ML15023A080

2015/01/22 NRR E-mail Capture - Request for Additional Information Re. LAR 229 for Turkey Point 3 & 4 (TACs MF3931 & MF3932)

ML15023A080
Person / Time
Site:	Turkey Point
Issue date:	01/22/2015
From:	Audrey Klett Plant Licensing Branch II
To:	Guth J M Florida Power & Light Co
References
TAC MF3931, TAC MF3932
Download: ML15023A080 (3)

Text

1NRR-PMDAPEm ResourceFrom:Klett, AudreySent:Thursday, January 22, 2015 2:44 PMTo:Mitch.Guth@fpl.com; 'Hanek, Olga' (Olga.Hanek@fpl.com); Gary.Kilby@fpl.com

Subject:

Request for Additional Information Re. LAR 229 for Turkey Point 3 & 4 (TACs MF3931 & MF3932)Hi Mitch, Olga, Gary, By letter dated April 9, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14105A042), as supplemented by letter dated August 29, 2014 (ADAMS Accession No. ML14252A228), Florida Power & Light Company (FPL or the licensee) requested amendments to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Generating Unit Nos. 3 and 4. The license amendment request (LAR) proposed changes to the Technical Specifications (TSs) to relocate specific surveillance frequencies to a licensee controlled program in accordance with Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." The licensee stated that the proposed changes are consistent with the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Traveler TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF (Risk-Informed TSTF) Initiative 5b."

The NRC's Probabilistic Risk Assessment Licensing Branch (APLA) staff reviewed the LAR and identified areas where it needs additional information to complete its review. The Request for Additional Information (RAI) is provided below. As discussed in electronic mail from Gary Kilby of the licensee's staff on January 21, 2015, the NRC requests the licensee to respond to the RAI within 30 days of this email. APLA RAI-1 Nuclear Energy Institute (NEI) 04-10, Revision 1 (ADAMS Accession No. ML071360456), Section 4.0, Step 8, states:

The risk impact of a proposed [Surveillance Test Interval (STI)] adjustment shall be calculated as a change of the test-limited risk (see Regulatory Guide 1.177, Section 2.3.3). Since the test-limited risk is associated with failures occurring between tests, the failure rate that shall be used in calculating the risk impact of a proposed STI adjustment is the time-related failure rate associated with failures occurring while the component is in standby between tests (i.e., risk associated with the longer time to detect standby-stress failures).

Describe how the Turkey Point Surveillance Frequency Control Program will address the standby time-related contribution for extended surveillances. APLA RAI-2 NEI 04-10, Revision 1, Section 4.0, Step 10, provides guidance on the initial assessment of Internal Events, External Events, and Shutdown Events. Describe how shutdown events will be assessed as part of the Turkey Point Surveillance Frequency Control Program. APLA RAI-3 The enclosure to Attachment 2 of the LAR provides the peer review Facts and Observations (F&Os). Address the impact of the following F&Os on this application, clarifying the disposition of the F&O, as necessary:

DA-D5-01, DA-D6-01, DA-D6-02, IE-C14-01, IE-C14-02, IE-C14-03, IE-C14-04, IE-C14-05, IE-C14-06, and IE-C14-07.

2 APLA RAI-4 The NRC staff notes that the response to PRA Request for Additional Information (RAI) 22.01 (ADAMS Accession No. ML14113A176) associated with the licensee's request to adopt National Fire Protection Association (NFPA) Standard 805 (NFPA 805) provides the results of the Turkey Point Gap Analysis to the American Society of Mechanical Engineers (ASME) / American Nuclear Society (ANS) Probabilistic Risk Assessment (PRA) Standard (ASME/ANS RA-Sa-2009) as endorsed by Regulatory Guide (RG) 1.200, Revision 2 (ADAMS Accession No. ML090410014). Confirm whether the results of the assessment for F&Os LE-F1-01 and LE-G5-01, as discussed in PRA RAI 22.01, are applicable to the LAR to relocate specific surveillance frequency requirements to a licensee controlled program. If the results are not applicable, address the impact of the F&Os for this application.

Audrey Klett Project Manager NRR/DORL/LPLII-2 301-415-0489 Hearing Identifier: NRR_PMDA Email Number: 1827 Mail Envelope Properties (Audrey.Klett@nrc.gov20150122144300)

Subject:

Request for Additional Information Re. LAR 229 for Turkey Point 3 & 4 (TACs MF3931 & MF3932) Sent Date: 1/22/2015 2:43:54 PM Received Date: 1/22/2015 2:43:00 PM From: Klett, Audrey Created By: Audrey.Klett@nrc.gov Recipients: "Mitch.Guth@fpl.com" <Mitch.Guth@fpl.com> Tracking Status: None

"'Hanek, Olga' (Olga.Hanek@fpl.com)" <Olga.Hanek@fpl.com> Tracking Status: None "Gary.Kilby@fpl.com" <Gary.Kilby@fpl.com> Tracking Status: None Post Office: Files Size Date & Time MESSAGE 3963 1/22/2015 2:43:00 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received: ZZZ