ML14205A278

LAR-230, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process

ML14205A278
Person / Time
Site:	Turkey Point
Issue date:	07/08/2014
From:	Kiley M W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-08-001, L-2014-028, LAR-230
Download: ML14205A278 (35)

Text

0FPL.July 8, 2014L-2014-028 10 CFR 50.90U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment Request No. LAR-230, Application to Revise Technical Specifications toAdopt Technical Specifications Task Force (TSTF) Traveler-523, "Generic Letter 2008-01,Managing Gas Accumulation,"

Using the Consolidated Line Item Improvement Process

Reference:

1. Letter (L-2008-218) from W. Jefferson, Jr. (FPL) to Document Control Desk (NRC),"Nine Month Response to NRC Generic Letter 2008-01, Managing GasAccumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"

October 14, 2008Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) is submitting a request foramendment to the Technical Specifications for Turkey Point Nuclear Plant (Turkey Point),Units 3 and 4.The proposed amendment would modify TS requirements to address NRC Generic Letter(GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay HeatRemoval, and Containment Spray Systems,"

as described in TSTF-523, Revision 2, "GenericLetter 2008-01, Managing Gas Accumulation."

FPL committed to submit this proposedchange in Reference 1.Attachment 1 provides a description and assessment of the proposed change. Attachment 2provides the existing TS pages marked up to show the proposed change. Attachment 3provides revised (clean) TS pages. Attachment 4 provides existing TS Bases pages markedto show the proposed change. Changes to the existing TS Bases, consistent with thetechnical and regulatory

analyses, will be implemented under the Technical Specification Bases Control Program.

They are provided in Attachment 4 for information only.Please process these changes within one (1) year of receipt, and once approved, theamendment shall be implemented within 60 days.In accordance with 10 CFR 50.91, a copy of this application, with attachments is beingprovided to the designated State of Florida Official.

Florida Power & Light Company9760 SW 344th St., Homestead, FL 33035 Document Control DeskL-2014-028 Page 2 of 2This application has been reviewed by the Turkey Point Onsite Review Group.This letter satisfies FPL's commitment made in Reference 1 and makes no new commitments orchanges to any other existing commitments.

If you have any questions or require additional information, please contact Robert Tomonto at305-246-7327.

I declare under penalty of perjury that the foregoing is true and correct.Executed on July B, 2014.Michael KileySite Vice President Turkey Point Nuclear PlantAttachments (4)cc: USNRC Regional Administrator, Region IIUSNRC Project Manager, Turkey Point Nuclear PlantUSNRC Resident Inspector, Turkey Point Nuclear PlantMs. Cindy Becker, Florida Department of Health L-2014-028 Attachment 1License Amendment Request -LAR-230Adoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas Accumulation Attachment ITurkey PointDescription and Assessment

1.0 DESCRIPTION

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations 3.0 REGULATORY ANALYSIS3.1 No Significant Hazards Consideration 3.2 Applicable Regulatory Requirements/Criteria 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

Page 1 of 5 L-2014-028 Attachment 1ATTACHMENT 1DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements to verify that the systemlocations susceptible to gas accumulation are sufficiently filled with water and to provideallowances which permit performance of the verification.

The changes are being made toaddress the concerns discussed in NRC Generic Letter (GL) 2008-01, "Managing GasAccumulation in Emergency Core Cooling, Decay Heat Removal, and Containment SpraySystems,"

[Reference 2].The proposed amendment is consistent with Technical Specifications Task Force Traveler(TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation"

[Reference 3].2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Florida Power & Light Company (FPL) has reviewed the model safety evaluation published January 15, 2014 as part of the Federal Register Notice of Availability "TSTF-523, GenericLetter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process" (79 FR 2700) [Reference 4]. This review included a review of the NRC staffsevaluation, as well as the information provided in TSTF-523.

As described in the subsequent paragraphs, FPL has concluded that the justifications presented in the TSTF-523 proposal andthe model safety evaluation prepared by the NRC staff are applicable to Turkey Point Units 3and 4 (Turkey Point) and justify this amendment for incorporation of the changes to the TurkeyPoint Technical Specifications (TS).2.2 Optional Changes and Variations FPL is proposing the following variations from the TS changes described in the TSTF-523, Revision 2 [Reference 3], or the applicable parts of the NRC staffs model safety evaluation.

The Turkey Point TS utilize different numbering, format, and titles than NUREG-1431, "Standard Technical Specifications

-Westinghouse Plants" [Reference 5] on which TSTF-523 was based.Specifically, the numbering and titles differences are provided in the table below.NUREG-1431 Turkey PointStandard Technical Specifications Technical Specifications Westinglhouse Plants3.4.6, RCS LOOPS -Mode 4 3/4.4.1.3, Reactor Coolant System -HotShutdown3.4.7, RCS LOOPS -Mode 5 Loops Filled 3/4.4.1.4.1, Reactor Coolant System -ColdShutdown

-Loops Filled3.4.8, RCS LOOPS -Mode 5 Loops Not Filled 3/4.4.1.4.2, Reactor Coolant System -ColdShutdown

-Loops Not FilledPage 2 of 5 L-2014-028 Attachment 1NUREG-1431 Turkey PointStandard Technical Specifications Technical Specifications Westinghouse Plants3.5.2, ECCS -Operating 3/4.5.2, ECCS Subsystems

-Tavg Greater than orEqual to 350°F3.6.6A, Containment Spray and Cooling Systems 3/4.6.2, Containment Systems -Depressurization and Cooling Systems3.9.5, RHR and Coolant Circulation

-High Water 3/4.9.8.1

,Residual Heat Removal and CoolantLevel Circulation

-High Water Level3.9.6, RHR and Coolant Circulation

-Low Water 3/4.9.8.2, Residual Heat Removal and CoolantLevel Circulation

-Low Water LevelThese differences are administrative and do not affect the applicability of TSTF-523 to TurkeyPoint. Attachment 3 provides revised (clean) TS pages.TSTF-523 and the model safety evaluation discuss the applicable regulatory requirements andguidance including the10 CFR 50, Appendix A, General Design Criteria (GDC). Turkey Pointwas not licensed to the 10 CFR 50, Appendix A, GDC. The Turkey Point design criteria arediscussed in the Updated Final Safety Analysis Report (UFSAR) Section 1.3, General DesignCriteria.

The Turkey Point design criteria that equates to GDC 1 are addressed in UFSARSection 1.3.1, Overall Requirements and the design criteria that equates to GDC 34 throughGDC 40 are addressed in UFSAR Section 1.3.7, Engineered Safety Features.

This difference does not alter the conclusion that the proposed change is applicable to Turkey Point Units 3 and4.3.0 REGULATORY SAFETY ANALYSIS3.1 No Significant Hazards Consideration Determination Florida Power & Light Company (FPL) requests adoption of Technical Specification Task ForceTraveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation,"

whichis an approved change to the standard technical specifications (STS), into the Turkey PointUnits 3 and 4 Technical Specifications (TS). The proposed change revises or adds Surveillance Requirements (SRs) to verify that the system locations susceptible to gas accumulation aresufficiently filled with water and to provide allowances which permit performance of theverification.

FPL has evaluated whether or not a significant hazards consideration is involved with theproposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:1: Does the Proposed Change Involve a Significant Increase in the Probability orConsequences of an Accident Previously Evaluated?

Response:

NoThe proposed change revises or adds SRs that require verification that the Emergency CoreCooling Systems (ECCS), the Residual Heat Removal (RHR) System, and the Containment Spray (CS) System are not rendered inoperable due to accumulated gas and to providePage 3 of 5 L-2014-028 Attachment 1allowances which permit performance of the revised verification.

Gas accumulation in thesubject systems is not an initiator of any accident previously evaluated.

As a result, theprobability of any accident previously evaluated is not significantly increased.

The proposedSRs ensure that the subject systems continue to be capable to perform their assumedsafety function and are not rendered inoperable due to gas accumulation.

Thus, theconsequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.

2. Does the Proposed Change Create the Possibility of a New or Different Kind of Accidentfrom any Accident Previously Evaluated?

Response:

NoThe proposed change revises or adds SRs that require verification that the ECCS, the RHRSystem, and the CS System are not rendered inoperable due to accumulated gas and toprovide allowances which permit performance of the revised verification.

The proposedchange does not involve a physical alteration of the plant (i.e., no new or different type ofequipment will be installed) or a change in the methods governing normal plant operation.

In addition, the proposed change does not impose any new or different requirements thatcould initiate an accident.

The proposed change does not alter assumptions made in thesafety analysis and is consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any accident previously evaluated.

3. Does the Proposed Change Involve a Significant Reduction in a Margin of Safety?Response:

NoThe proposed change revises or adds SRs that require verification that the ECCS, RHRSystem, and CS System are not rendered inoperable due to accumulated gas and toprovide allowances which permit performance of the revised verification.

The proposedchange adds new requirements to manage gas accumulation in order to ensure that thesubject systems are capable of performing their assumed safety functions.

The proposedSRs are more comprehensive than the current SRs and will ensure that the assumptions ofthe safety analysis are protected.

The proposed change does not adversely affect anycurrent plant safety margins or the reliability of the equipment assumed in the safetyanalysis.

Therefore, there are no changes being made to any safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as aresult of the proposed change.Therefore, the proposed change does not involve a significant reduction in a margin ofsafety.Page 4 of 5 L-2014-028 Attachment 13.2 Applicable Regulatory Requirements/Criteria Based on the above, FPL concludes that the proposed change presents no significant hazardsconsideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of"no significant hazards consideration" is substantiated.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facilitycomponent located within the restricted area, as defined in 10 CFR Part 20, or would change aninspection or surveillance requirement.

However, the proposed change does not involve (i) asignificant hazards consideration, (ii) a significant change in the types or significant increase inthe amounts of any effluent that may be released

offsite, or (iii) a significant increase inindividual or cumulative occupational radiation exposure.

Accordingly, the proposed changemeets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

5.0 REFERENCES

1. Letter (L-2008-218) from W. Jefferson, Jr. (FPL) to Document Control Desk (NRC),"Nine Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation inEmergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"

October 14, 20082. Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling,Decay Heat Removal, and Containment Spray Systems,"

January 11, 2008, (ADAMSAccession No. ML072910759)

3. Technical Specifications Task Force (TSTF)-523, Revision 2, "Generic Letter 2008-01,Managing Gas Accumulation,"

February 23, 2013, (ADAMS Accession No.ML13053A075)

4. Federal Register Notice of Availability, "TSTF-523, Generic Letter 2008-01 ManagingGas Accumulation Using the Consolidated Line Item Improvement Process" published January 15, 2014 (79 FR 2700)5. NUREG-1431, Revision 4, "Standard Technical Specifications

-Westinghouse Plants,"April 2012 (ADAMS Accession No. ML12100A222)

Page 5 of 5 L-2014-028 Attachment 2License Amendment Request -LAR-230Adoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas Accumulation Attachment 2Turkey PointProposed Technical Specifications ChangesMark UpThis coversheet plus 8 pagesList of Affected Pages3/4 4-3 -No changes this page 3/45-5For information only3/4 4-4 3/4 6-123/4 4-5 3/4 9-73/4 4-6 3/4 9-8 REACTOR COOLANT SYSTEMINo change this page,Ifor information onlyHOT SHUTDOWNLIMITING CONDITION FOR OPERATION 3.4.1.3 At least two of the loops listed below shall be OPERABLE and at least one of these loops shall be inoperation:*

a. Reactor Coolant Loop A and its associated steam generator and reactor coolant pump,**b. Reactor Coolant Loop B and its associated steam generator and reactor coolant pump,**c. Reactor Coolant Loop C and its associated steam generator and reactor coolant pump,**d. RHR Loop A, ande. RHR Loop B.APPLICABILITY:

MODE 4.ACTION:a. With less than the above required loops OPERABLE, immediately initiate corrective action to returnthe required loops to OPERABLE status as soon as possible; if the remaining OPERABLE loop is anRHR loop, be in COLD SHUTDOWN within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.b. With no loop in operation, suspend all operations involving a reduction in boron concentration of theReactor Coolant System and immediately initiate corrective action to return the required loop tooperation.

All reactor coolant pumps and RHR pumps may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided:

(1) no operations are permitted that would cause dilution of the Reactor Coolant System boron concentration, and (2) coreoutlet temperature is maintained at least 10'F below saturation temperature.

• • A reactor coolant pump shall not be started with one or more of the Reactor Coolant System cold legtemperatures less than or equal to 275*F unless the secondary water temperature of each steam generator is less than 50°F above each of the Reactor Coolant System cold leg temperatures.

TURKEY POINT -UNITS 3 & 43/4 4-3AMENDMENT NOS. 137 AND 132 REACTOR COOLANT SYSTEMSURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required reactor coolant pump(s),

if not in operation, shall be determined OPERABLE once per7 days by verifying correct breaker alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying secondary side waterlevel to be greater than or equal to 10% at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.3 At least one reactor coolant or RHR loop shall be verified in operation and circulating reactor coolant atleast once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.4 Verify required RHR loop locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.*1* Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.TURKEY POINT -UNITS 3 & 43/4 4-4AMENDMENT NOS. +-13-AND 432-REACTOR COOLANT SYSTEMCOLD SHUTDOWN

-LOOPS FILLEDLIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation*,

and either:a. One additional RHR loop shall be OPERABLE**,

orb. The secondary side water level of at least two steam generators shall be greater than 10%.APPLICABILITY:

MODE 5 with reactor coolant loops filled***.

ACTION:a. With one of the RHR loops inoperable or with less than the required steam generator water level,immediately initiate corrective action to return the inoperable RHR loop to OPERABLE status orrestore the required steam generator water level as soon as possible.

b. With no RHR loop in operation, suspend all operations involving a reduction in boronconcentration of the Reactor Coolant System and immediately initiate corrective action to returnthe required RHR loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be determined to be within limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.2 At least one RHR loop shall be determined to be in operation and circulating reactor coolant at leastonce per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.3 Verify required RHR loop locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.The RHR pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided:

(1) no operations are permitted that wouldcause dilution of the Reactor Coolant System boron concentration, and (2) core outlet temperature ismaintained at least 1 0°F below saturation temperature.

• • One RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop isOPERABLE.

• A reactor coolant pump shall not be started with one or more of the Reactor Coolant System cold legtemperatures less than or equal to 2750F unless the secondary water temperature of each steam generator is less than 50°F above each of the Reactor Coolant System cold leg temperatures.

TURKEY POINT -UNITS 3 & 43/4 4-5AMENDMENT NOS. +3-7-AND Q

REACTOR COOLANT SYSTEMCOLD SHUTDOWN

-LOOPS NOT FILLEDLIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two residual heat removal (RHR) loops shall be OPERABLE*

and at least one RHR loop shall be inoperation."

APPLICABILITY:

MODE 5 with reactor coolant loops not filled.ACTION:a. With less than the above required RHR loops OPERABLE, immediately initiate corrective actionto return the required RHR loops to OPERABLE status as soon as possible.

b. With no RHR loop in operation, suspend all operations involving a reduction in boronconcentration of the Reactor Coolant System and immediately initiate corrective action to returnthe required RHR loop to operation.

4.4.1.4.2.1 SURVEILLANCE REQUIREMENTS 44.2 At least one RHR loop shall be determined to be in operation and circulating reactor coolant at leastonce per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.2.2 Verify RHR loop locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.One RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop isOPERABLE.

• • The RHR pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided:

(1) no operations are permitted that wouldcause dilution of the Reactor Coolant System boron concentration, and (2) core outlet temperature ismaintained at least 10°F below saturation temperature.

TURKEY POINT -UNITS 3 & 43/4 4-6AMENDMENT NOS. 4-. AND +8-EMERGENCY CORE COOLING SYSTEMSSURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS component and flow path shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying by control room indication that the following valves are in theindicated positions with power to the valve operators removed:Valve Number Valve Function Valve Position864A and B' Supply from RWST to ECCS Open862A and B RWST Supply to RHR pumps Open863A and B RHR Recirculation Closed866A and B H.H.S.I.

to Hot Legs ClosedHCV-758*

RHR HX Outlet OpenTo permit temporary operation of these valves for surveillance or maintenance

purposes, power may berestored to these valves for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.b. At least once per 31days b -Verifying ECCS locations susceptible to gasb. At east Jaccumulation are sufficiently filled with water.1) Ve=l, tatte CGS pip!.R.9 is f'-!! of'::ate b'; "-etinq the EGGS nacccc:ible diccha@9 piping,2) Verifying that each valve (manual, power-operated, or automatic) in the flow path that is notlocked, sealed, or otherwise secured in position, is in its correct position Lnd3) Verifying that each RHR Pump develops the indicated differential pressure applicable to theoperating conditions in accordance with Figure 3.5-1 when tested pursuant toSpecification 4.0.5.c. At least once per 92 days by:1) Verifying that each SI pump develops the indicated differential pressure applicable to theoperating conditions when tested pursuant to Specification 4.0.5.SI pump _> 1083 psid at a metered flowrate

_ 300 gpm (normal alignment or Unit 4 SI pumpsaligned to Unit 3 RWST), or>_ 1113 psid at a metered flowrate

> 280 gpm (Unit 3 SI pumps aligned to Unit 4RWST).*Air Supply to HCV-758 shall be verified shut off and sealed closed once per 31 days.** Not required to be met for system vent flow paths opened under administrative control.TURKEY POINT -UNITS 3 & 43/4 5-5AMENDMENT NOS.- 9+ AND +8-5 CONTAINMENT SYSTEMS3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMSCONTAINMENT SPRAY SYSTEMLIMITING CONDITION FOR OPERATION 3.6.2.1 Two independent Containment Spray Systems shall be OPERABLE with each Spray System capable oftaking suction from the RWST and manually transferring suction to the containment sump via the RHR System.APPLICABILITY:

MODES 1, 2, 3, and 4.ACTION:a. With one Containment Spray System inoperable restore the inoperable Spray System toOPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.b. With two Containment Spray Systems inoperable restore at least one Spray System toOPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore both Spray Systems to OPERABLEstatus within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS 4.6.2.1 Each Containment Spray System shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) inthe flow path that is not locked, sealed, or otherwise secured in position, is in its correct positionand that power is available to flow path components that require power for operation,<

yb. By verifying that on recirculation flow, each pump develops the indicated differential

pressure, when tested pursuant to Specification 4.0.5:Containment Spray Pump >_241.6 psid while aligned in recirculation mode.c. At least once per 31 days, by verifying containment spray locations susceptible to gas accumulation are sufficiently filled with water.I

• Not required to be met for system vent flow paths opened under administrative control.TURKEY POINT -UNITS 3 & 43/4 6-12AMENDMENT NOS. +84 AND -3" REFUELING OPERATIONS 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVELLIMITING CONDITION FOR OPERATION 3.9.8.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation.*

APPLICABILITY:

MODE 6, when the water level above the top of the reactor vessel flange is greater than orequal to 23 feet.ACTION:With no RHR loop OPERABLE and in operation, suspend all operations involving an increase in the reactor decayheat load or a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to OPERABLE and operating status as soon as possible.

Close allcontainment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />..SURVEILLANCE REQUIREMENTS_

4.9.8.1.1 At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate ofgreater than or equal to 3000 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.9.8.1.2 The RHR flow indicator shall be subjected to a CHANNEL CALIBRATION at least once per18 months.4.9.8.1.3 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filledwith water at least once per 31 days.*The required RHR loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period, provided nooperations are permitted that would cause reduction of the Reactor Coolant System boron concentration.

TURKEY POINT -UNITS 3 & 43/4 9-7AMENDMENT NOS. 268 AND "S y REFUELING OPERATIONS LOW WATER LEVELLIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent residual heat removal (RHR) loops shall be OPERABLE, and at least one RHR loopshall be in operation*.

APPLICABILITY:

MODE 6, when the water level above the top of the reactor vessel flange is less than 23 feet.ACTION:a. With less than the required RHR loops OPERABLE, immediately initiate corrective action toreturn the required RHR loops to OPERABLE status, or to establish greater than or equal to23 feet of water above the reactor vessel flange, as soon as possible.

b. With no RHR loop in operation, suspend all operations involving a reduction in boronconcentration of the Reactor Coolant System and immediately initiate corrective action to returnthe required RHR loop to operation.

Close all containment penetrations providing direct accessfrom the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.SURVEILLANCE REQUIREMENTS

-At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate ofgreater than or equal to 3000 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.9.8.2.2 Verify RHR loop locations susceptible to gas accumulation are sufficiently filled withwater at least once per 31 days.* One required RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance

testing, provided that the otherRHR loop is OPERABLE and in operation.

TURKEY POINT -UNITS 3 & 43/4 9-8AMENDMENT NOS. 26-AND 26-)f L-2014--028 Attachment 3License Amendment Request -LAR-230Adoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas Accumulation Attachment 3Turkey PointRevised Technical Specifications PagesThis coversheet plus 7 pages REACTOR COOLANT SYSTEMSURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required reactor coolant pump(s),

if not in operation, shall be determined OPERABLE once per7 days by verifying correct breaker alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying secondary side waterlevel to be greater than or equal to 10% at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.3 At least one reactor coolant or RHR loop shall be verified in operation and circulating reactor coolant atleast once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.4 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water atleast once per 31 days.** Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.TURKEY POINT -UNITS 3 & 43/4 4-4AMENDMENT NOS. AND REACTOR COOLANT SYSTEMCOLD SHUTDOWN

-LOOPS FILLEDLIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation*,

and either:a. One additional RHR loop shall be OPERABLE**,

orb. The secondary side water level of at least two steam generators shall be greater than 10%.APPLICABILITY:

MODE 5 with reactor coolant loops filled***.

ACTION:a. With one of the RHR loops inoperable or with less than the required steam generator water level,immediately initiate corrective action to return the inoperable RHR loop to OPERABLE status orrestore the required steam generator water level as soon as possible.

b. With no RHR loop in operation, suspend all operations involving a reduction in boronconcentration of the Reactor Coolant System and immediately initiate corrective action to returnthe required RHR loop to operation.

SSURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be determined to be within limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.2 At least one RHR loop shall be determined to be in operation and circulating reactor coolant at leastonce per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.3 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water atleast once per 31 days.The RHR pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided:

(1) no operations are permitted that wouldcause dilution of the Reactor Coolant System boron concentration, and (2) core outlet temperature ismaintained at least 1 0°F below saturation temperature.

• • One RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop isOPERABLE.

• A reactor coolant pump shall not be started with one or more of the Reactor Coolant System cold legtemperatures less than or equal to 2750F unless the secondary water temperature of each steam generator is less than 50°F above each of the Reactor Coolant System cold leg temperatures.

TURKEY POINT -UNITS 3 & 43/4 4-5AMENDMENT NOS. AND REACTOR COOLANT SYSTEMCOLD SHUTDOWN

-LOOPS NOT FILLEDLIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two residual heat removal (RHR) loops shall be OPERABLE*

and at least one RHR loop shall be inoperation."

APPLICABILITY:

MODE 5 with reactor coolant loops not filled.ACTION:a. With less than the above required RHR loops OPERABLE, immediately initiate corrective actionto return the required RHR loops to OPERABLE status as soon as possible.

b. With no RHR loop in operation, suspend all operations involving a reduction in boronconcentration of the Reactor Coolant System and immediately initiate corrective action to returnthe required RHR loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.2.1 At least one RHR loop shall be determined to be in operation and circulating reactor coolant at leastonce per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.2.2 Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water at leastonce per 31 days.One RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop isOPERABLE.

• • The RHR pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided:

(1) no operations are permitted that wouldcause dilution of the Reactor Coolant System boron concentration, and (2) core outlet temperature ismaintained at least 100F below saturation temperature.

TURKEY POINT -UNITS 3 & 43/4 4-6AMENDMENTNOS.

AND EMERGENCY CORE COOLING SYSTEMSSURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS component and flow path shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying by control room indication that the following valves are in theindicated positions with power to the valve operators removed:Valve Number Valve Function Valve Position864A and B Supply from RWST to ECCS Open862A and B RWST Supply to RHR pumps Open863A and B RHR Recirculation Closed866A and B H.H.S.I.

to Hot Legs ClosedHCV-758*

RHR HX Outlet OpenTo permit temporary operation of these valves for surveillance or maintenance

purposes, power may berestored to these valves for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.b. At least once per 31 days by:1) Verifying ECCS locations susceptible to gas accumulation are sufficiently filled with water.2) Verifying that each valve (manual, power-operated, or automatic) in the flow path that is notlocked, sealed, or otherwise secured in position, is in its correct position,

• • and3) Verifying that each RHR Pump develops the indicated differential pressure applicable to theoperating conditions in accordance with Figure 3.5-1 when tested pursuant toSpecification 4.0.5.c. At least once per 92 days by:1) Verifying that each SI pump develops the indicated differential pressure applicable to theoperating conditions when tested pursuant to Specification 4.0.5.Sl pump _> 1083 psid at a metered flowrate

_ 300 gpm (normal alignment or Unit 4 SI pumpsaligned to Unit 3 RWST), or_> 1113 psid at a metered flowrate

> 280 gpm (Unit 3 SI pumps aligned to Unit 4RWST).*Air Supply to HCV-758 shall be verified shut off and sealed closed once per 31 days.**Not required to be met for system vent flow paths opened under administrative control.TURKEY POINT -UNITS 3 & 43/4 5-5AMENDMENT NOS. AND CONTAINMENT SYSTEMS3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMSCONTAINMENT SPRAY SYSTEMLIMITING CONDITION FOR OPERATION 3.6.2.1 Two independent Containment Spray Systems shall be OPERABLE with each Spray System capable oftaking suction from the RWST and manually transferring suction to the containment sump via the RHR System.APPLICABILITY:

MODES 1, 2, 3, and 4.ACTION:a. With one Containment Spray System inoperable restore the inoperable Spray System toOPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.b. With two Containment Spray Systems inoperable restore at least one Spray System toOPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore both Spray Systems to OPERABLEstatus within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and inCOLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS 4.6.2.1 Each Containment Spray System shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) inthe flow path that is not locked, sealed, or otherwise secured in position, is in its correct positionand that power is available to flow path components that require power for operation;*

b. By verifying that on recirculation flow, each pump develops the indicated differential

pressure, when tested pursuant to Specification 4.0.5:Containment Spray Pump 241.6 psid while aligned in recirculation mode.c. At least once per 31 days, by verifying containment spray locations susceptible to gasaccumulation are sufficiently filled with water.*Not required to be met for system vent flow paths opened under administrative control.TURKEY POINT -UNITS 3 & 43/4 6-12AMENDMENT NOS. AND REFUELING OPERATIONS 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVELLIMITING CONDITION FOR OPERATION 3.9.8.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation.*

APPLICABILITY:

MODE 6, when the water level above the top of the reactor vessel flange is greater than orequal to 23 feet.ACTION:With no RHR loop OPERABLE and in operation, suspend all operations involving an increase in the reactor decayheat load or a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to OPERABLE and operating status as soon as possible.

Close allcontainment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.SURVEILLANCE REQUIREMENTS 4.9.8.1.1 At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate ofgreater than or equal to 3000 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.9.8.1.2 The RHR flow indicator shall be subjected to a CHANNEL CALIBRATION at least once per18 months.4.9.8.1.3 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled water at leastonce per 31 days.*The required RHR loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period, provided nooperations are permitted that would cause reduction of the Reactor Coolant System boron concentration.

TURKEY POINT -UNITS 3 & 43/4 9-7AMENDMENTNOS.

AND REFUELING OPERATIONS LOW WATER LEVELLIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent residual heat removal (RHR) loops shall be OPERABLE, and at least one RHR loopshall be in operation*.

APPLICABILITY:

MODE 6, when the water level above the top of the reactor vessel flange is less than 23 feet.ACTION:a. With less than the required RHR loops OPERABLE, immediately initiate corrective action toreturn the required RHR loops to OPERABLE status, or to establish greater than or equal to23 feet of water above the reactor vessel flange, as soon as possible.

b. With no RHR loop in operation, suspend all operations involving a reduction in boronconcentration of the Reactor Coolant System and immediately initiate corrective action to returnthe required RHR loop to operation.

Close all containment penetrations providing direct accessfrom the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.SURVEILLANCE REQUIREMENTS 4.9.8.2.1 At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate ofgreater than or equal to 3000 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.9.8.2.2 Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water at least onceper 31 days.* One required RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance

testing, provided that the otherRHR loop is OPERABLE and in operation.

TURKEY POINT -UNITS 3 & 43/4 9-8AMENDMENTNOS.

AND L-2014-028 Attachment 4License Amendment Request -LAR-230Adoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas Accumulation Attachment 4Turkey PointProposed Technical Specifications Bases ChangesMark Up(For Information Only)This coversheet plus 10 pages REVISION NO.: PROCEDURE TITLE: PAGE:TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 80 of 192PROCEDURE NO.:O-ADM-536 TURKEY POINT PLANTATTACHMENT 2Technical Specification Bases(Page 64 of 176)3/4.4.1 (Continued)

The Technical Specifications for Cold Shutdown allow an inoperable RHR pump to be the operating RHR pump for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> forsurveillance testing to establish operability.

This is required because ofthe piping arrangement when the RHR system is being used for DecayHeat Removal.< 1INSERT 1 next page]3/4.4.2 Safety ValvesThe Pressurizer Code Safety Valves operate to prevent the RCS frombeing pressurized above its Safety Limit of 2735 psig. Each safetyvalve is designed to relieve 293,330 lbs per hour of saturated steam atthe valve setpoint.

The relief capacity of a single safety valve isadequate to relieve any overpressure condition which could occurduring shutdown.

In the event that NO safety valves are OPERABLE, an RCS vent opening of at least 2.20 square inches will provideoverpressure relief capability and will prevent RCS overpressurization.

In addition, the Overpressure Mitigating System provides a diversemeans of protection against RCS overpressurization at lowtemperatures.

During operation, all Pressurizer Code Safety Valves must beOPERABLE to prevent the RCS from being pressurized above itsSafety Limit of 2735 psig. The combined relief capacity of all of thesevalves is greater than the maximum surge rate resulting from acomplete loss-of-load assuming NO Reactor trip until the first ReactorTrip System Trip Setpoint is reached (i.e., NO credit is taken for adirect Reactor trip on the loss-of-load) and also assuming NOoperation of the power-operated relief valves or steam dump valves.The pressurizer safety valves are set to open at an RCS pressure of2465 psig +2% and -3% to avoid exceeding the maximum designpressure safety limit and to maintain accident assumptions.

Thepressurizer safety valve lift setting is needed to assure acceptable results for the Loss of Load/ Turbine Trip analysis.

The upper andlower pressure tolerance limits are based on the tolerance requirements assumed in the safety analyses.

RHR System piping and components have the potential to develop voids and pockets ofentrained gases. Preventing and managing gas intrusion and accumulation is necessary forproper operation of the required RHR loops and may also prevent water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel.Selection of RHR System locations susceptible to gas accumulation is based on a review ofsystem design information, including piping and instrument

drawings, isometric

drawings, planand elevation

drawings, and calculations.

The design review is supplemented by systemwalk downs to validate the system high points and to confirm the location and orientation ofimportant components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations.

If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criteria for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas(i.e., the system is sufficiently filled with water), the Surveillance may be declared met.Accumulated gas should be eliminated or brought within the acceptance criteria limits.RHR System locations susceptible to gas accumulation are monitored and, if gas is found, thegas volume is compared to the acceptance criteria for the location.

Susceptible locations in thesame system flow path which are subject to the same gas intrusion mechanisms may beverified by monitoring a representative sub-set of susceptible locations.

Monitoring may not bepractical for locations that are inaccessible due to radiological or environmental conditions, the plantconfiguration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring isnot required for susceptible locations where the maximum potential accumulated gas voidvolume has been evaluated and determined to not challenge system OPERABILITY.

Theaccuracy of the method used for monitoring the susceptible locations and trending of the resultsshould be sufficient to assure system OPERABILITY during the Surveillance interval.

SR 4.4.1.3.4 is modified by a Note that states the SR is not required to be performed until12 hours after entering MODE 4. In a rapid shutdown, there may be insufficient time to verify allsusceptible locations prior to entering MODE 4.The 31 day frequency for ensuring locations are sufficiently filled with water takes intoconsideration the gradual nature of gas accumulation in the RHR System piping and theprocedural controls governing system operation.

REVISION NO.: PROCEDURE TITLE: PAGE:9 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 121 of 192PROCEDURE NO.:O-ADM-536 TURKEY POINT PLANTATTACHMENT 2Technical Specification Bases(Page 105 of 176)3/4.5.2 Management of gas voids is important to& ECCS OPERABILITY.

3/4.5.3 ECCS Subsystems The OPERABILITY of ECCS components and flowpaths required inModes 1, 2 and 3 ensures that sufficient emergency core cooling capability will be available in the event of a LOGA assuming any single active failureconsideration.

Two SI Pumps and one RHR Pump operating in conjunctionL with two Accumulators are capable of supplying sufficient core cooling tou!limit the peak cladding temperatures within acceptable limits for all pipebreak sizes up to and including the maximum hypothetical accident of acircumferential rupture of a reactor coolant loop. In addition, the RHRsubsystem provides long-term core cooling capability in the recirculation mode during the accident recovery period.CAUTIONInterim Compensatory MeasureThe provision for temporary restoration of power to locked EGGS valves listedin SR 4.5.2.a for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit temporary operation for surveillance and maintenance purposes has been determined to be non-conservative withrespect to the safety analysis.

Therefore, until appropriate changes to SR 4.5.2via LAR 212 are approved and implemented, restoration of power to the valveslisted in SR 4.5.2.a shall be limited to one hour in order to provide alternative valve position indication in the event that the continuous valve positionindication (amber light) in the control room is unavailable.

Ref AR 1811016Motor Operated Valves (MOVs) 862A, 862B, 863A, 863B are required totake suction from the containment sump via the RHR System.PC-600 supplies controlling signals to valves MOVs 862B and 863B, toprevent opening these valves if RHR Pump B discharge pressure isabove 210 psig. PC-601 provides similar functions to valves MOVs 862Aand 863A. Although all four valves are normally locked in position, withpow er rem oved, the capability to pow er up and strok e nthe valves m ust bemaintained in order to satisfy the requirements for OPERABLE flow paths(capable of taking suction from the containment sump).

REVISION NO.: PROCEDURE TITLE: PAGE:9 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 123 of 192PROCEDURE NO.:0-ADM-536 TURKEY POINT PLANTATTACHMENT 2Technical Specification Bases(Page 107 of 176)/4.5.2 & 3/4.5.3 (Continued)

If cnt in accordance with NRC Generic Letter Mll~anaging G as ' u- ation in E m ergency C ore C , ecay H eatsGasIn the RHR test, differential head is specified in feet. This criteria will allowfor compensation of test data with water density due to varying temperature.

ECCS pump testing for the SI and RHR Pumps accounts for possibleunderfrequency conditions, i.e., the results of pump testing performed at60 Hz is then adjusted to reflect possible degraded grid conditions (60+0.6) to the lower limit (59.4 Hz).CAUTIONInterim Compensatory MeasureTS 3.5.2 Action 'a' has been determined to be non-conservative with respect tothe safety analysis as it allows up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for restoration of the inoperable flow path despite inoperability of both EGGS trains during this period.Therefore, until appropriate changes to TS 3/4.5.2 via LAR 212 are approvedand implemented, TS 3.0.3 shall be entered vice TS 3.5.2 Action 'a' in theevent that the suction flowgpath from the RWST to the EGGS is inoperable.

Reference AR 1811016.Technical Specifications Surveillance Requirement 4.5.2.e.3 requires thateach EGGS component and flow path be demonstrated OPERABLE every18 months by visual inspection which verifies sump components (trashracks, screens, etc.) show NO evidence of structural distress or abnormalcorrosion.

The strainer modules are rigid enough to provide both functions as trash racks and screens without losing their structural integrity andparticle efficiency.

Therefore, strainer modules are functionally equivalent to trash racks and screens.

Accordingly, the categorical description, sumpcomponents, is broad enough to require inspection of the strainer modules.

INSERT 2ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for properoperation of the ECCS and may also prevent a water hammer, pump cavitation, andpumping of noncondensible gas into the reactor vessel.Selection of ECCS locations susceptible to gas accumulation is based on a review of systemdesign information, including piping and instrument

drawings, isometric

drawings, plan andelevation

drawings, and calculations.

The design review is supplemented by system walk downsto validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped ordifficult to remove during system maintenance or restoration.

Susceptible locations depend onplant and system configuration, such as stand-by versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations.

If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criteria for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas(i.e., the system is sufficiently filled with water), the Surveillance may be declared met.Accumulated gas should be eliminated or brought within the acceptance criteria limits.ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gasvolume is compared to the acceptance criteria for the location.

Susceptible locations in thesame system flow path which are subject to the same gas intrusion mechanisms may beverified by monitoring a representative sub-set of susceptible locations.

Monitoring may not bepractical for locations that are inaccessible due to radiological or environmental conditions, the plantconfiguration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring isnot required for susceptible locations where the maximum potential accumulated gas voidvolume has been evaluated and determined to not challenge system OPERABILITY.

Theaccuracy of the method used for monitoring the susceptible locations and trending of the resultsshould be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day frequency for SR 4.5.2.b.1) takes into consideration the gradual nature of gasaccumulation in the ECCS piping and the procedural controls governing system operation.

Surveillance 4.5.2.b.2) is modified by a Note which exempts system vent flow paths openedunder administrative control.

The administrative control should be proceduralized and includestationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close thesystem vent path if directed.

REVISION NO.: PROCEDURE TITLE: PAGE:9 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 131 of 192PROCEDURE NO.:O-ADM-536 TURKEY POINT PLANTATTACHMENT 2Technical Specification Bases(Page 115 of 176)3/4.6.1.6 (Continued)

The required Special Reports from any engineering evaluation ofcontainment abnormalities shall include a description of the tendoncondition, the condition of the concrete (specially at tendonanchorages),

the inspection procedures, the tolerances on cracking, the results of the engineering evaluation, and the corrective actionstaken.The submittal of a Special Report for a failed tendon surveillance isconsidered an administrative requirement and it does NOT impact theplant operability.

The administrative requirements for Special Reportsare defined in Technical Specifications section 6.9.2.3/4.6.1.7 Containment Ventilation SystemThe Containment Purge supply and exhaust isolation valves arerequired to be closed during a LOCA. When NOT purging, power tothe purge valve actuators will be removed (sealed closed) to preventinadvertent opening of these values. Maintaining these valves sealedclosed during plant operation ensures that excessive quantities ofradioactive materials will NOT be released via the Containment PurgeSystem.Leakage integrity tests with a maximum allowable leakage rate forContainment Purge supply and exhaust supply valves will provideearly indication of resilient material seal degradation and will allowopportunity for repair before gross leakage failures could develop.

The0.60 La leakage limit shall NOT be exceeded whenthe leakage ratesdetermined by the leakage integrity tests of these valves are added tothe previously determined total for all valves and penetrations subjectto Type B and C tests.Management of gas voids is3/4.6.2 Depressurization and Coolinq Systems important to containment spray system OPERABILITY.

3/4.6.2.1 Containment Spray SystemThe OPERABILITY of the Containment Spray System ensures thatcontainment depressurization capability will be available in the event ofa LOCA. The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in the safetyanalyses.

<

REVISION NO.: PROCEDURE TITLE: PAGE:9 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 132 of 192PROCEDURE NO.:0-ADM-536 TURKEY POINT PLANTATTACHMENT 2Technical Specification Bases(Page 116 of 176)3/4.6.2.1 (Continued)

The allowable out-of-service time requirements for the Containment Spray System have been maintained consistent with that assignedother inoperable ESF equipment and do NOT reflect the additional redundancy in cooling capability provided by the Emergency Containment Cooling System. Pump performance requirements areobtained from the accidents analysis assumptions.

Motor Operated Valves (MOVs) 862A, 862B, 863A, 863B are requiredto take suction from the Containment Sump via the RHR system.PC-600 supplies controlling signals to valves MOVs 862B and 863B, toprevent opening these valves if RHR pump B discharge pressure isabove 210 psig. PC-601 provides similar functions to valves MOVs862A and 863A. Although all four valves are normally locked inposition, with power removed, the capability to power up and stroke thevalves must be maintained in order to satisfy the requirements forOPERABLE flow paths (capable of taking suction from the containment sump).When PC-600/-601 are calibrated, a test signal is supplied to eachcircuit to check operation of the relays and annunciators operated bysubject controllers.

This test signal will prevent MOVs 862A, 862B,INSERT 3 863A, 863B from opening.

Therefore, it is appropriate to tag out thenext page MOV breakers, and enter Technical Specification Action Statement 3.5.2.a.

and 3.6.2.1 when calibrating PC-600/-601.

3/4.6.2.2 Emerclencv Containment Coolina SvstemThe OPERABILITY of the Emergency Containment Cooling (ECC)System ensures that the heat removal capacity is maintained withacceptable ranges following postulated design basis accidents.

Tosupport both containment integrity safety analyses and component cooling water thermal analysis, a maximum of two ECCs can receivean automatic start signal following generation of a safety injection (SI)signal (one ECC receives an A train SI signal and another ECCreceives a B train SI signal).

To support post-LOCA long-term containment pressure/temperature

analyses, a maximum of two ECCsare required to operate.

The third (swing) ECC is required to beOPERABLE to support manual starting following a postulated LOCAevent for containment pressure/temperature suppression.

INSERT 3Containment Spray System piping and components have the potential to developvoids and pockets of entrained gases. Preventing and managing gas intrusion andaccumulation is necessary for proper operation of the containment spray trains andmay also prevent a water hammer and pump cavitation.

Selection of Containment Spray System locations susceptible to gas accumulation is based ona review of system design information, including piping and instrument

drawings, isometric

drawings, plan and elevation

drawings, and calculations.

The design review is supplemented bysystem walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The Containment Spray System is OPERABLE when it is sufficiently filled with water.Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds anacceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance isnot met. If it is determined by subsequent evaluation that the Containment Spray System isnot rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),the Surveillance may be declared met. Accumulated gas should be eliminated or brought withinthe acceptance criteria limits.Containment Spray System locations susceptible to gas accumulation are monitored and, if gasis found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring maynot be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations, alternative methods(e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge systemOPERABILITY.

The accuracy of the method used for monitoring the susceptible locations andtrending of the results should be sufficient to assure system OPERABILITY during theSurveillance interval.

The 31 day frequency for SR 4.6.2.1 .c takes into consideration the gradual nature of gasaccumulation in the Containment Spray System piping and the procedural controls governing system operation.

SR 4.6.2.1 .a is modified by a Note which exempts system vent flow paths openedunder administrative control.

The administrative control should be proceduralized and includestationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close thesystem vent path if directed.

REVISION NO.: PROCEDURE TITLE: PAGE:_ 9_ _ TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 188 of 192PROCEDURE NO.:O-ADM-536 TURKEY POINT PLANTATTACHMENT 2Technical Specification Bases(Page 172 of 176)3/4.9.8 (Continued)

The requirement to have two RHR loops OPERABLE when there isless than 23 feet of water above the reactor vessel flange ensures thata single failure of the operating RHR loop will NOT result in a completeloss of residual heat removal capability.

With the reactor vessel headINSERT 4 removed and at least 23 feet of water above the reactor pressurenSet page vessel flange, a large heat sink is available for core cooling.

Thus, ininext page the event of a failure of the operating RHR loop, adequate time is-provided to initiate emergency procedures to cool the core.3/4.9.9 Containment Ventilation Isolation SystemThe OPERABILITY of this system ensures that the containment ventilation penetrations will be automatically isolated upon detection ofhigh radiation levels within the containment.

The OPERABILITY of thissystem is required to restrict the release of radioactive material fromthe containment atmosphere to the environment.

T.S. surveillance requirement 4.9.9 states:4.9.9 The Containment Ventilation Isolation System shall bedemonstrated OPERABLE within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the startof and at least once per 7 days during CORE ALTERATIONS by verifying that Containment Ventilation Isolation occurs on aHigh Radiation test signal from each of the containment radiation monitoring instrumentation channels.

A normal refueling consists of 2 CORE ALTERATION sequences:

unloading the core, and reloading the core, typically with a suspension of CORE ALTERATIONS in between.

The core unload sequencebegins with control rod unlatching, followed by removal of upperinternals, followed by unloading fuel assemblies to the SFP. The corereload sequence consists of reloading fuel assemblies from the SFP,followed by upper internals installation, followed by latching controlrods. Therefore, if the Containment Ventilation Isolation System isdemonstrated OPERABLE at least once per 7 days following thespecified testing within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of control rodunlatching, then Containment Ventilation Isolation System operability need NOT be demonstrated within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of corereload. Otherwise, the specified testing is required to be performed within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of core reload.

[INSERT 4RHR System piping and components have the potential to develop voids and pockets ofentrained gases. Preventing and managing gas intrusion and accumulation is necessary forproper operation of the RHR loops and may also prevent water hammer, pump cavitation, andpumping of non-condensible gas into the reactor vessel.Selection of RHR System locations susceptible to gas accumulation is based on a review ofsystem design information, including piping and instrument

drawings, isometric

drawings, planand elevation

drawings, and calculations.

The design review is supplemented by systemwalk downs to validate the system high points and to confirm the location and orientation ofimportant components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations.

If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criteria for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas(i.e., the system is sufficiently filled with water), the Surveillance may be declared met.Accumulated gas should be eliminated or brought within the acceptance criteria limits.RHR System locations susceptible to gas accumulation are monitored and, if gas is found, thegas volume is compared to the acceptance criteria for the location.

Susceptible locations in thesame system flow path which are subject to the same gas intrusion mechanisms may beverified by monitoring a representative sub-set of susceptible locations.

Monitoring may not bepractical for locations that are inaccessible due to radiological or environmental conditions, the plantconfiguration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring isnot required for susceptible locations where the maximum potential accumulated gas voidvolume has been evaluated and determined to not challenge system OPERABILITY.

Theaccuracy of the method used for monitoring the susceptible locations and trending of the resultsshould be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day frequency for ensuring locations are sufficiently filled with water takes intoconsideration the gradual nature of gas accumulation in the RHR System piping and theprocedural controls governing system operation.