L-2019-135, Response to Request for Additional Information Regarding License Amendment Request 266, Clarify Requirements When One Unit Is Outside the Applicability of Certain Technical Specifications
| ML19203A039 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/22/2019 |
| From: | Stamp B Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2019-135 | |
| Download: ML19203A039 (6) | |
Text
Florida Power & Light Company 9760 SW 344 St., Homestead, FL 33035 July 22, 2019 L-2019-135 10 CFR 50.90 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Re:
Turkey Point Nuclear Plant, Units 3 and 4 Docket Nos. 50-250 and 50-251
Subject:
Response to Request for Additional Information Regarding License Amendment Request 266, Clarify Requirements When One Unit is Outside the Applicability of Certain Technical Specifications
Reference:
- 1. Florida Power & Light Company letter L-2019-005, License Amendment Request 266, Clarify Requirements When One Unit is Outside the Applicability of Certain Technical Specifications, February 14, 2019 (ML19045A617)
- 2. NRC e-mail Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additional Information Regarding License Amendment Request 266 (EPID L-2019-LLA-0024), July 3, 2019 In Reference 1, Florida Power & Light Company (FPL) submitted License Amendment Request 266 for an amendment to the technical specifications (TS) for Turkey Point Units 3 and 4. Certain systems and components that are controlled by the TS are shared between the two units, and some TS requirements change when only one unit is operating and the other unit is shutdown in mode 4, 5, or 6. The proposed change clarifies that shutdown also includes the defueled condition. In addition, the change removes from a TS action an inappropriate footnote that allows an exception from TS 4.0.4, which requires that surveillance requirements must be met prior to entering the applicability of a TS.
In Reference 2, the NRC staff requested additional information to support its review of the proposed change. The enclosure to this letter provides the requested information.
This response to the request for information does not alter the conclusion in Reference 1 that the change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with this change.
No new or revised commitments are included in this letter.
L-2019-135 Page 2 of 2 Should you have any questions regarding this submittal, please contact Robert Hess, Licensing Manager, at (305) 246-4112.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on July ~.;t, 2019 Sincerely, Brian Stamp Site Director 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
L-2019-135 Enclosure Page 1 of 4 ENCLOSURE Response to Request for Additional Information Regarding License Amendment Request 266, Clarify Requirements When One Unit is Outside the Applicability of Certain Technical Specifications RAI #1 The licensees proposed change adds a new Defueled, condition as stated above. The licensee justifies the Regulatory Requirement/Criteria for the change as follows:
The proposed change to the TS is consistent with the requirements of 10 CFR 50.36. 10 CFR 50.36, Technical specifications, requires that the TS include limiting conditions for operation, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The TS must also include surveillance requirements 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 to the TS is consistent with the requirements of 10 CFR 50.36.
The NRC Commissions Final Policy Statement on Technical Specifications Improvements presents the policy of the Nuclear Regulatory Commission (NRC) with respect to the scope and purpose of Technical Specifications for nuclear power plants as required by 10 CFR 50.36. It establishes a specific set of objective criteria (Section IV) as guidance for determining which regulatory requirements and operating restrictions should be included in Technical Specifications. Regarding the licensees proposed addition of a defueled condition in the Technical Specifications, the licensee states, The proposed change to the TS is consistent with the requirements of 10 CFR 50.36.
- a. When a shutdown unit is in a defueled condition, please explain how the proposed change complies with the 10 CFR 50.36 regulation.
- b. Please confirm, based on a review of your current licensing basis, that there are no safety requirements, accidents or events which would need to be reanalyzed if the proposed change is implemented.
FPL Response
- a. 10 CFR 50.36 requires, in part, that the technical specifications (TS) are derived from the analyses and evaluation included in the final safety analysis report and contain safety limits, limiting safety system settings, limiting conditions for operation (LCOs), and surveillance requirements (SRs). LCOs are the lowest functional capability or performance level of equipment required for safe operation of the facility, and SRs demonstrate that LCOs are met.
L-2019-135 Enclosure Page 2 of 4 The purpose of LCOs is to ensure that safety analysis assumptions are met for accidents, most of which are assumed to occur during reactor operation. Appropriately, certain LCOs do not apply when the plant is in a condition where the accident is not assumed to occur, such as the condition that the reactor is not operating and contains no fuel. If a unit is operating in a mode outside the applicability of the LCO when in mode 4, 5 or 6, it is similarly operating outside the applicability of the LCO when it is in a defueled condition.
With the proposed change that clarifies a unit is outside the applicability of a particular TS when fuel has been removed from the reactor, the TS continue to comply with 10 CFR 50.36. For example, when the reactor is defueled, a fuel handling accident remains plausible.
Therefore, consistent with 10 CFR 50.36, the TS continue to require operability of TS equipment that is assumed in the safety analysis for mitigation of a fuel handling accident.
In this case, the relevant TS have an applicability of during movement of irradiated fuel, which would be applicable even if the reactor is defueled and the plant is not in a TS-defined operational mode.
The proposed change does not modify any surveillance requirements (SRs) or the applicability of any TS and does not alter the technical requirements of any TS; therefore, the proposed change has no affect on the way the TS comply with 10 CFR 50.36. Following the proposed change, the TS will continue to comply with 10 CFR 50.36 as they do currently.
- b. The TS define the limits of plant operation that ensure the plant is operated within the boundaries established by the safety analysis. The requirements of the TS must be met when the plant is in the mode or other specified conditions in the applicability of the TS to ensure the conditions assumed in the safety analysis are met. However, with the plant operating in a condition in which an accident is not assumed to occur, then the plant condition may also be outside the applicability of the TS. For example, the analysis for a loss of coolant accident assumes the plant is operating at power when the event occurs, and the analysis credits operation of the emergency core cooling system (ECCS) to mitigate the event.
Accordingly, Turkey Point TS 3.5.2 specifies the operability requirements for ECCS components with both units operating in modes 1, 2, or 3. However, when one unit is operating outside the applicability of TS 3.5.2, then the ECCS components required to be operable are only those associated with the single unit that is operating in the applicability of the TS because the conditions assumed in the safety analysis do not apply to the unit that is outside the conditions in which the accident is assumed to occur.
The proposed amendment makes no changes to the technical requirements of any TS and does not modify the applicability of any TS. Therefore, the safety analysis assumptions currently maintained by the TS are unchanged by the proposed amendment. The proposed change is associated only with the status of the opposite unit when it is operating outside the applicability of certain TS. The current TS relax certain requirements when one unit is operating outside the applicability of the TS and refer to this condition in terms of an operational mode (mode 4, 5, or 6). However, if all fuel is removed from the reactor, the relaxation also applies since, just like in modes 4, 5 and 6, the defueled condition precludes the plant condition in which most accidents are assumed to occur. The proposed amendment makes no changes involving the applicability or technical requirements of TS
L-2019-135 Enclosure Page 3 of 4 that apply under conditions for which safety requirements, accidents, or events are assumed to occur. Therefore, no re-analyses are necessary for this change because it does not affect any safety requirements, accidents, or events.
RAI #2 LCO 3.5.2a requires that The Emergency Core Cooling System (ECCS) equipment and flow paths shall be OPERABLE with Four Safety Injection (SI) pumps, each capable of being powered from its associated OPERABLE diesel generator, with discharge flow paths aligned to the RCS cold legs.*
The footnote states:
- Only three Safety Injection (SI) pumps (two associated with the unit and one from the opposite unit), each capable of being powered from its associated OPERABLE diesel generator#, with discharge flow paths aligned to the RCS cold leg are required if the opposite unit is in MODE 4, 5, or 6.
The proposed change adds Defueled condition to Modes 4,5 or 6 as 4, 5, 6, or Defueled.
Please provide an explanation on how the ECCS equipment and flow paths are ensured OPERABLE when the opposite unit is in a Defueled, condition consistent with current requirements in Mode 4, 5 or 6.
Similarly, provide an explanation for the addition of the Defueled, condition in LCO 3.7.1.3 and LCO 3.8.3.1, as stated in the LAR.
FPL Response Surveillance requirements (SRs) demonstrate that LCOs are met, and Turkey Point TS 4.0.1 requires that SRs must be met for LCOs when operating in the modes or other specified conditions in the applicability of the TS. The operability of ECCS equipment and flow paths is ensured by meeting the requirements in SR 4.5.2. Similarly, operability of the condensate storage tank in TS 3.7.1.3 and operability of the onsite power distribution system in TS 3.8.3.1 are demonstrated by meeting the SR 4.7.1.3 and SR 4.8.3.1, respectively. The proposed change has no impact on any LCO or the method of demonstrating compliance with LCOs.
Certain systems and components that are controlled by the TS are shared between the two units, and some TS requirements change when only one unit is operating and the other unit is outside the applicability of the TS. (Appendix A to the Turkey Point Updated Final Safety Analysis provides an evaluation of systems shared by the two units.) In some cases, such as the safety injection pumps required by current TS 3.5.2, the operating unit relies on TS equipment associated with the unit that is in a shutdown or refueling mode to meet the LCO for the unit that is operating. The processes currently in place for demonstrating operability of the required equipment in the unit that is in a shutdown or refueling mode will also be used to demonstrate operability of that equipment when the non-operating unit is in the defueled condition.
L-2019-135 Enclosure Page 4 of 4 RAI #3 Section 1.0 of the LAR states, The proposed change clarifies that shutdown also includes the Defueled condition.
Please explain how this LAR statement is a correct statement since Shutdown Operational Mode, as specified in TS Table 1.2, does not specify inclusion of a Defueled condition.
FPL Response The reference to the shutdown condition in the LAR statement above was meant to distinguish this condition from that of an operating reactor; it was not referring to the shutdown operational modes defined in TS Table 1.2. When a nuclear power plant is not operating, it is considered to be in a shutdown condition. When shutdown, the plant may be in one of the shutdown modes (mode 4 or 5) or in the refueling mode (mode 6). In each of these modes, fuel is present in the reactor.
However, sometimes when a plant is shutdown, all the fuel is removed from the reactor. In the defueled condition, the plant is still considered to be in a shutdown condition, but it is no longer in a mode defined by the TS because all the modes involve a reactor containing fuel. Therefore, the statement that shutdown includes the defueled condition is correct and appropriate.