ML16292A716

Turkey Point 3 and 4 RAI for LAR 242 Snubber TSs (CACs MF7557/58)

ML16292A716
Person / Time
Site:	Turkey Point
Issue date:	10/18/2016
From:	Klett A L Plant Licensing Branch II
To:	Guth M Florida Power & Light Co
References
MF7557, MF7558
Download: ML16292A716 (2)

Text

1 NRR-PMDAPEm Resource From: Klett, Audrey Sent: Tuesday, October 18, 2016 9:18 AM To:'Mitch.Guth@fpl.com' Cc: Czaya, Paul (Paul.Czaya@fpl.com); 'Hanek, Olga' (Olga.Hanek@fpl.com)

Subject:

Turkey Point 3 and 4 RAI for LAR 242 Snubber TSs (CACs MF7557/58)

Hi Mitch, By letter L-2016-055 dated April 4, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16110A266), Florida Power & Light Company (FPL, the licensee) submitted License Amendment Request (LAR) 242 for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point 3 and 4). The licensee requested to revise the Technical Specifications (TSs) for snubbers to conform to the licensee's Snubber Testing Program. By electronic mail dated August 11, 2016 (ADAMS Accession No. ML16228A004), the U.S. Nuclear Regulatory Commission (NRC) staff request ed additional information to complete its review of the LAR. By letter dated September 1, 2016 (A DAMS Accession Number ML16260A399), the licensee responded to the request. After reviewing the licensee's response, the staff determined that it needs additional information to complete its review. The staff's request for additional information (RAI) is as follows, continued sequentially from the RAI in the email dated August 11, 2016. As discussed with Mr. Paul Czaya of the licensee's staff, the NRC staff is requesting the licensee to respond to the RAI on or by November 14, 2016.

RAI 7 In its application dated April 4, 2016, the licensee requested, in part, the following changes to Surveillance Requirement (SR) 4.7.6:

4.7.6 Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection Snubber Testing Program in Specification 6.8.4.m in addition to the requirements of Specification 4.0.5.

In its RAI dated August 11, 2016, the NRC requested (via RAI 3) the licensee to clarify the use of TS 4.0.5 along with newly added TS 6.8.4.m and to confirm whether these TSs are duplicative and/or if TS 6.8.4.m encompasses all requirements of TS 4.0.5. In its letter dated September 1, 2016, the licensee responded to RAI 3 stating that TS 6.8.4.m and TS 4.0.5 are duplicative with respect to snubbers and that the licensee has proposed to delete reference to TS 4.0.5 in TS 4.7.6 via a separate license amendment application.

In Attachment 3 to its application dated April 4, 2016, the licensee provided the Turkey Point Nuclear Plant Unit 3 and 4 Snubber Testing Program Plan, which is based on the ASME OM Code 2004 Edition with 2005 and 2006 Addenda. In TS 4.0.5, the ASME OM Code is only used for inservice testing of pumps and valves; it is not applicable to snubbers. Therefore, TS 6.8.4.m and TS 4.0.5 do not appear to be duplicative with respect to snubbers, and the "in addition to the requirements of Specification 4.0.5" no longer appears to be applicable to

this SR. The staff requests the licensee to revise the application by proposing to delete "in addition to the requirements of Specification 4.0.5," or to provide additional justification for retaining this phrasing in Specification 4.7.6.

Audrey Klett

Project Manager NRR/DORL/LPLII-2

301-415-0489

Hearing Identifier: NRR_PMDA Email Number: 3106 Mail Envelope Properties (Audrey.Klett@nrc.gov20161018091800)

Subject:

Turkey Point 3 and 4 RAI for LAR 242 Snubber TSs (CACs MF7557/58) Sent Date: 10/18/2016 9:18:07 AM Received Date: 10/18/2016 9:18:00 AM From: Klett, Audrey Created By: Audrey.Klett@nrc.gov Recipients: "Czaya, Paul (Paul.Czaya@fpl.com)" <Paul.Czaya@fpl.com>

Tracking Status: None "'Hanek, Olga' (Olga.Hanek@fpl.com)" <Olga.Hanek@fpl.com>

Tracking Status: None "'Mitch.Guth@fpl.com'" <Mitch.Guth@fpl.com> Tracking Status: None

Post Office: Files Size Date & Time MESSAGE 2926 10/18/2016 9:18:00 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received: