A.2.2 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.
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| AND Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.10-1 Rev. 5.0 2
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| CTS Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)
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| CONDITION REQUIRED ACTION COMPLETION TIME and DC electrical power distribution trains A.2.3 Initiate actions to restore Immediately required AC, DC, and AC vital bus electrical power distribution subsystems to 2 OPERABLE status. buses subsystems AND A.2.4 Declare associated Immediately required residual heat DOC M03 removal subsystem(s) inoperable and not in operation.
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| SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY and DC electrical power distribution trains 4.8.2.3 SR 3.8.10.1 Verify correct breaker alignments and voltage to [ 7 days required AC, DC, and AC vital bus electrical power 1 distribution subsystems. OR 2 buses subsystems In accordance with the Surveillance Frequency Control Program ] 1 Turkey Point Unit 3 and Unit 4 Amendment Nos. XXX and YYY Westinghouse STS 3.8.10-2 Rev. 5.0 2
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| Distribution Systems - Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems -
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| Operating."
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| APPLICABLE The initial conditions of Design Basis Accident and transient analyses in 14 SAFETY U the FSAR, Chapter [6] (Ref. 1) and Chapter [15] (Ref. 2), assume 2 1 ANALYSES Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.
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| The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY. and DC electrical power 2
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| distribution trains The OPERABILITY of the minimum AC, DC, and AC vital bus electrical power distribution subsystems during MODES 5 and 6, and during movement of [recently] irradiated fuel assemblies ensures that: 1
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| : a. The unit can be maintained in the shutdown or refueling condition for extended periods,
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| : b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and
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| : c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident [involving handling recently irradiated fuel. Due to radioactive decay, AC and DC electrical power is only required to mitigate fuel handling accidents 1 involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].
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| The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.10-1 Rev. 5.0 2
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| Distribution Systems - Shutdown B 3.8.10 BASES trains, 2 LCO Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of required systems, equipment, and components - all specifically addressed in each LCO and implicitly required via the definition of OPERABILITY.
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| INSERT 1 2 Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,
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| INSERT 2 fuel handling accidents [involving handling recently irradiated fuel]). 1 2
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| trains and APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, and during movement of [recently] 1 irradiated fuel assemblies, provide assurance that:
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| : a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core,
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| : b. Systems needed to mitigate a fuel handling accident [involving handling recently irradiated fuel (i.e., fuel that has occupied part of a 1 critical reactor core within the previous [X] days)] are available,
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| : c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and
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| : d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition. and DC electrical power 2 distribution trains The AC, DC, and AC vital bus electrical power distribution subsystems requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9. INSERT 3 2 ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.
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| Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.10-2 Rev. 5.0 2
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| 2 INSERT 1 As a minimum, the following electrical buses shall be energized:
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| : a. One train of AC emergency buses associated with the unit consisting of one 4.16 kV and three 480 VAC emergency buses load centers* and three (four for Unit 4 Train A) vital sections of motor control center busses (The Vital sections of the MCCs shown in Table B 3.8.10-1 must be energized to satisfy this requirement),
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| : b. Two 120 VAC vital buses for the unit, and
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| : c. Three 125 VDC buses.
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| * With the opposite unit in MODE 1, 2, 3, or 4, the 480 V load centers can only be cross tied upon issuance of an engineering evaluation to prevent exceeding required electrical components maximum design ratings and to ensure availability of the minimum required equipment.
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| 2 INSERT 2 Table B 3.8.10-1 Train in Service(a)
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| Reason 3A 3B 4A 4B 3A 3B 4A 4B Major Safety MCCs 3C 4C Major Safety MCCs MCCs 3D 3D 4D 4D CR HVAC 3K 4J 4K EDG Auxiliaries (a) MCCs 3K, 4J, and 4K were added during the EPS Upgrade Project. Auxiliaries for the 3A EDG were left on the 3A MCC. As a result, only Unit 4 Train A needs four MCC vital sections energized.
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| 2 INSERT 3 If the opposite unit is in MODES 1, 2, 3, or 4, see the corresponding LCO 3.8.9.
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| Insert Page B 3.8.10-2
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| Distribution Systems - Shutdown B 3.8.10 BASES ACTIONS (continued)
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| The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.
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| and DC electrical power SURVEILLANCE SR 3.8.10.1 distribution trains 2 REQUIREMENTS This Surveillance verifies that the AC, DC, and AC vital bus electrical required power distribution subsystems are functioning properly, with all the buses energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses.
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| [ The 7 day Frequency takes into account the capability of the electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions. 1 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
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| -----------------------------------REVIEWERS NOTE-----------------------------------
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| Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 3 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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| ------------------------------------------------------------------------------------------------ ]
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| U REFERENCES 1. FSAR, Chapter [6]. 2 1 U 14
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| : 2. FSAR, Chapter [15]. 2 1 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.10-4 Rev. 5.0 2
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| 7/14/22, 3:29 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1570 NRC Question KAB053 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 7/14/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 7/14/2022 1:32 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1570 1/1
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| 6/8/22, 3:18 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 783 NRC Question KAB054 Number Category Editorial ITS 3.8 Section ITS 3.8.1 Number DOC LA-4 Number JFD Number JFD Bases Number Page 27 of 422 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC ITS 3.8.1 DOC LA04 states, "ITS 3.8.1, Required Action C.3.2, states to determine OPERABLE EDG(s) is Question not inoperable due to common cause failure." This reference appears to be incorrect. In Revision 1 of the ITS, Required Action C.3.1 requires the operators to determine that the OPERABLE EDG(s) are not inoperable due to common cause failure. C.3.2 requires the performance of SR 3.8.1.6 as an alternative option to C.3.1. Please revise LA04 to cite C.3.1 or explain why the refeerence to C.3.2 is correct.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/8/2022 Added By Robert Elliot Date Modified Modified By Date 6/8/2022 2:05 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=783 1/1
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| 8/11/22, 10:28 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1207 NRC Question KAB054 Number Select Licensee Response Application Attachment Attachment 1 - KAB054 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response FPL will revise ITS 3.8.1, Discussion of Change (DOC) LA04, to reference Required Action C.3.1 in lieu of Statement C.3.2 with respect to the determination of common cause failure. See attached KAB054 license amendment request (LAR) markup.
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| Attachment
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| : 1. KAB054 LAR Markups
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| ===Response===
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| 6/17/2022 1:25 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 6/17/2022 12:22 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1207 1/1
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| DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES - OPERATING public health and safety. The ITS retains the requirement for OPERABLE EDGs.
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| Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because information relating to system design is being removed from the Technical Specifications.
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| LA03 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 3.8.1.1.b requires three separate and independent diesel generators to be OPERABLE and includes specific supporting requirements.
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| CTS 3.8.1.1.b.1.f and 3.8.1.1.b.2.d require specific motor control center (MCC) buses to be energized for specific EDGs. ITS LCO 3.8.1 does not include a discussion regarding MCCs energized for specific EDGs. This changes the CTS by moving the design details regarding MCCs for specific EDGs from the CTS to the Bases.
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| The purpose of the CTS requirement is to ensure power is supplied to the MCCs associated with the EDGs auxiliaries. The removal of these details related to system design from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the requirement for OPERABLE EDGs. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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| LA04 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.1, ACTION b.2 and ACTION c.2, state, in part, that if the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, to demonstrate the OPERABILITY of the remaining required EDGs by performing SR 4.8.1.1.2.a.4 within 24 hours. In addition, CTS 3.8.1, ACTION c.2, states, in part, to demonstrate the OPERABILITY of the remaining required EDGs by performing SR 4.8.1.1.2.a.4 C.3.1 within 8 hours unless the EDGs are already operating. ITS 3.8.1, Required Action C.3.2, states to determine OPERABLE EDG(s) is not inoperable due to common cause failure. This changes the CTS by removing the details of what is not a potential common mode failure.
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| The removal of these details for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirement to ensure the absence of any potential common mode failure for the remaining EDGs is determined.
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| Also, this change is acceptable because these types of procedural details will be Turkey Point Unit 3 and Unit 4 Page 11 of 27
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| 7/1/22, 10:00 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1391 NRC Question KAB054 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/30/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/30/2022 4:17 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1391 1/1
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| 6/14/22, 10:30 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 787 NRC Question KAB055 Number Category Technical ITS 3.8 Section ITS 3.8.1 Number DOC A-5 Number JFD Number JFD Bases Number Page 19 of 422 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC In Revision 1 of the ITS Section 3.8 markups, PTN deleted several notes from the CTS that indicated that Question the Required Actions applied to both units simultaneously due to the systems being shared between units. The justification for deleting these notes is that they are redundant to 3.0.10, which states, "Whenever the LCO refers to systems or components which are shared by both units, the Conditions and Required Actions will apply to both units simultaneously." 10CFR50.36 states that Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications. While the Required Action notes are redundant to LCO 3.0.10, shared systems and components are part of the bases or reasons for the technical specifications and should be included as relevant information in the ITS Bases. The STS and the STS Bases do not include notes for shared systems because they are written for a single unit. Therefore, when modifying the STS bases to reflect plant specific information (ITS Bases), licensees should include relevant information about shared systems and components. Accordingly, please update the Bases for all Section 3.8 LCOs where these notes are proposed to be deleted to state what systems or components covered by the LCO are shared between Units 3 and 4.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/14/2022 Added By Robert Elliot Date Modified Modified By Date 6/13/2022 11:26 PM https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=787 1/2
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| 6/14/22, 10:30 AM Turkey Point ITS Conversion Database Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=787 2/2
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| 8/14/22, 10:36 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1299 NRC Question KAB055 Number Select Licensee Response Application Attachment Attachment 1 - KAB055 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response The Background and LCO sections of the Bases associated with the ITS Section 3.8 Specifications provide a Statement summary description of the Turkey Point (PTN) Class 1E Electrical Power System and includes, where applicable, a description of specific shared electrical power and distribution trains, subsystems, and components required for each unit to meet the associated Limiting Conditions for Operation. To further clarify the shared relationship between PTN Unit 3 and Unit 4 Class 1E Electrical Power System, FPL will add a sentence regarding shared systems to the Bases of ITS 3.8.1, "AC Sources - Operating," ITS 3.8.4, "DC Sources - Operating," and ITS 3.8.9, "Distribution Systems - Operating." The Background section of the Bases associated with ITS 3.8.2, "AC Sources - Shutdown," ITS 3.8.5, "DC Sources - Shutdown," and ITS 3.8.10, "Distribution Systems - Shutdown," point to Bases of ITS Specifications 3.8.1, 3.8.4, and 3.8.9, respectively. Therefore, no changes are made to these Bases. See attached KAB055 license amendment request (LAR) markup.
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| Attachment
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| : 1. KAB055 LAR Markups
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| ===Response===
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| 6/27/2022 10:35 AM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 6/27/2022 9:35 AM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1299 1/1
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| B 3.8.1 1
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| Offsite circuits and INSERT 1 EDGs are shared between the units.
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| Turkey Point Units 3 and 4 were designed prior to the implementation of 10 CFR 50, Appendix A, General Design Criteria (GDC) for Nuclear Power Plants, and utilized the criteria of 1967 AEC proposed GDC 39, "Emergency Power for Engineered Safety Features," in the design of the site electric power systems.
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| The normal power source to the Class 1E AC Electrical Power Distribution System is the respective unit auxiliary transformers and associated circuits to the Train A and B 4.16 kV buses. The preferred offsite power source is the unit startup transformer and associated circuit to the Train A and B 4.16 kV buses. One offsite circuit for each unit is supplied via the unit's start-up transformer. The alternate offsite circuit (i.e., delayed circuit) is supplied by the adjacent unit's start-up transformer to the Train A 4.16 kV bus. Manual operator action is required to align the adjacent units startup transformer to the Train A 4.16 kV bus. Each start-up transformer is connected by separate, independent highlines to separate buses in the switchyard. Each transformer is connected to the unit's Class 1E AC Electrical Power Distribution System via separate cables and breakers. No single failure can affect both circuits simultaneously or consequentially such that both circuits are lost. Each startup transformer has the capability to supply backup power of approximately 2500 kW (equivalent to the lowest EDG continuous rating) to the opposite unit's Train A 4.16 kV bus while simultaneously providing power to the units Train B 4.16 kV bus.
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| 1 INSERT 2 Two EDGs provide onsite emergency AC power for each unit. EDGs 3A and 3B provide Unit 3 A train, and B train emergency power, respectively. EDGs 4A and 4B provide Unit 4 A train and B train emergency power, respectively.
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| 1 INSERT 3 High Differential Pressure Between the Steam Line Header and any Steam Line, or Steam Line flowHigh Coincident with: Steam Generator PressureLow or Tavg--Low Insert Page B 3.8.1-1
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| B 3.8.4 1
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| The DC electrical INSERT 1 power sources are shared between the units.
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| The DC electrical power system contains five safety related 125V batteries and associated battery chargers. Two battery banks (Train A and Train B) are associated with each unit, one 1800 ampere-hour (AH) and one 1200 AH, and a spare 1945 AH battery bank that can be substituted, to allow for testing or maintenance, for any of the other four battery banks. Each 1800 AH battery bank has two safety related full capacity 400 ampere solid-state battery chargers associated with it; a normal and an alternate charger. Each 1200 AH battery bank has two safety related full capacity 300 ampere solid-state battery chargers associated with it; a normal and an alternate charger. The spare battery bank is normally isolated from the vital DC buses and maintained in a fully charged condition by a non-safety related battery charger. Each battery has been sized to support operation of its required loads for 2 hours without terminal voltage falling below its minimum required value.
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| Each normal battery charger is powered by a vital motor control center (MCC) of the same train and unit of its associated battery. The alternate battery chargers for both battery banks are powered by the vital swing MCC of the opposite unit. Unit 3 DC battery chargers 3A2 and 3B2 are powered from Unit 4 via swing MCC 4D, and Unit 4 DC battery chargers 4A2 and 4B2 are powered from Unit 3 via swing MCC 3D.
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| Insert Page B 3.8.4-1
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| ITS ITS 3.8.7 A01 ONSITE POWER DISTRIBUTION LIMITING CONDITION FOR OPERATION (Continued)
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| ACTION: (Continued)
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| ACTION A within 24 hours or in accordance with the Risk Informed Completion Time Program, or be in at ACTION B least HOT STANDBY within the next 12 hours and in COLD SHUTDOWN within the following 30 hours. This ACTION applies to both units simultaneously. MODE 4 18 See ITS Add proposed Required Action B.2 Note L01 3.8.9
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| : d. With one D.C. bus not energized from its associated battery bank or associated charger, reenergize the D.C. bus from its associated battery bank within 2 hours* or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours and in COLD SHUTDOWN within the following 30 hours. This ACTION applies to both units simultaneously.
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| See ITS SURVEILLANCE REQUIREMENTS 3.8.9 SR 3.8.7.1 4.8.3.1 The specified busses shall be determined energized and aligned in the required manner by verifying correct breaker alignment and indicated voltage on the buses in accordance with the Surveillance Frequency Control Program.
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| * Can be extended to 24 hours if the opposite unit is in MODE 5, 6, or defueled and each of the remaining See ITS required battery chargers is capable of being powered from its associated diesel generator(s). 3.8.9 TURKEY POINT - UNITS 3 & 4 3/4 8-20 AMENDMENT NOS. 289 AND 283 Page 3 of 3
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| Distribution Systems - Operating B 3.8.9 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.9 Distribution Systems - Operating BASES BACKGROUND The onsite Class 1E AC, DC, and AC vital bus electrical power 1distribution systems are divided by train into [two] redundant and independent AC, DC, and AC vital bus electrical power distribution buses and panels subsystems. Specific electrical distribution subsystems are 2 INSERT 1 shared between the units to support required loads.
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| The AC electrical power subsystem for each train consists of a primary Engineered Safety Feature (ESF) 4.16 kV bus and secondary [480 and 120] V buses, distribution panels, motor control centers and load centers.
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| Each [4.16 kV ESF bus] has at least [one separate and independent offsite source of power] as well as a dedicated onsite diesel generator (DG) source. Each [4.16 kV ESF bus] is normally connected to a preferred offsite source. After a loss of the preferred offsite power source to a 4.16 kV ESF bus, a transfer to the alternate offsite source is accomplished by utilizing a time delayed bus undervoltage relay. If all offsite sources are unavailable, the onsite emergency DG supplies power to the 4.16 kV ESF bus. Control power for the 4.16 kV breakers is supplied from the Class 1E batteries. Additional description of this system may be found in the Bases for LCO 3.8.1, "AC Sources -
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| Operating," and the Bases for LCO 3.8.4, "DC Sources - Operating."
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| 1 The secondary AC electrical power distribution subsystem for each train includes the safety related buses, load centers, motor control centers, and distribution panels shown in Table B 3.8.9-1.
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| The 120 VAC vital buses are arranged in two load groups per train and are normally powered from the inverters. The alternate power supply for the vital buses are Class 1E constant voltage source transformers powered from the same train as the associated inverter, and its use is governed by LCO 3.8.7, "Inverters - Operating." Each constant voltage source transformer is powered from a Class 1E AC bus.
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| The DC electrical power distribution subsystem consists of [125] V bus(es) and distribution panel(s).
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| The list of all required DC and vital AC distribution buses [and panels] is 2 1
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| presented in Table B 3.8.9-1.
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| for Unit 3 and Table B 3.8.9-2 for Unit 4 Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.9-1 Rev. 5.0 1
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| 6/30/22, 10:54 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1371 NRC Question KAB055 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/30/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/30/2022 9:51 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1371 1/1
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| 6/14/22, 10:31 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 791 NRC Question KAB056 Number Category Technical ITS 3.8 Section ITS 3.8.2 Number DOC Number JFD Number JFD Bases Number Page 159 of 422 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC CTS 3.8.1.2 has an applicability footnote
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| * that states, If the opposite unit is in MODES 1. 2. 3, or 4 see Question Specification 3.8.1.1. PTN has proposed to move the footnote to the Bases of ITS 3.8.2. However, the relocated footnote in the Bases markup references the CTS LCO instead of the ITS LCO. Please revise the Applicability Bases to reference ITS LCO 3.8.1 or explain why the reference to 3.8.1.1 is appropriate Attach File 1
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| Attach File 2
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| Issue Date 6/14/2022 Added By Robert Elliot Date Modified Modified By Date 6/13/2022 11:57 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=791 1/1
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| 8/14/22, 10:36 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1199 NRC Question KAB056 Number Select Licensee Response Application Attachment Attachment 1 - KAB056 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response FPL will revise the Applicability section of ITS 3.8.2 Bases to refer to LCO 3.8.1 in lieu of CTS Specification Statement 3.8.1.1. See attached KAB056 license amendment request (LAR) markup.
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| Attachment
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| : 1. KAB056 LAR Markups
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| ===Response===
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| 6/16/2022 4:20 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date Added 6/16/2022 3:20 PM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1199 1/1
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| AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY (continued)
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| : d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition. MODES 1, 2, 3, or 4, requirements for the opposite unit are provided in LCO 3.8.1 The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1. If the opposite unit is in MODES 1. 2. 3, or 4 see Specification 3.8.1.1. 1 ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.
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| A.1 An offsite circuit would be considered inoperable if it were not available to one required ESF train. Although two trains are required by LCO 3.8.10, the one train with offsite power available may be capable of supporting sufficient required features to allow continuation of [recently] irradiated 2 fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.
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| A.2.1, A.2.2, A.2.3, B.1, B.2, and B.3 With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently EDG conservative actions is made. With the required DG inoperable, the 1 minimum required diversity of AC power sources is not available. It is, therefore, required to suspend movement of [recently] irradiated fuel 2 assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron Turkey Point Unit 3 and Unit 4 Revision XXX Westinghouse STS B 3.8.2-4 Rev. 5.0 1
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| 6/30/22, 11:36 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1375 NRC Question KAB056 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/30/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/30/2022 10:34 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1375 1/1
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| 6/14/22, 10:31 AM Turkey Point ITS Conversion Database ITS NRC Questions Id 795 NRC Question KAB057 Number Category Technical ITS 3.8 Section ITS 3.8.2 Number DOC L-5 Number JFD Number JFD Bases Number Page 146 of 422 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC By {{letter dated|date=December 21, 2021|text=letter dated December 21, 2021}}, the NRC requested PTN to supplement their technical specification Question conversion license amendment request (ADAMS Accession ML21342A293). The letter provided specific information to be provided in the supplement. In the letter, the NRC provided the following request, ITS 3.8.1 - page 140 - On CTS page 3/4 8-11, it is proposed that operations involving CORE ALTERATIONS be deleted from the CTS 3.8.1.2 Action statement. However, the proposed change does not have a discussion of change associated with it. In STS this Required Action was deleted under TSTF-471. In order to delete CORE ALTERATIONS from CTS, provide a description of the limitations and controls that would prevent movement of any unirradiated fuel assembly, source, reactivity control component, or other component affecting reactivity within the reactor vessel capable of damaging an irradiated fuel assembly prior to the 72 hour decay time assumed in the Fuel Handling Accident (FHA) analysis or information demonstrating that the dropping of any unirradiated fuel assembly, sources, reactivity control component, or other component affecting reactivity within the reactor vessel onto irradiated fuel assemblies prior to the 72 hour decay time assumed in the FHA will not result in a radioactive release from the irradiated fuel. The licensee provided the requested DOC in Revision 1 of their amendment request; however, it is not completely responsive to the staffs request. The DOC appears to pre-date more complete responses provided to RAIs KAB-011, KAB-034 and KAB052. Please revise DOC L05 to be consistent with PTNs responses to these RAIs.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/14/2022 Added By Robert Elliot Date Modified Modified By Date 6/14/2022 12:02 AM https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=795 1/2
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| 6/14/22, 10:31 AM Turkey Point ITS Conversion Database Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=795 2/2
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| 8/14/22, 10:36 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1203 NRC Question KAB057 Number Select Licensee Response Application Attachment Attachment 1 - KAB057 LAR Markups.pdf (1MB) 1 Attachment 2
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| Response FPL will revise ITS 3.8.2, Discussion of Change (DOC) L05, to include discussion of the potential for an FHA Statement prior to the 72-hour decay time assumed in the analysis. See attached KAB057 license amendment request (LAR) markup.
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| Attachment
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| : 1. KAB057 LAR Markups
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| ===Response===
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| 6/16/2022 4:25 PM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 6/16/2022 3:22 PM Added Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1203 1/1
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| DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN SR 3.8.1.7), manual transfer of AC power sources, CTS 4.8.1.1.2g.5 (ITS SR 3.8.1.11), the ESF actuation signal EDG start test, CTS 4.8.1.1.2g.10 (ITS SR 3.8.1.16), ESF actuation signal overrides the test mode, CTS 4.8.1.1.2g.a and b (ITS SR 3.8.1.18), ESF concurrent with loss of offsite power signal test, and CTS 4.8.1.1.2h (ITS SR 3.8.1.19) the simultaneous EDG start test. ITS SR 3.8.1.11 and ITS SR 3.8.1.17 are not required to be met because the ESF signal is not required to be OPERABLE in the MODE 5 or 6. The CTS and ITS also do not require the Emergency Core Cooling System (ECCS) subsystem(s) to be OPERABLE in MODE 5 and 6. The EDGs are required to support the equipment powered from the 4160 V buses. However, when the ECCS subsystem(s) are not required to be OPERABLE, then there is no reason to require the EDG to auto-start on an ESF actuation signal. In addition, the ESF actuation signal is only an anticipatory start signal; the EDGs are only needed during a Design Basis Accident (DBA) if a loss of offsite power occurs concurrently. The EDGs are also required to start if a loss of offsite power occurs. The requirement to auto-start the required EDG(s) on a loss of offsite power signal is being maintained in the ITS (ITS SR 3.8.1.10). Thus, under these conditions (associated ECCS subsystem(s) not required to be OPERABLE), there is no reason to require the EDGs to be capable of automatically starting on an ESF actuation signal (either by itself or concurrent with a loss of offsite power signal). This change is designated as less restrictive because Surveillances that are required in CTS will not be required in the ITS.
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| L05 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 ACTION specifies the compensatory action for an inoperable required AC Source while in MODES 5 and 6. One of the compensatory actions is the suspension of CORE ALTERATIONS. Under similar conditions, ITS 3.8.2 does not require suspension of CORE ALTERATIONS. This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when a required AC source is inoperable.
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| The purpose of the CTS 3.8.1.2 ACTION to suspend CORE ALTERATIONS is to minimize the possibility of an event that may need the AC source to mitigate the consequences of the event. CORE ALTERATION is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed - it only applies in MODE 6. There is only one accident considered during MODE 6 that involves a CORE ALTERATION: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is Additionally, CORE ALTERATIONS that may be initiated by the dropping of an irradiated fuel assembly, either in the containment capable of damaging a fuel or in the fuel building. Suspension of CORE ALTERATIONS, except for assembly prior to the 72- suspension of movement of irradiated fuel, will not prevent or impair the hour decay period is improbable because the mitigation of a fuel handling accident. ITS 3.8.2 retains the requirement to physical time required to suspend movement of irradiated fuel assemblies in ITS 3.8.2 Required Action perform plant shutdown, A.2.1 (for an inoperable required offsite circuit) and Required Action B.1 (for one cooldown, depressurize the Reactor Coolant System, or more inoperable required EDG(s)). Therefore, because the only CORE and the additional operations ALTERATION analyzed in the safety analysis and potentially affected by a loss required to expose the of an AC source is covered by the ITS Required Actions, deletion of the term irradiated fuel (e.g.,
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| containment entry, removal "CORE ALTERATIONS" is acceptable. This change is designated as less of vessel head, removal of vessel internals, etc.) is greater than 72 hours.
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| Turkey Point Unit 3 and Unit 4 Page 6 of 7
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| DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES - SHUTDOWN restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
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| Turkey Point Unit 3 and Unit 4 Page 7 of 7
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| 6/30/22, 11:40 AM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1379 NRC Question KAB057 Number Select NRC Question Closure Application Attachment 1 Attachment 2
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| ===Response===
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| Statement
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| ===Response===
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| Date/Time Closure This question is closed pending revision of the LAR as noted in licensee's response and no further Statement information is required at this time to draft the Safety Evaluation.
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| Question 6/30/2022 Closure Date Notification Gregg Ellis Christina Long Added By Robert Elliot Date Added 6/30/2022 10:40 AM Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1379 1/1
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| 6/15/22, 1:24 PM Turkey Point ITS Conversion Database ITS NRC Questions Id 799 NRC Question KAB058 Number Category Technical ITS 3.8 Section ITS 3.8.1 Number DOC Docs K09, A07 and A10 Number JFD Number JFD Bases Number Page 20, 21 and 36 of 422 Number(s)
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| NRC Reviewer Victor Cusumano Supervisor Technical Branch Add Name POC Conf Call N
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| Requested NRC CTS 3.8.1.1, DOCs L09, A07 and A10 justify changes to the ITS that are not in the CTS or the STS and are, Question therefore, beyond scope. Specifically, the following revisions and their associated DOCs are beyond scope:
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| : 1) CTS Action e is modified to allow three offsite circuits to be inoperable instead of the current action for two offsite circuits (DOC A10),
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| : 2) A new Condition G and associated Required Action is added to the ITS LCO 3.8.1 which allows One or more unit EDGs inoperable AND One or more required opposite unit EDGs inoperable. (DOC L09),
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| and
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| : 3) STS Condition H is modified in ITS Condition K to require entry into LCO 3.0.3 when PTN has 4 or more inoperable AC sources versus the STS and CTS requirement of 3 inoperable AC sources. (DOC A07)
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| Neither the CTS or the STS have any of these Conditions and associated Required Actions. The net effect of the combination of these changes is to prevent entry into LCO 3.0.3 when 3 AC sources are inoperable and to allow continued operation with 3 EDGs inoperable. LCO 3.0.3 is entered when an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS. Entry into LCO 3.0.3 is appropriate for 3 AC sources inoperable since neither the CTS or the STS provide an associated action for this situation. The technical basis for the STS requirement to enter LCO 3.0.3 with 3 inoperable AC sources is that a severe degradation of redundancy has been lost and any further losses in the AC power system will cause a loss of safety function. Please modify 3.8.1 to conform with either the CTS or the STS.
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| Attach File 1
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| Attach File 2
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| Issue Date 6/15/2022 Added By Robert Elliot Date Modified Modified https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=799 1/2
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| 6/15/22, 1:24 PM Turkey Point ITS Conversion Database By Date 6/15/2022 12:22 PM Added Notification Gregg Ellis Christina Long https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26215&itemId=799 2/2
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| 8/3/22, 5:17 PM Turkey Point ITS Conversion Database Licensee Response/NRC Response/NRC Question Closure Id 1594 NRC Question KAB058 Number Select Licensee Response Application Attachment Attachment 1 KAB058 LAR Markup.pdf (1MB) 1 Attachment 2
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| Response As indicated in ITS 3.8.1 Discussion of Change (DOC) A10, CTS 3.8.1.1 Action e is equivalent to ITS 3.8.1 Statement ACTION D and therefore, not considered beyond the scope of CTS. The more precise characterization of the alternate unit offsite circuit and the opposite unit offsite circuit instead of a single opposite unit startup transformer and associated circuits results in a total of three required offsite circuits: two unit offsite circuits and one required opposite unit offsite circuit. This characterization ensures appropriate Technical Specification actions are performed for various offsite circuit inoperabilities commensurate with the level of degradation of the circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System. As a result, ITS 3.8.1 Condition D stating, Three offsite circuits inoperable, is equivalent to the condition of two inoperable startup transformers or their associated circuits (i.e., two unit circuits and one opposite unit circuit) specified in CTS 3.8.1.1 Action e. ITS 3.8.1 DOC A10 will be revised to include additional clarity that the condition of three offsite circuits inoperable in ITS is equivalent to the CTS condition of two startup transformers or associated circuits inoperable. Refer to KAB058 LAR Markup.
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| Following several conversations with the NRC staff regarding the proposed ITS 3.8.1 ACTIONS and the unique design of the Turkey Point Unit 3 and Unit 4 (PTN) Class 1E Electrical Power System design with regard to the Improved Standard Technical Specifications (ISTS), FPL will revise the proposed ITS 3.8.1 ACTIONS as follows to resolve the beyond scope conditions:
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| ACTION F will be revised to restore all but one required emergency diesel generator (EDG) to OPERABLE status within 2 hours when two or more required EDGs are inoperable.
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| ACTION G will be deleted and ACTIONS H, I, J, and K will be relabeled and Conditions I and J will be revised to reflect this change.
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| Condition K (revised as Condition J) will be revised to state: One or more required offsite circuits inoperable and two or more required EDGs inoperable OR One or more required EDGs inoperable and two or more required offsite circuits inoperable.
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| Additionally, ITS 3.8.1 DOC L09 and A07 and Justification for Deviation (JFD) 7 will be revised to reflect the changes to the ITS 3.8.1 ACTIONS and consequent changes made to the CTS markups, DOCs, ITS markups, and ITS Bases markups. Refer to KAB058 LAR Markup.
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| Attachments:
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| : 1. KAB058 LAR Markup
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| ===Response===
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| 7/15/2022 11:45 AM Date/Time Closure Statement Question Closure Date Notification Kristy Bucholtz Gregg Ellis Christina Long Michael Mahoney Caroline Tilton Added By Christina Long Date 7/15/2022 10:44 AM Added https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1594 1/2
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| 8/3/22, 5:17 PM Turkey Point ITS Conversion Database Date Modified Modified By https://taktix.certrec.com/5735/index.php?requestType=areaItemPrint&areaId=26219&itemId=1594 2/2
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| ITS A01 ITS 3.8.1 ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)
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| Applicability APPLICABILITY: MODES 1, 2, 3, and 4.
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| ACTION: unit or one required opposite unit A10 Actions Note NOTE: LCO 3.0.4.b is not applicable to diesel generators.
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| offsite LA01 Action A a. With one of two startup transformers or an associated circuit inoperable:
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| Action B Required Action (RA) A.1 1. Demonstrate the OPERABILITY of the other startup transformer and its associated RA B.1 circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour and at least once per 8 hours thereafter.
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| RA A.2 2. Within 24 hours from discovery of no offsite power to one train concurrent with RA B.2 inoperability of redundant required feature(s), declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.
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| unit offsite circuit LA01 Action A 3. If the inoperable startup transformer is the associated startup transformer and became Action B inoperable while the unit is in Mode 1:
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| M01 a) Reduce THERMAL POWER to 30% RATED THERMAL POWER within 24 hours, or unit offsite LA01 RA A.3 b) Restore t}}
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