L-2020-083, Supplemental Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Re

Supplemental Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Re

ML20142A275
Person / Time
Site:	Turkey Point
Issue date:	05/21/2020
From:	Stamp B Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2020-083
Download: ML20142A275 (14)

Text

May 21, 2020 L-2020-083 10 CFR 50.90 Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE:

Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating Licenses DPR-31 and DPR-41 Supplemental Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements

References:

1)

Florida Power & Light Company Letter L-2019-192, License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements, November 4, 2019 (ADAMS Accession No. ML19315A003)

2)

NRR E-Mail Capture, Request for Additional Information Regarding Containment Radiation Monitoring Instrumentation, Florida Power & Light Company, Turkey Point Nuclear Generating Unit Nos. 3 and 4, Docket Nos. 50-250 and 50-251, March 20, 2020 (ADAMS Accession No. ML20084G562)

3)

Florida Power & Light Company Letter L-2020-071, Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements, April 16, 2020 (ADAMS Accession No. ML20107H232)

In Reference 1, Florida Power & Light Company (FPL) submitted license amendment request (LAR) 270 for Turkey Point Units 3 and 4. The proposed license amendments modify the Turkey Point Technical Specifications (TS) by modifying the containment atmosphere radioactivity monitoring, containment ventilation isolation and Reactor Coolant System (RCS) leakage detection system requirements.

In Reference 2, the NRC requested additional information necessary to complete its review. In Reference 3, FPL provided its response to the request for additional information. During subsequent discussion with the NRC, it was determined that information supplementing the response in Reference 3 was necessary.

The enclosure to this letter provides supplemental information supporting FPLs response to the request for additional information (RAI). In addition, and as discussed in the enclosure, FPL is modifying the TS changes proposed in Reference 1. Attachment 1 to enclosure provides the existing TS pages marked up to show the proposed change. Attachment 2 provides the existing TS Bases pages marked up to show the proposed change. The TS and TS Bases marked up pages supersede the corresponding pages provided in Reference 1. 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 license amendments.

The supplements included in this letter provide additional information which clarifies the application, do not expand the scope of the application as originally noticed, and should not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 This letter contains no regulatory commitments.

L-2020-083 Page 2 of 2 Should you have any questions regarding this submission, please contact Mr. Robert Hess, Turkey Point Licensing Manager, at 305-246-4112.

I declare under penalty of perjury that the foregoing is true and correct.

t!

Executed on the ~

day of May, 2020.

Sincerely, A@&,"'~

Brian Stamp Site Director, Turkey Point Nuclear Plant Enclosure - Supplemental Response to NRG Request for Additional Information cc:

USN RC Regional Administrator, Region II USN RC Project Manager, Turkey Point Nuclear Plant USN RC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health

Turkey Point Nuclear Plant L-2020-083 Docket Nos. 50-250 and 50-251 Enclosure Page 1 of 12 Enclosure FPL Supplemental Response to NRC Request for Additional Information (RAI) Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements

Turkey Point Nuclear Plant L-2020-083 Docket Nos. 50-250 and 50-251 Enclosure Page 2 of 12 In an e-mail memorandum dated March 20, 2020 (Reference 1), the NRC staff of the Office of Nuclear Reactor Regulation requested the additional information identified below regarding Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements (Reference 2). In Reference 3, FPL provided its response to the request for additional information (RAI). During subsequent discussion with the NRC, it was determined that information supplementing FPLs response to RAI #3 and RAI #4 of Reference 3 were necessary. The RAIs, FPLs RAI response and FPLs supplemental response to the RAIs are provided below:

RAI #3 (Reference 2)

Section 11.2.3, Radiation Monitoring System of the TPN Updated Final Safety Analysis Report (UFSAR) includes a description of the Process Radiation Monitoring System. The UFSAR states that the function of these monitors includes measuring radioactivity in the containment and to ensure that the release rate during purging is maintained below specified limits. Section 11.2.3 of the UFSAR states that the high radiation level for each channel initiates closure of the containment purge supply and exhaust duct valves.

The UFSAR further states that the alarm setpoints for the R-11 and R-12 containment radiation monitors are derived from Table 3.3-3 of the TS and set in accordance with the methodology and parameters from the TPN ODCM.

Section 3.3 of the Enclosure to the submittal discusses that the containment purge supply and exhaust duct valves will be maintained in an administratively-controlled closed position or that a blind flange will be installed in Modes 1-4. Therefore, the R-11 and R-12 monitors will no longer function to initiate closure of the containment purge supply and exhaust valves. As a result, the current TS alarm/trip setpoints should no longer be necessary to ensure that the release rate during purging is maintained below specified limits, making the setpoints immaterial with respect to effluent control during purging.

However, the NRC staff identified that the R-11 and R-12 monitors remain credited for identification of RCS Leakage per TS 3/4.4.6, Reactor Coolant System Leakage. Describe how the existing setpoints continue to support detection of RCS leakage at the operational limits identified in the TS.

FPL Response (Reference 3):

The allowable range and alarm/trip setpoints for the R-11 and R-12 instrumentation will continue to be verified for the ESFAS Containment Ventilation Isolation function, but only as they relate to the containment instrument air bleed penetrations. High radiation levels at the R-11 and R-12 detectors initiate closure of the containment instrument air bleed valves and this ESFAS function will continue to be demonstrated, in part, by verifying the R-11/R-12 alarm/trip setpoints in accordance with TS 3.3-2, Table 4.3-2, Functional Unit (FU) 3.c.4. In addition, the Radiation Monitoring for Plant Operation functional surveillance requirements of TS 3.3-3, Table 4.3-3, FU 1.a, remain applicable, which also require R-11/R-12 setpoint verification. However, since the containment purge supply and exhaust penetration isolation valves will be administratively sealed closed and deactivated in Modes 1 - 4, Table 4.3-2, FU 3.c.4, would no longer apply to the containment purge penetration isolation instrumentation and the R-11/R-12 setpoints need not be re-verified for this function.

Regarding RCS leakage detection, the current alarm/trip setpoints for R-11/R-12 are unchanged by the proposed change. Only the instrument measurement units are changed, i.e. by numerical conversion from CPM to µCi/cc. As stated above, the alarm/trip setpoints for R-11/R-12 will continue to be verified as specified in Table 4.3-2, FU 3.c.4 for the ESFAS containment instrument air bleed isolation function, and Table 4.3-3, FU 1.a, for the Radiation Monitoring for Plant Operations function. Hence, no changes are proposed to the RCS leakage detection capabilities of R11 and R-12 since the alarm/trip setpoints are unchanged by the proposed change. The existing R11 and R-12 setpoints will continue to support RCS leakage detection at the TS identified operational limits.

Turkey Point Nuclear Plant L-2020-083 Docket Nos. 50-250 and 50-251 Enclosure Page 3 of 12 FPL Supplemental Response:

To be clear, the current R-11/R-12 instrument readouts are expressed in Ci/cc (see image below displaying R-12 reading). However, the TS specified allowable ranges and setpoints are expressed in CPM. The proposed change modifies the R-11/R-12 requirements by converting the allowable range and setpoint measurement units specified in the TS from CPM to Ci/cc. No changes are proposed to the R-11/R-12 instruments, the instrument readouts or any applicable regulatory requirements other than the conversion of the TS specified measurement units from CPM to Ci/cc.

Regarding RCS leakage detection, TS 3/4.4.6 specifies the requirements for RCS leakage, including the allowable limits for identified and unidentified RCS leakage. TS 3/4.4.6 requires the R-11/R-12 instruments to be operable but does not specify the R-11/R-12 alarm and trip setpoints since RCS leakage at the TS 3/4.4.6 specified limits occurs at containment radiological levels well below the R-11/R-12 alarm and trip setpoints. The ability to detect RCS leakage at the TS 3/4.4.6 specified limits is a design feature of the R-11/R-12 instruments sensitivity rather than the setpoints, an attribute unchanged by the proposed change to the TS specified allowable range and setpoint measurement units. Moreover, the TS 3/4.4.6 requirements reflect that successful RCS leakage detection is not wholly reliant on R-11/R-12 but also requires containment sump level and RCS makeup water monitoring, as well as RCS visual inspection and audible detection. Along with these other techniques, RCS leakage detection at the TS 3/4.4.6 operational limits remains assured since the proposed change to the R-11/R-12 setpoints specified in TS 3/4.3-2 and TS 3/4.3-3 do not affect this functional capability. The R-11/R-12 instruments will also continue to satisfy the Turkey Point licensing bases for leak-before-break (i.e. 1 gpm within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) as currently stated in Chapter 6.5.1 of the Turkey Point UFSAR. The R-11/R-12 instrument capabilities at the leak-before-break required sensitivity were validated in uCi/cc and the proposed change to the TS specified allowable range and setpoint measurement units do not affect this functional capability for early RCS leakage detection. Hence, the proposed change will not adversely affect the capability of the R-11/R-12 instruments to satisfy their licensing basis for RCS leakage detection.

Turkey Point Nuclear Plant L-2020-083 Docket Nos. 50-250 and 50-251 Enclosure Page 4 of 12 RAI #4 (Reference 2):

Section 3.3.3 discusses the proposed revisions to the purge valve TS SRs. This proposed change essentially creates two separate conditions that, in accordance with 10 CFR 50.36, need to be verified and maintained via surveillance requirements. The first condition is when the valves are administratively sealed closed and deactivated and the second condition is when the associated penetration(s) are isolated by blind flange. In addition, the licensee is proposing the addition of a footnote to TS 3/4.6.1.7, which states:

[p]erformance of SR 4.6.1.7.1 and SR 4.6.1.7.2 are not required when the associated purge supply and/or exhaust penetration is isolated by blind flange.

Discuss how the proposed TS SRs in SR 4.6.1.7 demonstrate operability of each containment purge supply and exhaust isolation valve, when the associated purge supply and/or exhaust penetration(s) is isolated by a blind flange.

FPL Response (Reference 3):

SR 4.6.1.7.1 verifies that each containment purge supply and exhaust isolation valves is either seal closed or open in accordance with LCO 3.6.1.7.a. SR 4.6.1.7.2 verifies that each containment purge isolation valve measured leakage rate is within limit. The SRs assure the containment purge penetration isolation and leak tightness functions assumed in plant safety analyses remain valid.

When SR 4.6.1.7.1 or SR 4.6.1.7.2 cannot be met, installation of a blind flange serves to replace the penetration isolation and leak tightness functions normally performed by the containment purge isolation valves. The flange features double O-rings, which provide the requisite redundant barrier isolation for the containment purge penetration. The blind flange is bolted to the purge penetration inlet or outlet flange such that once secured in place, its position cannot be inadvertently altered.

The flange would be subject to satisfactory Type-B local leakage rate testing in accordance with 10 CFR 50, Appendix J, either before restoring the containment purge penetration to operability or prior to entering the applicable MODES, as appropriate. Hence, the proposed LCO would be met for the non-complying containment purge penetration upon installation of the blind flange, subject to satisfactory Type-B testing. As such, containment purge isolation valve operability need not be verified for the affected containment purge penetration since the penetration isolation and leak tightness functions assumed in plant safety analyses are assured by the blind flange. Moreover, the containment purge isolation valves would no longer satisfy 10 CFR 50.36(c)(2)(ii), Criterion 3, and thereby would no longer be subject to the surveillance requirements of 10 CFR 50.36(c)(3).

TS LCO 4.0.1 states that surveillance requirements shall be met during the operational MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual surveillance requirement. (LCO 4.0.1 is consistent with SR 3.0.1 of NUREG-1431 (Reference 6.5)). 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. The proposed change modifies SR 4.6.1.7.1 and SR 4.6.1.7.2 by adding a footnote which exempts SR performance whenever the associated penetration is isolated by a blind flange. The proposed change would not contravene LCO 4.0.1 since exceptions to SR performance are allowed where otherwise stated in the individual surveillance requirements.

The proposed change would not contravene 10 CFR 50.36(c)(3) since the proposed LCO 3.6.1.7 provides two conditions for satisfying the LCO and specifies that only one condition need be met.

FPL Supplemental Response:

In Reference 2, FPL proposed modifying SR 4.6.1.7.1 and SR 4.6.1.7.2 by adding a footnote exempting SR performance whenever the associated containment purge penetration is isolated by blind flange. In this supplement, FPL proposes instead to apply the footnote solely to SR 4.6.1.7.1 and modify SR 4.6.1.7.2 by adding a new surveillance requirement applicable to containment purge

Turkey Point Nuclear Plant L-2020-083 Docket Nos. 50-250 and 50-251 Enclosure Page 5 of 12 penetrations isolated by blind flange. The modified SR 4.6.1.7.2 would require verification that the measured leakage rate is within limit in accordance with the Containment Leakage Rate Testing Program [of TS 6.8.4.h] for each containment purge penetration isolated by blind flange. The newly proposed SR 4.6.1.7.2 would assure satisfactory Type-B leak testing of the blind flange prior to restoring the containment purge penetration to operability or entering the applicable MODES, as appropriate. Maintaining the proposed footnote exempting SR performance of SR 4.6.1.7.1 is appropriate since once secured in place, the blind flange(s) cannot be inadvertently altered, thereby negating the need for periodic position verification. The proposed change aligns with the proposed change to LCO 3.6.1.7 allowing isolation of the containment purge penetration(s) by blind flange while maintaining the existing SR 4.6.1.7.2 requirement to verify purge valve measured leakage within limit whenever the purge valves are relied on for containment purge penetration isolation.

to the enclosure provides the existing TS page marked up to show the changes proposed in this supplemental RAI response. Attachment 2 provides the existing TS Bases page marked up to show the proposed changes. The TS and TS Bases marked up pages supersede the corresponding pages provided in Reference 2.

REFERENCES

1)

NRR E-Mail Capture, Request for Additional Information Regarding Containment Radiation Monitoring Instrumentation, Florida Power & Light Company, Turkey Point Nuclear Generating Unit Nos. 3 and 4, Docket Nos. 50-250 and 50-251, March 20, 2020 (ADAMS Accession No. ML20084G562)

2)

Florida Power & Light Company Letter L-2019-192, License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements, November 4, 2019 (ADAMS Accession No. ML19315A003)

3)

Florida Power & Light Company Letter L-2020-071, Response to Request for Additional Information Regarding License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements, April 16, 2020 (ADAMS Accession No. ML20107H232)

Turkey Point Nuclear Plant L-2020-083 Docket Nos. 50-250 and 50-251 Enclosure Page 6 of 12 ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION PAGE (MARKUP)

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administratively sealed closed and deactivated within limit

• Performance of SR 4.6.1.7.1 is not required when the associated purge supply and/or exhaust penetration is isolated by blind flange.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Add new asterisk (*)

administratively sealed closed and deactivated or the associated penetration(s) shall be isolated by blind flange.

Specification 3.6.1.7 not met, comply with Specification 3.6.1.7, or For each containment purge penetration isolated by a blind flange, the measured leakage rate shall be verified within limit in accordance with the Containment Leakage Rate Testing Program.

Turkey Point Nuclear Plant L-2020-083 Docket Nos. 50-250 and 50-251 Enclosure Page 8 of 12 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION BASES PAGE (MARKUP)

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TURKEY POINT PLANT Procedure No.

0-ADM-536 ADMINISTRATIVE PROCEDURE Revision No.

39 SAFETY RELATED INFORMATION USE

Title:

TECHNICAL SPECIFICATION BASES CONTROL PROGRAM Responsible Department: LICENSING Special Considerations:

FOR INFORMATION ONLY Before use, verify revision and change documentation (if applicable) with a controlled index or document.

DATE VERIFIED_________ INITIAL__________

Revision Approved By Approval Date UNIT #

DATE DOCT PROCEDURE 0

Bob Tomonto 07/09/12 DOCN 0-ADM-536 SYS STATUS COMPLETED 39 Bob Hess 02/25/20 REV 39

1. OF PGS FPL

REVISION NO.:

PROCEDURE TITLE:

PAGE:

39 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 89 of 236 PROCEDURE NO.:

0-ADM-536 TURKEY POINT PLANT ATTACHMENT 2 Technical Specification Bases (Page 70 of 217) 3/4.3.1 & 3/4.3.2 (Continued)

Item 5 of Table 3.3-2 requires that two trains of feedwater isolation actuation logic and relays be OPERABLE in MODES 1, 2 and 3.

Operability requires:

Isolation of both the normal feedwater branch and the bypass branch lines through automatic closure of the main feedwater and main feedwater bypass flow control valves (FCV) or automatic closure of the feedwater isolation valves (FIV) during a safety injection actuation signal or high-high steam generator water level signal, and Two independent trains of Automatic Actuation Logic and actuation relays.

In the event that maintenance and/or in-service testing is required on a feedwater regulating valve in Mode 1, 2 and 3, the above requirements can be met by closing the isolation valve upstream of the affected feedwater regulating valve, administratively controlling the position of the isolation valve, and controlling feedwater flow with an OPERABLE feedwater regulating valve (main or bypass).

For Table 3.3-2, Functional Unit (FU) 3.c.4, simultaneous inoperability of the Containment Atmosphere Particulate (R-11) and Gaseous (R-12) Radioactivity Monitoring Systems impact the Containment Ventilation Isolation (TS 3.3.2), Containment Radiation Monitoring for Plant Operations (TS 3.3.3.1), and RCS Leakage Detection (TS 3.4.6.1) functions. With R-11 and R-12 both inoperable, the following ACTIONS must be entered:

ACTION 16 of TS 3.3-2, Table 3.3-2, FU 3.c.4 ACTION 26 (or ACTION 27 for Modes 5 and 6) of TS 3.3.3.1, Table 3.3-4, FU 1.a ACTION (a) of TS 3.4.6.1 INSERT A

REVISION NO.:

PROCEDURE TITLE:

PAGE:

39 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 161 of 236 PROCEDURE NO.:

0-ADM-536 TURKEY POINT PLANT ATTACHMENT 2 Technical Specification Bases (Page 142 of 217) 3/4.6.1.7 Containment Ventilation System The Containment Purge supply and exhaust isolation valves are required to be closed during a LOCA. When NOT purging, power to the purge valve actuators will be removed (sealed closed) to prevent inadvertent opening of these values. Maintaining these valves sealed closed during plant operation ensures that excessive quantities of radioactive materials will NOT be released via the Containment Purge System.

Leakage integrity tests with a maximum allowable leakage rate for Containment Purge supply and exhaust supply valves will provide early indication of resilient material seal degradation and will allow opportunity for repair before gross leakage failures could develop. The 0.60 La leakage limit shall NOT be exceeded when the leakage rates determined by the leakage integrity tests of these valves are added to the previously determined total for all valves and penetrations subject to Type B and C tests.

In MODES 1 through 4, Specification 3.6.1.7 requires that or isolating the penetrations or the associated penetration(s) is isolated by blind flange.

INSERT B INSERT C

INSERT A Functional Unit (FU) 3.c of ESFAS Tables 3.3-2, 3.3-3 and 4.3-2, specifies requirements for the containment ventilation isolation instrument channels. The footnote (*) to FU 3.c exempts the containment purge supply and exhaust isolation valves from the FU 3.c requirements.

Specification 3.6.1.7 requires the containment purge supply and exhaust isolation valves to be maintained administratively sealed closed and deactivated or the associated penetration(s) shall be isolated by blind flange in MODES 1 through 4. Thereby, the purge valve containment ventilation isolation function is performed without reliance on the FU 3.c actuation instrumentation.

Only the containment instrument air bleed isolation valves are applicable to the FU 3.c requirements of ESFAS Tables 3.3-2, 3.3-3 and 4.3-2.

INSERT B If Specification 3.6.1.7 is not met, ACTION a) allots 4-hours to restore compliance or Unit shutdown must commence. The 4-hours provides sufficient time to verify the purge valves are administratively sealed closed and power to the actuators are removed (i.e. if a blind flange is not installed). Specification 4.6.1.7.1 requires each containment purge valve to be verified administratively sealed closed and deactivated in accordance with the Surveillance Frequency Control Program (SFCP). The footnote (*) exempts performance of Specification 4.6.1.7.1 when the associated penetration(s) is isolated by blind flange. The blind flange shall feature double o-rings and shall be bolted to the purge penetration flange such that once secured in place, its position cannot be inadvertently altered, thereby obviating the need to periodically verify isolation of the affected containment purge penetration.

INSERT C Specification 4.6.1.7.2 requires the containment purge supply and exhaust isolation valve(s) measured leakage rate to be verified within limit in accordance with the SFCP. This purge valve measured leakage rate requirement is in addition to Specification 4.6.1.2, which requires leakage testing of all containment penetrations in accordance with Containment Leakage Rate Testing Program. Specification 4.6.1.7.2 addresses the NRCs leakage reliability concern with containment penetrations isolated by purge valves equipped with resilient seats [IE Circular 77-11] by imposing additional purge valve leakage testing in accordance with the SFCP. If the containment purge valve(s) measured leakage rate exceeds the limits of Specification 4.6.1.7.2, ACTION b) allots 72-hours to restore the measure leakage rate to within limit. The 72-hours provides sufficient time for orderly planning and repair without adversely impacting safety given the substantial margin that routinely exists between the Type B & C leakage limit [0.60 La] and the combined Type B & C maximum pathway leakage determined in accordance with TS 6.8.4.h, Containment Leakage Rate Testing Program. Alternatively, Specification 4.6.1.7.2 requires Type-B leakage rate testing in accordance with the Containment Leakage Rate Testing Program whenever the affected penetration is isolated by blind flange. The blind flange shall feature double o-rings, which provide the requisite redundant barrier isolation during the applicable MODES and thereby resolves the NRCs purge valve leakage reliability concern with purge valves equipped with resilient seats [IE Circular 77-11]. With a blind flange installed, the associated purge valves are not subject to leakage rate testing and the blind flange is only subject to the leakage rate testing required by the Containment Leakage Rate Testing Program.