ML12251A249

Turkey Point, Units 3 and 4, License Amendment Request No. 224 Regarding Technical Specification 3/4.6.2.3 - Recirculation Ph Control System and Natb Basket Minimum Loading Requirement

ML12251A249
Person / Time
Site:	Turkey Point
Issue date:	09/06/2012
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2012-314, TAC ME1624, TAC ME1625
Download: ML12251A249 (11)

Text

L-2012-31410 CFR 50.90SEP 0,6 2012FIPLoU. S. Nuclear Regulatory CommissionAttn.: Document Control DeskWashington, D.C. 20555-0001Re: Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment Request No. 224 Regarding Technical Specification 3/4.6.2.3 -Recirculation pH Control System and NaTB Basket Minimum Loading RequirementReference:(1) J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 -"Issuance of AmendmentsRegarding Alternative Source Term (TAC Nos. ME1624 and ME1625)," Accession No.ML1 10800666, June 23, 2011.On June 23, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment Nos. 244and 240 to Renewed Facility Operating License Nos. DPR-31 and DPR-41 for the Turkey PointNuclear Plant, Units Nos. 3 and 4, respectively, with supporting Safety Evaluation Report (SER)regarding the Alternative Source Term (AST) [Reference 1].The Recirculation pH Control System is a passive safeguard consisting often stainless steel wiremesh baskets located in the containment basement and containing a total of at least 11,061 lbm ofsodium tetraborate decahydrate (NaTB). This passive system assures that there is sufficient NaTBavailable in the containment to ensure a sump pH greater than 7.0 at the onset of the recirculationphase of a postulated loss-of-coolant accident (LOCA). The proposed license amendment requestwill reduce the minimum NaTB basket loading to 7,500 ibm in order to lessen the long term sumppH profile, recover design margin, and facilitate NaTB basket loading and maintenance activities.Description of the proposed TS change with supporting justification and a no significant hazardsdetermination and environmental consideration are provided in the Enclosure to this letter.The Turkey Point Plant Nuclear Safety Committee (PNSC) has reviewed the proposed licenseamendments. The proposed TS change has been evaluated in accordance with 10 CFR 50.91 (a)(1),using the criteria in 10 CFR 50.92(c). FPL has determined that the proposed TS change does notinvolve a significant hazards consideration.The proposed license amendments change requirements with respect to the use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20. FPL has determinedthat the proposed amendments involve no significant increase in the amounts and no significantchange in the types of any effluents that may be released offsite, and no significant increase inindividual or cumulative occupational radiation exposure. Therefore, FPL has concluded that theproposed amendments meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9)and, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmentalassessment need not be prepared in connection with issuance of the amendments.This letter contains no new commitments and no revisions to existing commitments.In accordance with 10 CFR 50.91(b)(1), a copy of this letter is being forwarded to the StateDesignee of Florida.Florida Power & Light Company9760 SW 344 St., Florida City, FL 33035 Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251L-2012-314Page 2 of 2Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto,Licensing Manager, at (305) 246-7327.I declare under penalty of perjury that the foregoing is true and correct.Executed on September 6 , 2012.Very truly yours,Michael KileySite Vice PresidentTurkey Point Nuclear PlantEnclosurecc: USNRC Regional Administrator, Region IIUSNRC Project Manager, Turkey Point Nuclear PlantUSNRC Senior Resident Inspector, Turkey Point Nuclear PlantMs. Cindy Becker, Florida Department of HealthFlorida Power & Light Company9760 SW 344 St., Florida City, FL 33035 Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment Request No. 224L-2012-314EnclosurePage I of 9EnclosureTurkey Point Units 3 and 4License Amendment Request No. 224Regarding Technical Specification 3/4.6.2.3-Recirculation pH Control System andNaTB Basket Minimum Loading Requirement Turkey Point Units 3 and 4 L-2012-314Docket Nos. 50-250 and 50-251 EnclosureLicense Amendment Request No. 224 Page 2 of 9TABLE OF CONTENTSLICENSE AMENDMENT REQUEST NO. 224REGARDING TECHNICAL SPECIFICATION 3/4.6.2.3-RECIRCULATION PH CONTROL SYSTEM ANDNATB BASKET MINIMUM LOADING REQUIREMENTSECTION TITLE PAGECover Sheet 1--- Table of Contents 21.0 Purpose and Scope 32.0 Background Information 33.0 Description of Proposed Changes 34.0 Basis/Justification of Proposed Changes 45.0 List of Commitments 46.0 Conclusion 47.0 No Significant Hazards Determination 58.0 Environmental Consideration 79.0 Summary of Results 810.0 References 811.0 Tables & Figures 9 Turkey Point Units 3 and 4 L-2012-314Docket Nos. 50-250 and 50-251 EnclosureLicense Amendment Request No. 224 Page 3 of 91.0 Purpose and ScopeFlorida Power and Light Company (FPL) proposes to amend Renewed Facility OperatingLicenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 by reducing the minimumrequired sodium tetraborate decahydrate (NaTB) basket loading from 11,061 Ibm to 7,500Ibm in Technical Specification (TS) 3/4.6.2.3. This change, when implemented, will lessenthe long term sump pH profile while ensuring sump pH remains above 7.0 throughout therecirculation phase of a loss of coolant accident (LOCA), recover design margin to upperpH limits, and facilitate NaTB basket loading and maintenance activities.2.0 Background InformationOn June 23, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued AmendmentNos. 244 to DPR-31 and 240 to DPR-41 with supporting Safety Evaluation Report (SER)regarding the Alternative Source Term (AST) [Reference 1]. The amendments includednew TS 3/4.6.2.3, Recirculation pH Control System. The Recirculation pH Control Systemis a passive safeguard consisting of ten stainless steel wire mesh baskets located in thecontainment basement with sufficient NaTB to maintain the sump pH greater than 7.0throughout the LOCA recirculation phaseThe current specified value in TS 3/4.6.2.3 for the minimum total NaTB mass in these tenbaskets is 11,061 lbm. This minimum value was provided in the original AST LicenseAmendment Request (LAR No. 196) [Reference 2]. Subsequent calculations demonstratedthat the minimum required NaTB mass to achieve a sump pH of>7.0 is actually as low as6,427 Ibm. Although the results of these revised calculations were submitted in response to aNRC Request for Additional Information (RAI) via letter L-2010-082 dated April 28, 2010[Reference 3], the original proposed TS value was not changed at that time.Parametric analyses were conducted for maximum sump pH profiles assuming realistic time-dependent containment sump temperatures and maximum NaTB dissolution rates based onvarious reduced basket loading options. With full baskets (15,816 lbm NaTB), the peak pHis 8.006. With the fill level reduced to 7,500 lbm, the peak pH drops to about 7.680.As both the AST and EPU license amendments for Units 3 and 4 have been issued, and fullyimplemented for Unit 3, FPL proposes to reduce the current TS 3/4.6.2.3 minimum requiredNaTB mass from 11,061 lbm to 7,500 Ibm, leaving more than 1000 Ibm of margin to theanalyzed minimum of 6,427 lbm. This change reduces the basket loading requirement, andwhen implemented, will reduce the long-term post-LOCA sump pH profile, allow recoveryof design margin to upper pH limits and facilitate basket maintenance activities whileassuring sump pH remains above 7.0 throughout the post-LOCA recirculation phase.3.0 Description of Proposed ChangesThe proposed TS change involves TS 3/4.6.2.3 only. In order to provide a more specificdescription of the proposed change, a TS mark-up is attached and a description is providedbelow with a briefjustification.

Turkey Point Units 3 and 4 L-2012-314Docket Nos. 50-250 and 50-251 EnclosureLicense Amendment Request No. 224 Page 4 of 94.0 Basis/Justification for the Proposed Changes4.1 Changes to the PTN Technical Specifications4.1.1 Technical Specification Surveillance Requirement 4.6.2.3Recirculation pH Control SystemCurrent TSThe Recirculation pH Control System shall be demonstrated OPERABLE:a. At least once per 18 months by2. Collectively contain> 11061 pounds (227 cubic feet) of sodiumtetraborate decahydrate, or equivalent.Proposed TSThe Recirculation pH Control System shall be demonstrated OPERABLE:a. At least once per 18 months by2. Collectively contain > 7500 pounds (154 cubic feet) of sodiumtetraborate decahydrate, or equivalent.Basis for the Change: Previous calculations have shown that as little as 6,427 Ibmof NaTB is sufficient to bring the containment sump pH to greater than 7.0 at theonset of the post-LOCA containment spray recirculation phase. The calculationsconsidered both the minimum post-LOCA containment sump pH at the time ofcontainment spray recirculation to support radiological analyses and maximumpost-LOCA containment sump pH over the course of the accident. The 7,500 Ibmcase satisfies the minimum sump pH requirement at the onset of the recirculationphase, and when implemented, will reduce the long-term sump pH profile, allowrecovery of design margin to upper pH limits and facilitate NaTB basket loadingand maintenance activities. A markup of the proposed TS change is attached.5.0 List of CommitmentsNone6.0 ConclusionThe proposed amendments will reduce the minimum required NaTB basket loadingfrom 11,061 Ibm to 7,500 Ibm in Technical Specification (TS) 3/4.6.2.3. This change,when implemented, will lessen the long term sump pH profile, allow recovery of designmargin to upper pH limits and facilitate NaTB basket loading and maintenance activities.

Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment Request No. 224L-2012-314EnclosurePage 5 of 97.0 No Significant Hazards DeterminationThe Commission has provided standards in 10 CFR 50.92(c) for determining whether asignificant hazards consideration exists. A proposed amendment to an operating licensefor a facility involves no significant hazard if operation of the facility in accordance withthe proposed amendment would not: (1) involve a significant increase in the probabilityor consequences of an accident previously evaluated; or (2) create the possibility of a newor different kind of accident from any accident previously evaluated; or (3) involve asignificant reduction in a margin of safety.The proposed license amendments to Renewed Facility Operating Licenses DPR-31 forTurkey Point Unit 3 and DPR-41 for Turkey Point Unit 4 will reduce the minimumrequired NaTB basket loading from 11,061 Ibm to 7,500 Ibm in TS 3/4.6.2.3. This change,when implemented, will lessen the long term sump pH profile, allow recovery of designmargin to upper pH limits and facilitate NaTB basket loading and maintenance activities.FPL has reviewed this proposed license amendment for FPL's Turkey Point Units 3 and 4and determined that its adoption would not involve a significant hazards consideration.The bases for this determination are:The proposed amendments do not involve a significant hazards consideration forthe following reasons:1. Do the proposed amendments involve a significant increase in the probability orconsequences of an accident previously evaluated?No. The proposed amendments do not affect any precursors to any accident previouslyevaluated. The proposed amendments do affect the passive recirculation pH controlsystem consisting of ten stainless steel baskets loaded with NaTB but do not adverselyaffect the system performance or its contribution to the mitigation strategy for a designbasis large break loss of coolant accident (LBLOCA). The proposed TS change, whenimplemented, will reduce the minimum required NaTB basket loading from 11,061 Ibmto 7,500 Ibm in TS 3/4.6.2.3. This change will also lessen the long term sump pHprofile, allow recovery of design margin and facilitate NaTB basket loading andmaintenance activities.Therefore, the proposed amendments do not involve a significant increase in theprobability or consequences of an accident previously evaluated.2. Do the proposed amendments create the possibility of a new or different kind ofaccident from any accident previously evaluated?No. The proposed amendments do not directly or indirectly affect any recognizedaccident initiators. The proposed amendments do affect the passive recirculation pHcontrol system consisting often stainless steel baskets loaded with NaTB but do notadversely affect the system performance or its contribution to the mitigation strategyfor a design basis LBLOCA. The proposed TS change, when implemented, will reducethe minimum required NaTB basket loading from 11,061 Ibm to 7,500 Ibm in TS3/4.6.2.3. This change will lessen the long term sump pH profile, allow recovery ofdesign margin to upper pH limits and facilitate NaTB basket loading and maintenanceactivities while it continues to ensure that the design basis minimum sump pH of 7.0 ismaintained throughout the recirculation phase of a LOCA.

Turkey Point Units 3 and 4 L-2012-314Docket Nos. 50-250 and 50-251 EnclosureLicense Amendment Request No. 224 Page 6 of 9Therefore, the proposed amendments do not create the possibility of a new ordifferent kind of accident from any accident previously evaluated.3. Do the proposed amendments involve a significant reduction in the margin of safety?No. The proposed amendments will reduce the minimum required NaTB basket loadingfrom 11,061 lbm to 7,500 lbm in TS 3/4.6.2.3. This change, when implemented, will alsolessen the long term sump pH profile, allow recovery of design margin to upper pH limitsand facilitate NaTB basket loading and maintenance activities. This change continues toassure that containment sump pH reaches 7.0 by onset of containment spray recirculationphase in response to a LBLOCA and lessens the peak and long-term sump pH such thatpost-accident chemical precipitate generation and the potential for stainless steel stresscorrosion cracking is reduced.Therefore, the proposed amendments do not involve a significant reduction in themargin of safety.Based on the above discussion, FPL has determined that the proposed amendments do notinvolve a significant hazards consideration.

Turkey Point Units 3 and 4 L-2012-314Docket Nos. 50-250 and 50-251 EnclosureLicense Amendment Request No. 224 Page 7 of 98.0 Environmental Consideration10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatoryactions eligible for categorical exclusion from performing an environmental assessment.A proposed amendment of an operating license for a facility requires no environmentalassessment, if the operation of the facility in accordance with the proposed amendmentdoes not: (1) involve a significant hazards consideration, (2) result in a significant changein the types or significant increase in the amounts of any effluents that may be releasedoffsite, and (3) result in a significant increase in individual or cumulative occupationalradiation exposure.FPL has reviewed this LAR and determined that the proposed amendments meet theeligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to10 CFR 51.22(b), no environmental impact statement or environmental assessment needsto be prepared in connection with the issuance of this amendment. The basis for thisdetermination follows.BasisThis change meets the eligibility criteria for categorical exclusion set forth in10 CFR 51.22(c)(9) for the following reasons:1. As demonstrated in the 10 CFR 50.92 evaluation, the proposed amendment does notinvolve a significant hazards consideration.2. The proposed amendment does not result in a significant change in the types or increasein the amounts of any effluents that may be released offsite. The proposed amendmentsdo not adversely affect the post-LOCA containment source term since the minimumsump pH is maintained above 7.0 throughout the recirculation phase. The proposedamendments do not adversely affect the fuel, reactor coolant system components andpiping, or the containment building and its penetrations. The proposed amendments donot directly or indirectly affect effluent discharges.3. The proposed amendment does not result in a significant increase in individual orcumulative occupational radiation exposure. The proposed amendments do notadversely affect the post-LOCA containment source term since the minimum sump pHcontinues to be maintained above 7.0 throughout the recirculation phase. The proposedamendments do not adversely affect the fuel, reactor coolant system components andpiping, the containment or its penetrations. The proposed amendments do not directlyor indirectly affect the radiological source terms.

Turkey Point Units 3 and 4 L-2012-314Docket Nos. 50-250 and 50-251 EnclosureLicense Amendment Request No. 224 Page 8 of 99.0 Summary of ResultsThe proposed amendments will reduce the minimum required NaTB basket loadingfrom 11,061 Ibm to 7,500 Ibm in Technical Specification (TS) 3/4.6.2.3. This change,when implemented, will lessen the long term sump pH profile, allow recovery of designmargin to upper pH limits and facilitate NaTB basket loading and maintenance activities.10.0 Reference1. J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 -"Issuance ofAmendments Regarding Alternative Source Term (TAC Nos. ME 1624 andME1625)," Accession No. ML110800666, June 23, 2011.2. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2009-133), "LicenseAmendment Request 196: Alternative Source Term and Conforming Amendment,"Accession No. ML092050277, June 25, 2009.3. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-082), "Supplementto License Amendment Request 196 (ADAMS Accession No. ML092050112) -Revised Summary of Turkey Point Sump pH Calculation Inputs, Assumptions,Methodology, and Results," Accession No. ML 101200063, April 28, 2010.

Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251License Amendment Request No. 224L-2012-314EnclosurePage 9 of 9CONTAINMENT SYSTEM$3/46.2.3 RECIRCULATION OH CONTROL SYSTEMLIMITINQcQrNDITION FQ I _Pg___.4JTQN ..........3.6.2.3 The Recirculatlon pH Control System shall be OPERABLE.APPLICABILITY: MODES 1, 2, 3, and 4.ACTION:With the Recirculatlon pH Control System Inoperable, restore the buffeting agent to OPERABLE status wlitn 72hours 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 in COLD SHUTDOWN within the next 72hours,iLANCE_ _1F.QU 4.6.2.3 The Recircuation pH-I Control System shall be demonstrated OPERABLE:a. At least once per 18 months by1. Verifyng that the buffering agent baskets are in place and intact:2. Collectively contain > 11061 poun.ds (227 wbic fee.t) of sodium tetraborate decahydrae,or equvalent -17500 pounds (154 cubic feet)TURKEY POINT -UNITS 3 & 4 3/46-15 AMENDMENT NOS. 244 AND 2401