L-2017-110, License Amendment Request 255, Relocate Explosive Gas Monitoring, Gas Decay Tanks and Standby Feedwater System Technical Specifications to Licensee Controlled Documents
| ML17235B008 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/23/2017 |
| From: | Summers T Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2017-110 | |
| Download: ML17235B008 (43) | |
Text
August 23, 2017 L-2017-11 0 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555
-0001 RE: Turkey Point Nuclear Plant, Units 3 and 4 Docket Nos. 50
-250 and 50
-251 Renewed Facility Operating Licenses DPR
-31 and DPR
-41 License Amendment Request 2 55, Relocate the Explosive Gas Monitoring, Gas Decay Tanks and Standby Feedwater System Technical Specifications to Licensee Controlled Documents Pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests amendments to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively.
The proposed license amendments modify the Turkey Point Technical Specifications (TS) by relocating the Explosive Gas Monitoring Instrumentation, Explosive Gas Mixture, and Gas Decay Tanks System requirements to licensee controlled documents and establishing a Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program. The proposed license amendments additionally relocate the Standby Feedwater System requirements to licensee controlled documents and modify related Auxiliary Feedwater System requirements.
The enclosure to this letter provides FPL's evaluation of the proposed changes. Attachment 1 to the enclosure provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides existing TS Bases pages marked up to show the proposed changes.
The TS Bases changes are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment.
FPL has determined that the proposed changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and there are no significant environmental impacts associated with the change. The Turkey Point Onsite Review Group has reviewed the proposed license amendment
- s. In accordance with 10 CFR 50.91(b)(1), copies of the proposed license amendments are being forwarded to the State designee for the State of Florida.
FPL requests that the proposed changes are processed as a normal license amendment request, with approval within one year of the submittal date. Once approved, the amendments shall be implemented within 90 days.
This letter contains no new regulatory commitments.
Florida Power & Light Company 9760 SW 344 St., Homestead, FL 33035 Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2017-110 Page 2of2 Should you have any questions regarding this submission, please contact Mr. Mitch Guth, Turkey Point Licensing Manager, at (305) 246-6698.
I declare under penalty of perjury that the foregoing is true and correct. Executed on August 23, 2017 Sincerely, Thomas Summers Regional Vice President
-Southem Region Florida Power Light Company Enclosure cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 1 of 20 EVALUATION OF THE PROPOSED CHANGES Turkey Point Nuclear Plant, Units 3 and 4 License Amendment Request to Relocate the Explosive Gas Monitoring, Gas Decay Tanks and Standby Feedwater System Technical Specifications to Licensee Controlled Documents 1.0
SUMMARY
DESCRIPTION
.......................................................................................................... 2 2.0 DETAILED DESCRIPTION
......................................................................................................... 2 2.1 System Design and Operation
.............................................................................................. 2 2.2 Description of the Proposed Change
.................................................................................. 4
3.0 TECHNICAL EVALUATION
...................................................................................................... 7 4.0 REGULATORY EVALUATIO N ................................................................................................
16 4.1 Applicable Regulatory Requirements/Criteria
................................................................. 16 4.2 No Significant Hazards Consideration
..............................................................................
18 4.3 Conclusion
.............................................................................................................................
20
5.0 ENVIRONMENTAL CONSIDERATION
.............................................................................
20
6.0 REFERENCES
................................................................................................
................................. 20 ---------------..
Attachment 1 - Proposed Technical Specification Pages (markup)
Attachment 2 - Proposed Technical Specification Bases Pages (markup), Information Only
Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 2 of 20 1.0
SUMMARY
DESCRIPTION Florida Power & Light Company (FPL) requests amendments to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively.
The proposed license amendments modify the Turkey Point Technical Specifications (TS) by relocating the Explosive Gas Monitoring Instrumentation, Explosive Gas Mixture, and Gas Decay Tanks System requirements to licensee controlled documents and establishing a Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program. The proposed license amendments additionally relocate the Standby Feedwater System requirements to licensee controlled documents and modify related Auxiliary Feedwater System requirements. The proposed changes serve to align the Turkey Point TS more closely with NUREG 1431, Standard Technical Specifications - Westinghouse Plants, Revision 4 (Reference 6.
1).
2.0DETAILED DESCRIPTION 2.1System Design and Operation 2.1.1Gas Decay Tank System The Gas Decay Tank System consists of six welded carbon steel tanks fabricated to contain compressed waste gases including hydrogen, nitrogen, and fission product gaseous wastes from Turkey Point Units 3 and 4 normal operations. Gaseous wastes are stored in the Gas Decay Tank System for a specified period of natural radioactive decay following which the gases are either released through the monitored plant vent in accordance with the Turkey Point Activity Offsite Dose Calculation Manual (ODCM) or returned as cover gas previously displaced from the Chemical and Volume Control System (CVCS) holdup tanks. The quantity of radioactivity contained in each Gas Decay Tank is restricted to provide (a) assurance that in the event of an uncontrolled release of the tank's contents, the resulting total body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rem, and (b) assurance that the concentration of potentially explosive gas mixtures contained in the gas decay tank is maintained below the flammability limits of hydrogen and oxygen.
Gaseous sampling and analysis is conducted to monitor the concentrations of oxygen and hydrogen in the Waste Disposal System tanks, CVCS holdup tanks , Pressurizer Relief Tank and the Reactor Coolant Drain Tank. Upon indication of a high oxygen level, provisions are made to purge the affected tank to the Gas Decay Tank System. Gas samples are then drawn from the Gas Decay Tank being filled and analyzed to determine the hydrogen and Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 3 of 20 oxygen content. To prevent the hydrogen concentration from exceeding the combustible limit, components discharging to the vent header are restricted to those containing no air or aerated liquids and the vent header itself is designed to operate at a slight positive pressure to prevent in-leakage.
2.1.2Continuous Gas Analyzer (C-289 Panel)
The Continuous Gas Analyzer utilizes inputs from a hydrogen analyzer calibrated over a range of 0 -100% hydrogen and an oxygen analyzer calibrated over a range of 0
-4% oxygen. The gas analyzer performs continuous sampling of the inservice gas decay tank to ensure that the concentration of potentially explosive gas mixtures is maintained below the flammability limits of hydrogen and oxygen. Alarms are provided for both hydrogen and oxygen content. 2.1.3Auxiliary Feedwater System The Auxiliary Feedwater System (AFW) system is shared between Turkey Point Units 3 and 4 and supplies feedwater to the Steam Generators during transients when normal feedwater is not available. The AFW system provides sufficient heat removal capability to prevent reactor coolant inventory relief through the Pressurizer power-operated relief valves or the Pressurizer code
-safety valves. The AFW system consists of three quick starting steam turbine-driven AFW pumps, each capable of supplying the total feedwater requirement to either or both Units. The three pumps are aligned to provide two AFW trains with two of the pumps normally aligned to one of the trains. The AFW steam supply valves automatically open on any one of the following five Engineered Safety Features Actuation System (ESFAS) signals.
1.Safety injection 2.Low-low level in any of the three Steam Generators 3.Loss of both feedwater pumps under normal operating conditions 4.Bus low or degraded voltage 5.Anticipated Transient Without Scram (ATWS) Mitigating System Actuating Circuitry (AMSAC) signal 2.1.4Standby Feedwater System The Standby Feedwater System consists of two non
-safety grade standby steam generator feedwater pumps (SSGFP). One pump is motor driven and normally powered from the 4160 volt C-Bus. The other pump is diesel engine driven with an integral fuel tank and electric starting system.
The Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 4 of 20 SSGFPs are normally used to supply feedwater to the Steam Generators during start-up, shutdown, and hot standby conditions. The pumps take suction from the 500,000 gallon, non
-safety related demineralized water storage tank (DWST) and discharge into the main feedwater header upstream of the feedwater regulating valves.
The SSGFPs can be operated from the Control Room or from a local control panel. One SSGFP is typically used during startup or shutdown when Reactor power is less than 5%.
The Standby Feedwater System is shared by Units 3 and 4, whereby any one SSGFP can supply either or both Units as necessary to meet feedwater demand. The system provides a shutdown function but not a safety related or an emergency function. In the event the Auxiliary Feedwater (AFW) system does not function properly, the Standby Feedwater System can be used as a backup water supply during which the SSGFPs c an be manually started, aligned, and controlled by the operator as needed. In case of loss of off-site power, feedwater to the Steam Generators can be supplied by the diesel engine driven SSGFP should the AFW pumps not be available.
For fires affecting the AFW pumps, credit is taken for the Standby Feedwater System. 2.1.5Demineralized Water Storage Tank The DWST is a 500,000 gallon, non
-safety related source of demineralized water that is considered part of the primary makeup demineralized water system. The DWST is the main source of water for the Standby Feedwater System and is the alternate source of water for the AFW system. The DWST provides a shutdown function but not a safety related or an emergency function. The DWST minimum allowable inventory ensures that adequate water is available to provide reactor decay heat removal for either or both nuclear U nits in the event the AFW system is unavailable. 2.2Description of the Proposed Change 2.2.1Explosive Gas Monitoring Instrumentation TS 3.3.3.6, Explosive Gas Monitoring Instrumentation, specifies the Limiting Conditions for Operation (LCO), operational MODE(s), required ACTION(s) and Surveillance Requirements (SRs) for the Turkey Point explosive gas monitoring instrumentation. TS 3.3.3.6, Table 3.3-8, Explosive Gas Monitoring Instrumentation, specifies the Minimum Channels OPERABLE, operational MODE(s) and ACTION(s) for the Turkey Point explosive gas monitoring instrumentation.
Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 5 of 20 TS 3.3.3.6, Table 4.3-6, Explosive Gas Monitoring Instrumentation Surveillance Requirements, specifies the CHANNEL CHECK, Source Check, CHANNEL CALIBRATION, ANALOG CHANNEL OPERATIONAL TEST, and operational MODE(s) for the Turkey Point explosive gas monitoring instrumentation.
The proposed change deletes TS 3.3.3.6, Table 3.3-8 and Table 4.3-6, and relocates the Turkey Point explosive gas monitoring instrumentation requirements to the Turkey Point Updated Final Safety Analysis Report (UFSAR) and applicable plant procedures whereby future changes will be subject to the provisions of 10 CFR 50.59.
2.2.2Explosive Gas Mixture TS 3.7.8, Explosive Gas Mixture, specifies the LCO(s), operational MODE(s), ACTION(s) and SR(s) for the concentration of oxygen in the gas decay tank system when the concentration of hydrogen exceeds 4% by volume. The proposed change deletes TS 3.7.8 and relocates the requirements for the concentration of oxyge n and hydrogen in the gas decay tank system to the Turkey Point UFSAR and applicable plant procedures whereby future changes will be subject to the provisions of 10 CFR 50.59.
2.2.3Gas Decay Tanks TS 3.7.9, Gas Decay Tanks, specifies the LCO(s), operational MODE(s), ACTION(s) and SR(s) for the quantity of radioactivity (in dose equivalent Xenon-133) contained in each Gas Decay Tank.
The proposed change deletes TS 3.7.9 and relocates the requirements for the quantity of radioactivity contained in each Gas Decay Tank to the Turkey Point UFSAR and applicable plant procedures whereby future changes will be subject to the provisions of 10 CFR 50.59.
2.2.4Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program TS 6.8.4, Programs and Procedures, specifies the Turkey Point programs that shall be established, implemented, and maintained.
The proposed change establishes in TS 6.8.4, a Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program, which limits the concentration Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 6 of 20 of hydrogen and oxygen in the Gas Decay Tanks and establishes a surveillance program to ensure the limits are maintained.
The Program additionally establishes a surveillance program to ensure that the quantity of ra dioactivity contained in each Gas Decay Tank is less than the amount that would result in a whole body exposure of greater than or equal to 0.5 rem to any individual in a restricted area in the event of an uncontrolled release of the tanks' contents. The Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program will state the following:
Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program This Program provides controls for potentially explosive gas mixtures and the quantity of radioactivity contained in the Gas Decay Tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, Postulated Radioactive Release Due to Waste Gas System Leak or Failure. The Program shall include:
1.The limits for concentrations of hydrogen and oxygen in the Gas Decay Tanks and a surveillance program to ensure that the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion), and 2.A surveillance program to ensure that the quantity of radioactivity contained in each Gas Decay Tank is less than the amount that would result in a whole body exposure of
>0.5 rem to any individual in an unrestricted area, in the event of an uncontrolled release of the tanks' contents. The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program surveillance frequencies.
2.2.5Standby Feedwater System TS 3.7.1.6, Standby Feedwater System, specifies the LCO(s), operational MODE(s), ACTION(s) and SR(s) for the Standby Feedwater System, including requirements for the SSGFPs and the DWST. Included within are Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 7 of 20 requirements to submit a SPECIAL REPORT in the event of inoperable SSGFP or DWST beyond the TS 3.7.1.6 allowable outage times.
The proposed change deletes TS 3.7.1.6 and relocates the requirements to the Turkey Point UFSAR and applicable plant procedures whereby future changes will be subject to the provisions of 10 CFR 50.59. The proposed change also deletes the special reporting requirements such that no NRC notification would occur in the event a SSGFP or DWST is non-operational in excess of the current TS 3.7.1.6 specified periods triggering special reporting.
2.2.6Auxiliary Feedwater System TS 3.7.1.2, Auxiliary Feedwater System, specifies the LCO(s), operational MODE(s), ACTION(s) and SR(s) for the AFW system.
The proposed change modifies TS 3.7.1.2, ACTION 2, such that in the event both AFW trains are inoperable and cannot be restored to OPERABILITY within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the requirement to verify the OPERABILITY of both SSGFPs prior to commencing Unit(s) shutdown is replaced with a requirement to verify that both SSGFPs are capable of providing makeup to the Steam Generators prior to commencing Unit(s) shutdown.
3.0TECHNICAL EVALUATION
The proposed license amendments modify the Turkey Point TS by relocating the Explosive Gas Monitoring Instrumentation, Explosive Gas Mixture, and Gas Decay Tanks System requirements to licensee controlled documents and establishing a Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program. The proposed license amendments additionally relocate the Standby Feedwater System requirements to licensee controlled documents and modify related Auxiliary Feedwater System requirements. The bases for the proposed changes follow: 3.1Explosive Gas Monitoring Instrumentation The proposed change deletes TS 3.3.3.6, Explosive Gas Monitoring Instrumentation, Table 3.3-8, Explosive Gas Monitoring Instrumentation, and Table 4.3
-6, Explosive Gas Monitoring Instrumentation Surveillance Requirements, and relocates the explosive gas monitoring instrumentation requirements to the Turkey Point UFSAR and applicable plant procedures whereby future changes will be subject to the provisions of 10 CFR 50.59.
Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 8 of 20 The explosive gas monitoring instrumentation is not installed instrumentation used to detect, and indicate in the Control Room, a significant abnormal degradation of the reactor coolant pressure boundary; does not include process variables, design features, or operating restrictions that are an initial condition of a design basis accident or transient analysis that assumes the failure of or presents a challenge to the integrity of a fission product barrier; are not comprised of SSCs that are part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that assumes the failure of or presents a challenge to the integrity of a fission product barrier; and do not include SSCs which operating experience or probabilistic risk assessment have shown to be significant to public health and safety. Hence, the explosive gas monitoring instrumentation does not meet the 10 CFR 50.36(c)(2)(ii) criteria for TS inclusion as a LCO and hence is appropriate for relocation to licensee controlled documents with no adverse impact on safety. Th is determination is consistent the NRC's Final Policy Statement on TS Improvements for Nuclear Power Reactors (Reference 6.2), which states in reference to the 10 CFR 50.36(c)(2)(ii) criteria:
The purpose of Technical Specifications is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by identifying those features that are of controlling importance to safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval.
The Final Policy Statement further states:
If a licensee elects to apply these [10 CFR 50.36(c)(2)] criteria, the requirements of the removed specifications will be relocated to the FSAR or other licensee
-controlled documents.
Licensees are to operate their facilities in conformance with the descriptions of their facilities and procedures in their FSAR. Changes to the facility or to procedures described in the FSAR are to be made in accordance with 10 CFR 50.59.
The determination that the explosive gas monitoring instrumentation does not meet the 10 CFR 50.36(c)(2)(ii) criteria is also consistent with Generic Letter (GL) 95
-10, Relocation of Selected Technical Specifications Requirements Related to Instrumentation (Reference 6.3), which notes that the explosive gas monitoring instrumentation requirements address detection of possible precursors to the failure of a waste gas system but do not prevent or mitigate design basis accidents or transients which assume a failure of or present a challenge to a fission product barrier. GL 95
-10 explicitly recommends TS explosive gas monitoring instrumentation requirements as candidates for relocation to licensee controlled documents.
Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 9 of 20 Relocating the explosive gas monitoring instrumentation requirements to licensee controlled documents changes neither plant equipment nor modifies the manner in which plant equipment is operated or maintained. The explosive gas monitoring instrumentation operational limits, operational MODE(s) and required ACTION(s) will be relocated to plant procedures consistent with the Turkey Point TS requirements. The instrument channel checks, analyzer analog checks and zero and span checks will continue to be performed at their current periodicities. The existing defense in depth and diversity described in the Turkey Point UFSAR with regard to explosive gas monitoring instrumentation functional performance will not be diminished by the proposed license amendments. Any future changes to the UFSAR or applicable plant procedures will first be subject to the provisions of 10 CFR 50.59.
As such, the deletion of TS 3.3.3.6, Table 3.3
-8, and Table 4.3-6, and the relocation of the explosive gas monitoring instrumentation requirements to the Turkey Point USFAR and applicable plant procedures are reasonable.
3.2Explosive Gas Mixture The proposed change deletes TS 3.7.8, Explosive Gas Mixture, and relocates the requirements for the concentration of oxygen and hydrogen in the Gas Decay Tank system to licensee controlled documents whereby future changes will be subject to the provisions of 10 CFR 50.59.
The limitations specified in TS 3.7.8 ensure that the concentration of potentially explosive gas mixtures contained in the Gas Decay Tank System (as measured in the inservice gas decay tank) is maintained below the flammability limits of hydrogen and oxygen. Maintaining the concentration of hydrogen and oxygen below their flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Design Criterion (GDC) 60 of Appendix A to 10 CFR Part 50. Turkey Point procedures impose limits on the concentration of oxygen and hydrogen in the Gas Decay Tanks consistent with current TS Explosive Gas Mixture requirements and require immediate suspension of additions to the Gas Decay Tanks and reduction to acceptable levels if the oxygen and hydrogen concentration limits are exceeded.
More specifically, Turkey Point procedures: Prevent the formation of explosive mixtures in the VCT, HUT, PRT, RCDT, SFP Resin, etc., by limiting the oxygen concentration to less than or equal to 2% by volume when hydrogen is greater than 4%. If the concentration of oxygen and the hydrogen in one of the tanks exceed allowable limits, plant procedures require that the tank be purged to the Gas Decay Tank system until the subject tank reaches acceptable gas concentration levels. During Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 10 of 20 purging to a Gas Decay Tank , gas concentration levels are monitored using the C-289 analyzer or if out of service, by periodic grab sample analyses.
Prevent the formation of gases in the Gas Decay Tanks from approaching explosive levels by entry into an off-normal procedure if an in-service Gas Decay Tank reaches an oxygen concentration greater than 2% by volume and hydrogen concentration greater than 4% by volume. The off-normal procedure requires reduction of the oxygen concentration to less than or equal to 2% by volume within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the in-service Gas Decay Tank oxygen concentration is greater than 4% by volume and its hydrogen concentration is greater than 4% by volume, the immediate suspension of all gas additions to the Gas Decay Tank and the reduction of the oxygen concentration to less than 4% is required as soon as possible. In all cases involving the above limits, the Shift Manager is immediately notified.
The explosive gas mixture requirements of TS 3.7.8 are not of controlling importance to operational safety since they do not impose any limitations or conditions on Reactor operation which are necessary to obviate an abnormal situation or event that could pose an immediate threat to public safety. Hence, the TS Explosive Gas Mixture requirements do not meet the 10 CFR 50.36 (c)(2)(ii) criteria for TS inclusion as a LCO. Consistent with the NRC's Final Policy Statement on TS improvements (Reference 6.
2), the Explosive Gas Mixture requirements are appropriate for relocation from the Turkey Point TS to licensee controlled documents with no adverse impact on safety.
Relocating the explosive gas mixture requirements of TS 3.7.8 to licensee controlled documents will not affect the procedures described above for preventing explosive gas mixtures.
The explosive gas monitoring operational limits, monitoring requirements and required ACTIONS will be relocated to plant procedures consistent with the Turkey Point TS requirements. The existing defense in depth and diversity currently described in the Turkey Point UFSAR with regard to preventing explosive gas mixtures will not be diminished by the proposed change. Any future changes to the UFSAR or applicable plant procedures will first be subject to the provisions of 10 CFR 50.59. As such, the deletion of TS 3.7.8 and the relocation of the explosive gas mixture requirements to the Turkey Point USFAR and applicable plant procedures are reasonable.
3.3Gas Decay Tanks The proposed change deletes TS 3.7.9, Gas Decay Tanks
, and relocates the requirements for the quantity of radioactivity contained in each Gas Decay Tank to the Turkey Point USFAR and applicable plant procedures whereby future changes will be subject to the provisions of 10 CFR 50.59.
Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 11 of 20 The limits on the quantity of radioactivity contained in each Gas Decay Tank, as specified in TS 3.7.9, are not of controlling importance to operational safety since they do not impose any limitations or conditions on Reactor operation which are necessary to obviate an abnormal situation or event that could pose an immediate threat to public safety. Hence, the TS limits on the quantity of radioactivity contained in each Gas Decay Tank do not meet the 10 CFR 50.36 (c)(2)(ii) criteria for TS inclusion as a LCO. Consistent with the NRC's Final Policy Statement on TS improvements (Reference 6.2), the limits on the quantity of radioactivity contained in each Gas Decay Tank are appropriate for relocation from the Turkey Point TS to licensee controlled documents with no adverse impact on safety.
Relocating the limits on the quantity of radioactivity contained in each Gas Decay Tank to licensee controlled documents will not affect the manner in which whole body dose exposures will be limited to allowable levels in the event of a Gas Decay Tank rupture. The Gas Decay Tank operational limits, including the maximum dose equivalent Xe-133 activity allowed per Gas Decay Tank, the monitoring requirements and the required ACTIONS will be relocated to plant procedures consistent with the Turkey Point TS requirements. More specifically, the current TS limit of 70,000 curies dose equivalent Xe
-133 per Gas Decay Tank will be maintained in applicable plant procedures such that the consequences of a ruptured Gas Decay Tank remain bounded by the UFSAR accident analysis of record for a ruptured Gas Decay Tank. Relocating the limits on the quantity of radioactivity contained in each Gas Decay Tank to licensee controlled documents will not affect the ruptured Gas Decay Tank analysis conclusion that the resulting off
-site doses are less than the 0.1 rem TEDE limit specified in Branch Technical Position (BTP) 11-5 of the Standard Review Plan (SRP), Postulated Radioactive Release due to Waste Gas System Leak or Failure (Reference 6.4), and that the whole body exposure to any individual in an unrestricted area in the event of an uncontrolled release of the tanks' contents would not be greater than or equal to 0.5 rem. Hence, the existing defense in depth and diversity currently described in the Turkey Point UFSAR will not be diminished by the proposed change. Any future changes to the USFAR accident analyses or applicable plant procedures will first be subject to the provisions of 10 CFR 50.59. As such, the deletion of TS 3.7.9 and the relocation of the limits on the quantity of radioactivity contained in each Gas Decay Tank to the Turkey Point USFAR and applicable plant procedures are reasonable.
3.4Explosive Gas and Storage Tank Radioactivity Monitoring Program The proposed change adds TS 6.8.4.n, Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program, which limits the concentration of hydrogen and oxygen in the Gas Decay Tanks and establishes a surveillance program to ensure the limits are maintained.
The surveillance program ensures that the quantity of Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 12 of 20 ra dioactivity contained in each Gas Decay Tank is less than the amount that would result in a whole body exposure of greater than or equal to 0.5 rem to any individual in an unrestricted area in the event of an uncontrolled release of the tanks' contents.
The Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program incorporates the guidance provided in NUREG-1431, Section 5.5.12, Explosive Gas and Sto rage Tank Radioactivity Monitoring Program, (References 6.
- 1) as they relate to the concentration of hydrogen and oxygen and the quantity of radioactivity stored in the Turkey Point Gas Decay Tanks. However, the Program does not adopt the NUREG-1431, Section 5.5.12, guidance for outdoor liquid radwaste tanks since Turkey Point does not have outdoor liquid storage tanks that contain radwaste. Accordingly , the provisions of NUREG-1431, Section 5.5.12, relating to the limiting the contents of liquid radwaste storage tanks and determining the liquid radwaste quantities in accordance with SRP Section 15.7.3, Postulated Radioactive Release Due to Tank Failures, are not incorporated into the Turkey Point Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program.
The limits on the explosive gas concentration and radioactivity content in the Turkey Point Gas Decay Tanks that will be imposed by the Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program are unchanged from the limitations currently specified in TS 3.7.8, Explosive Gas Mixture, and TS 3.7.9, Gas Decay Tanks, and implemented by Turkey Point plant procedures. Similarly, the explosive monitoring instrumentation and surveillance requirements specified in TS 3.3.3.6, Table 3.3
-8, Explosive Gas Monitoring Instrumentation, and Table 4.3-6, Explosive Gas Monitoring Instrumentation Surveillance Requirements, will be implemented via the Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program, UFSAR and applicable plant procedures. Hence, the net effect of the proposed change is to retain key Gas Decay Tank requirements within the Turkey Point TS while simplifying the overall content of the TS, consistent with the standard TS provided in NUREG-1431 (Reference 6.
1). The proposed Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program also states that the gaseous radioactivity quantities in the Turkey Point Gas Decay Tanks shall be determined following the methodology in BTP ETSB 11-5, Postulated Radioactive Release Due to Waste Gas System Leak or Failure (Reference
6.4). The methodology is consistent with the methodology used in the Turkey Point USFAR analyses for the determination of offsite exposures resulting from a ruptured Gas Decay Tank. Hence the Program requirement to determine the gaseous radioactivity quantities in accordance with BTP ETSB 11-5 is consistent with the Turkey Point licensing basis. The proposed Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program also states that the provisions of Turkey Point SR 4.0.2 and SR 4.0.3 apply Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 13 of 20 to the Program surveillance frequencies. SR 4.0.2 states that each SR shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance interval. SR 4.0.3 specifies the required actions that must be performed in the event a surveillance requirement is not completed within its specified surveillance interval. Applying SR 4.0.2 and SR 4.0.3 to the Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program surveillance frequencies serve to retain the SR 4.0.2 and SR 4.0.3 requirements as currently applicable to the surveillances associated with T S 3.3.3.6, Explosive Gas Monitoring Instrumentation, TS 3.7.8, Explosive Gas Mixtures, and TS 3.7.9, Gas Decay Tanks, and thereby is consistent with the Turkey Point licensing basis.
The Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program will provide TS requirements to assure that appropriate procedures are maintained to monitor and control the radioactivity and explosive gas content of the Gas Decay Tanks using accepted NRC methodologies. Hence, incorporating the Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program into the Turkey Point TS provides adequate regulatory control and assurance that the Turkey Point Gas Decay Tanks will be monitored and controlled within the applicable limits for explosive gas and radioactivity content and is thereby reasonable.
3.5Standby Feedwater System The proposed change deletes TS 3.7.1.6, Standby Feedwater System, and relocates the requirements for the SSGFP(s) and the DWST to licensee controlled documents whereby future changes will be subject to the provisions of 10 CFR 50.59.
The proposed change also deletes the special reporting requirements of TS 3.7.1.6 such that no notification to the NRC would occur in the event a SSGFP or DWST is non-operational in excess of the current TS 3.7.1.6 specified periods triggering special reporting.
The Standby Feedwater System is not installed instrumentation used to detect, and indicate in the Control Room, a significant abnormal degradation of the reactor coolant pressure boundary; does not include process variables, design features, or operating restrictions that are an initial condition of a design basis accident o r transient analysis that assumes the failure of or presents a challenge to the integrity of a fission product barrier; is not comprised of SSCs that are part of the primary success path and which functions or actuates to mitigate a design basis accident o r transient that assumes the failure of or presents a challenge to the integrity of a fission product barrier; and does not include SSCs which operating experience or probabilistic risk assessment have shown to be significant to public health and safety. Hence, the Standby Feedwater System does not meet the 10 CFR 50.36(c)(2)(ii) criteria for TS inclusion as LCOs. Consistent with the NRC's Final Policy Statement on TS Improvements for Nuclear Power Reactors (Reference 6.
2), the Standby Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
-250 and 50
-251 Enclosure Page 14 of 20 Feedwater System TS requirements are appropriate for relocation to licensee controlled documents with no adverse impact on safety.
Relocating the Standby Feedwater System requirements to licensee controlled documents neither physically changes the system nor modifies the manner in which it will be operated and maintained. The SSG FP and DWST operational limits, applicable MODES, required ACTIONS and SRs will be relocated to plant procedures consistent with the Turkey Point TS requirements. The Standby Feedwater System will continue to perform with high reliability as FPL will continue to maintain the system in good operating condition with regard to appearance, structures, supports, component maintenance, calibrations, etc. This includes demonstrating system functionality on a periodic basis by operating the SSGFPs in the recirculation mode to verify supporting equipment performance and by verifying feedwater flow capability to the Steam Generators. To ensure that the diesel-driven SSGFP is maintained in good operating condition, the diesel driver will continue to be inspected consistent with manufacture's recommendations and FPL's overall objectives for system reliability. As such, the existing defense in depth and diversity currently described in the UFSAR with regard to Standby Feedwater System functional performance will not be diminished. Any future changes to the UFSAR or applicable plant procedures will first be subject to the provisions of 10 CFR 50.59.
The proposed change is consistent with NUREG
-1431 (Reference 6.1), which neither includes a Standby Feedwater System nor requires submittal of any special report associated with the SSGFPs or the DWST. The special reporting required by TS 3.7.1.6 provides information but neither requests NRC approval nor ensures safe operation of the facility during or after the period for report submittal. Therefore, elimination of the special reporting requirement is appropriate on the basis that it does not meet the immediate reporting criteria of 10 CFR 50.72, regarding immediate notification requirements for operating nuclear power reactors, and the reports are not necessary to ensure operation of the facility in a safe manner.
Hence, consistent with NUREG
-1431 and the NRC's Final Policy Statement on TS Improvements for Nuclear Power Reactors (Reference 6.
2), the Standby Feedwater System TS requirements are appropriate for relocation to licensee controlled documents with no adverse impact on safety. As such, the deletion of TS 3.7.1.6 and the relocation of the Standby Feedwater System requirements to the Turkey Point USFAR and applicable plant procedures is reasonable.
3.6Auxiliary Feedwater System The proposed change modifies TS 3.7.1.2, ACTION 2, such that in the event both AFW trains are inoperable and cannot be restored to OPERABILITY within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the requirement to verify the OPERABILITY of both SSGFPs prior to Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
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-251 Enclosure Page 15 of 20 commencing Unit(s) shutdown is replaced with a requirement to verify the Standby Feedwater System is capable of providing makeup to the Steam Generators prior to commencing Unit(s) shutdown.
TS 3.7.1.2, ACTION 2, requires that with both AFW trains inoperable, one train must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following which TS 3.7.1.2, ACTION 1, must be entered for a single inoperable AFW train. TS 3.7.1.2, ACTION 2, further requires that if one of the inoperable AFW trains cannot be restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the OPERABILITY of both SSGFPs must be verified and the affected Units(s) must be placed 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 in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. A footnote denoted by an asterisk (*) allows entry into HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if both Units are affected simultaneously. If the OPERABILITY of both SSGFPs cannot be verified within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, TS 3.7.1.2, ACTION 2, requires that corrective action be initiated to restore at least one AFW train to OPERABLE status as soon as possible followed by entry into TS 3.7.1.2, ACTION 1, for a single inoperable AFW train.
The proposed change replaces the requirement to verify the OPERABILITY of both SSGFPs prior to commencing Unit(s) shutdown with a requirement to verify that both SSGFPs are capable of providing makeup to the Steam Generators prior to commencing Unit(s) shutdown. The proposed change aligns TS 3.7.1.2, ACTION 2, with the Turkey Point licensing basis which describes the non-safety related Standby Feedwater System as a highly
-reliable backup to the AFW system. Verifying that both SSGFPs are capable of providing makeup to the Steam Generators provides added assurance that the non-safety related Standby Feedwater System is capable of supporting the shutdown of the affected Unit(s). As stated earlier, FPL intends to maintain the Standby Feedwater System in good operating condition with regard to appearance, structures, maintenance, etc., and relocating the Standby Feedwater System requirements to licensee control neither physically changes the system nor modifies the manner in which it will be operated and maintained. Hence , replacing the requirement to verify the OPERABILITY of both SSGFPs with a requirement to verify that both SSGFPs are capable of providing makeup to the Steam Generators prior to commencing Unit(s) shutdown in the event both AFW trains cannot be restored to OPERABILITY within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is reasonable.
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4.0REGULATORY EVALUATION
4.1Applicable Regulatory Requirements/Criteria 10 CFR 50.
36(c)(2)(ii) states that a limiting condition for operation must be included in TS for any item meeting one or more of the following four criteria:
1)installed instrumentation that is used to detect, and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary;
2)a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; 3)a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and 4)a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
10 CFR 50.36(c)(3), 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. General Design Criteria (GDC) 3 of Appendix A to 10 CFR 50, states that structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.
GDC 60 states that the nuclear power unit design shall include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during normal reactor operation, including anticipated operational occurrences. Sufficient holdup capacity shall be provided for retention of gaseous and liquid effluents containing radioactive materials, particularly where unfavorable site Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
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-251 Enclosure Page 17 of 20 environmental conditions can be expected to impose unusual operational limitations upon the release of such effluents to the environment.
GDC 63 states that appropriate systems shall be provided in fuel storage and radioactive waste systems and associated handling areas (1) to detect conditions that may result in loss of residual heat removal capability and excessive radiation levels and (2) to initiate appropriate safety actions.
GDC 64 states that means shall be provided for monitoring the reactor containment atmosphere, spaces containing components for recirculation of loss-of-coolant accident fluids, effluent discharge paths, and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences, and from postulated accidents.
1967 Proposed GDC 6 states that the reactor core with its related controls and protection systems shall be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits which have been stipulated and justified. The core and related auxiliary system designs shall provide this integrity under all expected conditions of normal operation with appropriate margins for uncertainties and for specified transient situations which can be anticipated. 1967 Proposed GDC 17 states that instrumentation and controls shall be provided as required to monitor and maintain within prescribed operating ranges essential reactor facility operating variables.
1967 Proposed GDC 18 states that monitoring and alarm instrumentation shall be provided for fuel and waste storage and associated handling areas for conditions that might result in loss of capability to remove decay heat and to detect excessive radiation levels.
1967 Proposed GDC 42 states that engineered safety features shall be designed so that the capability of these features to perform their required function is not impaired by the effects of a loss-of-coolant accident to the extent of causing undue risk to the health and safety of the public. 1967 Proposed GDC 43, states that protection against any action of the engineered safety features which would accentuate significantly the adverse after-effects of a loss of normal cooling shall be provided
.
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The proposed license amendments comply with the requirements of 10 CFR 50.36(c)(2)(ii) and 10 50.36(c)(3), and does not alter the manner in which the subject SSCs are operated and maintained consistent with GDC(s) 3, 60, 63 and 64, and 1967 Proposed GDC(s) 6, 17, 18, 42, 43 and 69. Therefore, all applicable regulatory requirements will continue to be satisfied as a result of the proposed license amendments. 4.2No Significant Hazards Consideration As required by 10 CFR 50.91(a), FPL has evaluated the proposed changes using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:
(1)Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed license amendments modify the Turkey Point TS by relocating the Explosive Gas Monitoring Instrumentation, Explosive Gas Mixture, Gas Decay Tanks and Standby Feedwater System requirements to licensee controlled documents, by relatedly modifying the AFW System requirements and by establishing a Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program. The proposed changes are administrative in nature and do not alter any plant equipment or the manner in which plant equipment is operated and maintained. All equipment limitations, applicable methodologies and surveillances are maintained by the proposed changes. In addition, the proposed changes to the AFW System requirements enhance plant safety. As such, the proposed changes cannot affect the initiator s, the likelihood or the expected outcomes of any analyzed accidents. Therefore, facility operation in accordance with the proposed changes would not involve a significant increase in the probability or consequences of an accident previously evaluated.
Turkey Point Nuclear Plant L-2017-110 Docket Nos. 50
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-251 Enclosure Page 19 of 20 (2)Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed license amendments modify the Turkey Point TS by relocating the Explosive Gas Monitoring Instrumentation, Explosive Gas Mixture, Gas Decay Tanks and Standby Feedwater System requirements to licensee controlled documents, by relatedly modifying the AFW System requirements and by establishing a Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program. The proposed changes neither install or remove plant equipment nor a lt e r any plant equipment design, con figuration, or method of operation. Hence, no new failure mechanisms are introduced as a result of the proposed changes.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
(3)Does the proposed amendment involve a significant reduction in a margin of safety? Response: No The proposed license amendments modify the Turkey Point TS by relocating the Explosive Gas Monitoring Instrumentation, Explosive Gas Mixture, Gas Decay Tanks and Standby Feedwater System requirements to licensee controlled documents, by relatedly modifying the AFW System requirements and by establishing a Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program. The proposed changes neither involve changes to safety analyses assumptions, safety limits, or limiting safety system settings nor adversely impact plant operating margins or the reliability of equipment credited in safety analyses.
Therefore, operation of the facility in accordance with the proposed changes will not involve a significant reduction in the margi n of safety.
Based upon the above analysis, FPL concludes that the proposed license amendments do not involve a significant hazards consideration, under the standards set forth in 10 CFR 50.92, "Issuance of Amendment," and accordingly, a finding of "no significant hazards consideration" is justified.
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5.0ENVIRONMENTAL CONSIDERATION
The proposed amendment modifies a regulatory requirement with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or changes an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
6.0REFERENCES
6.1NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 4.0, Volume 1, Specifications (Accession No. ML12100A222) 6.2NRC Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132) 6.3Generic Letter 95
-10, Relocation of Selected Technical Specifications Requirements Related to Instrumentation, December 15, 1995 (ADAMS Accession No.
ML031070178) 6.4NUREG-0800, Standard Review Plan, Branch Technical Position BTP 5, Postulated Radioactive Releases Due to a Waste Gas System Leak or Failure, Revision 3, March 2007 (ADAMS Accession No. ML070730056)
ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION PAGES (MARKUP)
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ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION BASES PAGES (MARKUP)
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