ML14212A520

Request for Extension of Enforcement Discretion Regarding Technical Specification 3/4.7.4, Ultimate Heat Sink

ML14212A520
Person / Time
Site:	Turkey Point
Issue date:	07/29/2014
From:	Kiley M W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-254
Download: ML14212A520 (3)

Text

0 FPL-L-2014-254 July 29, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating License Nos. DPR-31 and DPR-41

Subject:

Request for Extension of Enforcement Discretion Regarding Technical Specification 3/4.7.4, Ultimate Heat Sink

Reference:

1) Florida Power & Light Company (FPL) Letter L-2014-23 1, "Request for Enforcement Discretion Regarding Technical Specification 3/4.7.4, Ultimate Heat Sink," dated July 21, 2014.2) NRC Letter, "Notice of Enforcement Discretion (NOED) for Florida Power and Light Company Regarding Turkey Point Nuclear Generating Station Units 3 and 4 [NOED No. 14-2-001 ], dated July 23, 2014.3) Florida Power & Light Company (FPL) Letter L-2014-249, Request for Revision of Enforcement Discretion Regarding Technical Specification 3/4.7.4, Ultimate Heat Sink, dated July 25, 2014.4) Florida Power & Light Company (FPL) Letter L-2014-216, "License Amendment Request No. 231, Application to Revise Technical Specification to Revise Ultimate Heat Sink Temperature Limit, dated July 10, 2014.5) Florida Power & Light Company (FPL) Letter L-2014-226, "License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit -Request for Emergency Approval," dated July 17, 2014.By letter dated July 21, 2014 (Reference 1), FPL requested that the NRC exercise discretion from enforcing compliance with TS 3.7.4 "Ultimate Heat Sink." By letter dated July 23, 2014 (Reference 2), NRC issued the Notice of Enforcement Discretion (NOED) consistent with the NRC Enforcement Policy and NRC staff guidance concluding that the request had no adverse impact on public health and safety or the environment.

By letter dated July 25, 2014 (Reference 3), FPL requested revision to the 10 day condition of the NOED. This letter (L-2014-254) supersedes FPL letter L-2014-249, dated July 25, 2014 (Reference 3).

Florida Power & Light Company Page 2 of 3 Request for Extension of Notice of Enforcement Discretion The purpose of this letter is to request an extension for the approved NOED dated July 23, 2014 (Reference

2) from 6:00 PM July 30, 2014, to 6:00 PM August 9, 2014. The ultimate heat sink (UHS) temperatures have continued to cycle near or above the Technical Specification (TS) limit of I 00°F and are anticipated to stay high during the requested extension period. The extension period of ten days is within the timeframe associated with NRC review of FPL's emergency License Amendment Request (LAR) that would permanently revise the UHS temperature limit (References 4 and 5).The original risk assessment for the existing NOED supports the proposed extension of ten days.During the period of the enforcement discretion for the original NOED, the quantitative assessment of risk was conducted based on exceeding the TS temperature limit for a period of 10 days, which represents a cumulative total of 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> over 1 00'F. This assessment assumed an increased frequency of a loss of Intake Cooling Water (ICW) of 100 times the baseline frequency.

FPL has evaluated the increased temperatures and determined that the existing plant design supports the increased temperatures.

Therefore, the increased risk evaluation is a bounding number. Under the request for NOED extension, the results of the risk assessment remain valid, provided that the canal temperature does not exceed 1 00°F for a total of 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br />.Under the existing NOED, the 100'F TS limit has been exceeded for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> which yields substantial margin to 240 hrs. The 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> could only be exceeded if the canal temperature exceeds I 00 0 F for a duration of greater than 9 continuous days, which is unlikely based on recent experience.

Therefore, the request for a NOED extension is supported by the existing risk assessment evaluation.

In addition, this letter clarifies the actions FPL will take should the UHS temperature exceed 103'F during the period this extended NOED is in effect. Specifically, during any time interval where the UHS average supply water temperature exceeds 103'F, FPL will invoke the Action Statement associated with TS 3/4.7.4 to place both units in at least Hot Standby within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This action is the same as the Action Statement associated with the increased UHS temperature in the LAR (References 4 and 5). If the UHS temperature returns to less than or equal to 103'F within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, FPL will exit the Action Statement of TS 3/4.7.4 and continue operation in accordance with the NOED.FPL continues to remain in a period of high system load demand such that this request for extension concerns an avoidance of a dual unit shutdown of Turkey Point Units 3 and 4. The operation of Turkey Point Units 3 and 4 during the summer months is essential for grid voltage stability.

Florida Power & Light Company Page 3 of 3 Request for Extension of Notice of Enforcement Discretion This NOED request for extension was reviewed and approved by the Turkey Point Plant Nuclear Safety Committee on July 29, 2014.If you have any questions or require additional information, please contact Mr. Robert Tomonto at 305-246-7327.

Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant