L-2018-100, Turkey Point Units 3 and 4 - Submittal of 10 CFR 50.59(d)(2) Summary Report

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Turkey Point Units 3 and 4 - Submittal of 10 CFR 50.59(d)(2) Summary Report
ML18115A114
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 04/25/2018
From: Coffey R
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2018-100
Download: ML18115A114 (219)


Text

  • t=PL. U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 10 CFR 50.59(d)(2)

Summary Report 10 CFR 50.59(d)(2)

L-2018-100 APR 2 5 2018 In accordance with the requirements of 10 CFR 50.59(d)(2),

a summary report of changes, tests and experiments subject to 10 CFR 50.59 evaluation covering the period from April 29, 2016 to October 31, 2017 is provided in Sections 1 and 2 of Attachment

1. The report addresses the 10 CFR 50.59 evaluations for design change packages and temporary modifications, and engineering evaluations.

Section 3 of the Attachment 1 report contains a summary of Technical Specification (TS) Bases changes from January 25, 2017 to current.

The updated TS Bases are controlled and contained in Attachments 1 (index) and 2 (bases) to Turkey Point Administrative Procedure No. O-ADM-536, Technical Specification Bases Control Program.

Attachments 1 and 2 of procedure O-ADM-536 are contained in Attachment 2 to this letter. Should you have any questions regarding this submission, please contact Mr. Robert Hess, Licensing

Manager, at 305-246-4112.

Sincerely, Regional Vice President

-Southern Region Turkey Point Nuclear Plant Attachments:

1) 10 CFR 50.59(d)(2)

Summary Report 2) Technical Specification Bases Control Program, Procedure O-ADM-536, Attachments 1 and 2 cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Florida Power & Light Company 9760 SW 3441h St., Homestead, FL 33035 Florida Power & Light Company L-2018-100 Attachment 1 Page 1 of 18 Attachment 1 Unit 4 Cycle 29 10 CFR 50.59 Summary Report Changes, Tests, and Experiments Allowed by 10 CFR 50.59 For the Period Covering April 29, 2016 to October 31, 2017

Florida Power & Light Company Turkey Point Units 3 and 4 Docket Numbers 50-250 and 50-251

Florida Power & Light Company L-2018-100 Attachment 1 Page 2 of 18 TABLE OF CONTENTS PAGE TABLE OF CONTENTS 2 INTRODUCTION 4 SECTION 1 DESIGN CHANGE PACKAGES / TEMPORARY MODIFICATIONS Summary for Section 1 6 EC 283225 Unit 3 and 4 CCW Supplemental Cooling Modification 7 EC 280401 U4 - RCP Seals Upgrade Project 8 EC 289127 Temporary Lowering of SFP Water to Support Maintenance Replacement of the Process Diaphragm on 4-798B Under Work Order 40198323-01 9 SECTION 2 10 CFR 50.59 EVALUATIONS Summary for Section 2 11 EC 289227 JPN-PTN-SEMS-96-003 Revision 9, 10 CFR 50.59 Evaluation for Unit 4 Steam Generators' Secondary Side Foreign Objects 12 EC 290056 Reactor Coolant System Debris 13 EC 286596 10 CFR 50.59 Evaluation for Temporary Lowering of Spent Fuel Pool Water to Support Maintenance on 3-798B per Work Order 40331354 14 EC 284975 UFSAR Change to Allow Extension of the Six Month Turbine Valve Test Frequency to Twelve Months 15 SECTION 3 TECHNICAL SPECIFICATION BASES CHANGES Summary for Section 3 17 PCR 2140986 Clarification of TSTF-493 Requirements 17 PCR 2169786 Interim Compensatory Measure for Parallel Injection Flow Paths 17 PCR 2187079 Snubber Testing Program 17 Florida Power & Light Company L-2018-100 Attachment 1 Page 3 of 18 PCR 2159892 Auxiliary Feedwater System Steam Supply Flowpaths 17 PCR 2203165 ASME OM Code Case OMN-20 17 PCR 2190183 Technical Specification 3.8.1.1, ACTIONs 'a' and 'c' 18 PCR 2195391 Note 3 to Technical Specification Table 4.3

-2. 18 PCR 2169473 Control Room Emergency Ventilation System 18 PCR 2234452 High Range Noble Gas Effluent Monitors 18 PCR 2229788 Auxiliary Feedwater System Instrumentation 18 Florida Power & Light Company L-2018-100 Attachment 1 Page 4 of 18 INTRODUCTION This report is divided into three (3) sections. Section 1 summarizes changes made to the facility as described in the Updated Final Safety Analysis Report (UFSAR) resulting from Design Change Packages (DCPs) and Temporary Configuration Changes (TCCs) that screened in for evaluation under 10 CFR 50.59. Section 2 summarizes changes made to the facility or procedures as described in the UFSAR which were justified by a stand-alone 10 CFR 50.59 evaluation, not performed as part of a DCP or TCC.

Each of the Engineering Change (EC) documents is presented with an overall summary of the associated activity and a summary of the 10 CFR 50.59 evaluation(s) (SE).

Each EC package summary indicates the revision level(s) of the completed 10 CFR 50.59evaluation(s) and the revision level(s) of the associated EC package. Example: An EC package may have dozens of revisions but only one or two revisions of the evaluation, e.g., Revision 0 of a SE could correspond to Revision 2 of the EC while Revision 1 of the SE could correspond to Revision 10 of the EC.

Section 3 provides a summary of the Technical Specification Bases changes made since the previous submission of the report.

Florida Power & Light Company L-2018-100 Attachment 1 Page 5 of 18 SECTION 1

DESIGN CHANGE PACKAGES/TEMPORARY MODIFICATIONS

Florida Power & Light Company L-2018-100 Attachment 1 Page 6 of 18 SUMMARY FOR SECTION 1: DESIGN CHANGE PACKAGES / TEMPORARY MODIFICATIONS 10 CFR 50.59(d)(2) requires that each licensee submit a periodic report containing a brief description of any changes, tests, and experiments made or conducted at their facility under the criteria of 10 CFR 50.59(c)(2). This report is also required to include a summary of the evaluation of each change, test, or experiment.

Florida Power & Light Company is committed to submitting this report for the Turkey Point facility on an approximate eighteen month periodicity beginning six months after each Unit 4 refueling outage.

The report contained herein covers the period between April 29, 2016 and October 31, 2017. During this period, there were 2 permanent and 1 temporary plant modifications evaluated under the criteria of 10 CFR 50.59(c)(2) that were completely implemented and turned over to the station. A description of each is included in this section along with a summary of the applicable 10 CFR 50.59 evaluation.

Florida Power & Light Company L-2018-100 Attachment 1 Page 7 of 18 DESIGN CHANGE PACKAGE EC 283225 Revision 11 UNIT: 3 & 4 UNIT 3 & UNIT 4 CCW SUPPLEMENTAL COOLING SUMMARY: This Design Change Package (DCP) installed a new supplemental cooling system (SCS) as an addition to the Component Cooling Water (CCW) system to provide additional cooling to the containment building atmosphere. The SCS provided supplemental cooling to the Unit 3 and Unit 4 CCW system by injecting cooled water into the existing Unit 4 Boric Acid Evaporator (BAE) connections upstream of the Normal Containment Coolers (NCCs).

10 CFR 50.59 Evaluation:

This change does not require prior NRC approval in accordance with 10 CFR 50.59(c)(1). Implementation of the CCW SCS was demonstrated to meet all plant design basis requirements. Existing system and component temperature limits were maintained for all postulated accident and malfunction scenarios.

Florida Power & Light Company L-2018-100 Attachment 1 Page 8 of 18 DESIGN CHANGE PACKAGE EC 280401 Revision 14 UNIT: 3 & 4 Unit 4 - RCP Seals Upgrade Project SUMMARY: This Design Change Package (DCP) provides the design justification and the associated modifications required for replacement of the shaft seals on all three Reactor Coolant Pumps (RCPs) 4P200A/B/C for Unit 4. The existing Areva/Westinghouse shaft seals are being replaced with low

-leakage Flowserve N

-Seals (specifically model NX seals). This change package supports the Flexible and Diverse Strategies (FLEX) for beyond Design Basis External Events (BDBEEs) and the site's transition to NFPA 805.

The Flowserve NX shaft sealing system design consists of three mechanical face

-type sealing stages arranged for assembly as a single piece cartridge unit for installation in the RCP. During normal operation, each seal stage is subjected to a differential pressure of approximately one-third of reactor coolant system (RCS) pressure. Each of the three individual sealing stages is designed to withstand full RCS pressure indefinitely with the RCP idle, and for a limited period of time with the pump running at a nominal speed. Additionally, normal and maximum seal leakage rates are lower than those of the existing seal, thereby reducing charging flow from the Chemical and Volume Control System (CVCS) and reducing RCS inventory loss during plant transients. The Flowserve NX seal package also includes an abeyance, or shutdown seal that activates after failure of all three stages. Activation of the abeyance seal is not credited for design basis events, but is credited for beyond design basis events to limit RCS inventory losses.

10 CFR 50.59 Evaluation:

This change does not require prior NRC approval in accordance with 10 CFR 50.59(c)(1). The performance requirements of the new Flowserve NX seals were reviewed against the existing Areva/Westinghouse seal designs and demonstrated that the replacement seals would provide improved performance characteristics under normal and transient conditions.

Florida Power & Light Company L-2018-100 Attachment 1 Page 9 of 18 DESIGN CHANGE PACKAGE EC 289127 Revision 0 UNIT: 4 TEMPORARY LOWERING OF SFP WATER TO SUPPORT MAINTENANCE REPLACEMENT OF THE PROCESS DIAPHRAGM ON 4

-798B UNDER WO40198323

-01 SUMMARY: This temporary modification was developed to support replacement of the process diaphragm on 4-798B (Spent Fuel Pool (SFP) Demin. Return Valve to Spent Fuel Pool). The clearance for this activity requires lowering the Unit 4 SFP level below the 1/2" diameter hole in the discharge pipe that is submerging in the pool so that the line can be drained without siphoning water from the pool.

Temporarily decreasing the SFP water level below the Technical Specification limit of 56' - 10" to support maintenance to the SFP Filter valve requires a 10CFR50.59 evaluation as well as a risk evaluation per 10 CFR 50.65.

10 CFR 50.59 Evaluation:

Per Technical Specifications Section 3/4.9.11, the water level shall be maintained greater than or equal to elevation 56' - 10" in the spent fuel storage pool. Action statement b) includes the following, "The requirements of this specification may be suspended for more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to perform maintenance provided a 10 CFR 50.59 evaluation is prepared prior to suspension of the above requirement and all movement of fuel assemblies and crane operation with loads in the fuel storage areas are suspended. If the level is not restored within 7 days, the NRC shall be notified within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." The 10 CFR 50.59 evaluation of this activity concludes that the temporary lowering of SFP water level in accordance with this evaluation is acceptable and the proposed activity does not require prior NRC approval, or require a change to plant Technical Specifications.

Florida Power & Light Company L-2018-100 Attachment 1 Page 10 of 18 SECTION 2

10 CFR 50.59 EVALUATIONS

Florida Power & Light Company L-2018-100 Attachment 1 Page 11 of 18 SUMMARY FOR SECTION 2: 10 CFR 50.59 EVALUATIONS 10 CFR 50.59(d)(2) requires that each licensee submit a periodic report containing a brief description of any changes, tests, and experiments made or conducted at their facility under the criteria of 10 CFR 50.59(c )(2). This report is also required to include a summary of the evaluation of each change, test, or experiment. Florida Power & Light Company is committed to submitting this report for the Turkey Point facility six months after each Unit 4 refueling outage.

This report contained herein covers the period between April 29, 2016 and October 31, 2017. During this period, the following engineering evaluations were approved under the criteria of 10 CFR 50.59(c)(2).

Florida Power & Light Company L-2018-100 Attachment 1 Page 12 of 18 ENGINEERING EVALUATION JPN-PTN-SEMS-96-003 REV. 9 (EC 289227 Revision 1)

UNIT: 4 10CFR50.59 EVALUATION FOR UNIT 4 STEAM GENERATORS' SECONDARY SIDE FOREIGN OBJECTS SUMMARY: Foreign objects have previously been identified within the secondary side of all of the Unit 4 Steam Generators. Evaluation JPN

-PTN-SEMS-96-003 address the foreign objects which are not retrievable (or have not been retrieved) and potentially remain within the Steam Generators. Prior Evaluations have addressed the acceptability of continued Unit 4 operation with foreign objects remaining in the Steam Generators and associated systems. Revision 9 incorporates the results from the 2009 Unit 4 Cycle 25 refueling outage inspections. This included secondary side FOSAR (Foreign Object Search and Retrieval) inspections and full length ECT examination of 100% of active tubes. Both of the objects found during PT4-25 (Plant Turkey Point, Unit 4 Cycle 25) were assessed in accordance with the methodology provided in WCAP-14258. The acceptance standard for the wear time was based on the time to the next 100% ECT, at which point the minimum wall thickness of the subject tubes would be re-evaluated. In both cases, the identified objects did not yield a minimum wear time that would challenge the integrity of the affected tubes. Revision 9 also captures the results of the 2012 Unit 4 Cycle 27 refueling outage inspections. The locations of several of the tracked items were confirmed and some items were removed: no new objects were left in the Steam Generators. Additionally, there was no damage identified during the visual inspection or the Eddy Current Testing (ECT) for the tubes of the affected areas. The updates required for the PT4-27 refueling outage are administrative only and do not include alterations to any previously completed wear rate calculations.

Revision 9 also captures the results of the October 2014 Unit 4 Cycle 28 (EOC 27) refueling outage inspections and the March 2016 Unit 4 Cycle 29 (EOC 28) inspections. This Revision 9 provides the evaluation and documentation to support safe operation of the Unit 4 Steam Generators with foreign objects present in the secondary side until PT4-31 (Plant Turkey Point, Unit 4 Cycle 31).

10 CFR 50.59 Evaluation:

The 10 CFR 50.59 Evaluation for Revision 9 of JPN

-PTN-SEMS-96-003 concludes that the presence of secondary side foreign objects does not result in more than a minimal impact to any safety related design function, nor does it require a change to the Technical Specifications. It was determined that this activity did not require prior NRC approval. Continued operation of the Unit 4 Steam Generators within the restriction of the wear time calculations and TS surveillance requirements with the foreign objects present in the secondary side was determined to be acceptable under the existing design, analysis and licensing requirements. The Unit 4 Steam Generators shall receive 100% ECT inspection prior to exceeding any wear time calculation.

Florida Power & Light Company L-2018-100 Attachment 1 Page 13 of 18 UFSAR CHANGE REQUEST REACTOR COOLANT SYSTEM DEBRIS (EC 290056 Revision 1)

UNIT: 4 10CFR50.59 EVALUATION FOR UNIT 4 REACTOR COOLANT SYSTEM DEBRIS SUMMARY: EC-UCR 290056 (AR 2229699 and 2230537) describe two different pieces of debris

-cap screw and c

-clip-remaining in the reactor vessel.

These items were lost in the reactor coolant system (RCS) during refueling activities and were evaluated for their potential impacts to equipment within the RCS. The 50.59 screening determined only the c-clip warranted further evaluation because of the increased potential for a cladding failure. The cap screw is not included in this evaluation because it cannot damage fuel cladding.

10 CFR 50.59 Evaluation:

As stated in the UFSAR, the reactor design considered the potential for operating with cladding damage up to 1% of the fuel rods (320 rods) in the core. Fuel cladding defects within plant Technical Specifications limits during any mode of operation is a condition I event (ANSI/ANS 51.1-1973). The c-clip has the potential to damage up to four (4) fuel rods. This value is significantly less than 1% cladding failure which is the bases of Technical Specification 3.4.8. Therefore the potential fuel failure caused by the c

-clip will not change the frequency classification and thus the proposed activity will not have a more than minimal increase in the frequency of occurrence of an accident previously evaluated in the UFSAR. Failure of up to 1% of fuel cladding is within the plant's operational design bases (dose consequences, RCS cleanup systems, equipment qualifications, and ALARA personnel shielding). Fuel failure from debris has been considered in the design of the RCS. It has been shown that the c-clip cannot fail more than 1% of the fuel cladding precluding the possibility of increasing the likelihood of a fuel failure malfunction. Continued compliance is demonstrated because cladding failure will not reach this threshold to create an increase in the likelihood of occurrence of a malfunction. All UFSAR Chapter 14 radiological dose consequence analysis includes 1%

cladding defects (320 rods) as the initial condition. The c-clip will not damage more than 4 out of 32028 fuel rods and is within the allowance for possible fuel failures. There are no changes to dose consequence analysis results. Since no new failure modes are created by the proposed activity, it is concluded that there is no possibility that an accident may be created that is different from any already evaluated in the UFSAR.

No analysis must be changed to accommodate the c-clip. There is no impact to any radiological, thermal hydraulic, nuclear, or mechanical analysis of the fuel cladding or safety analysis; therefore, this change does not result in a departure from a design basis or safety analysis method. Reactor Coolant System, Specific -nt Xe-133. This limit is based on 1% cladding defects. DNB parameters (TS 2.1.1 & 3.2.5) are not affected.

The 10 CFR 50.59 Evaluation concludes that this activity did not require prior NRC approval.

Florida Power & Light Company L-2018-100 Attachment 1 Page 14 of 18 ENGINEERING EVALUATION LOWERING OF SPENT FUEL POOL WATER (EC 286596 Revision 0)

UNIT: 3 10 CFR 50.59 EVALUATION FOR TEMPORARY LOWERING OF SPENT FUEL POOL WATER TO SUPPORT MAINTENANCE ON 3

-798B SUMMARY: The subject activity for this evaluation involved work to replace the process diaphragm on 3-798B, SFP Demin. Return Valve To Spent Fuel Pit. The clearance required lowering the Unit 3 SFP level below the 1/2" diameter hole in the discharge pipe that is submerged in the pool so that the line could be drained without siphoning water from the pool. Lowering the SFP water level was controlled by a one-time Temporary Change (TC) to procedure 3-NOP-033 under AR/PCR 02041836. The purpose of this EC/DCR was for the transmittal of the 10 CFR 50.59 evaluation.

Technical Specification 3/4.9.11 states the water level shall be maintained greater than or equal to elevation 56' - 10" in the spent fuel storage pool whenever irradiated fuel assemblies are in the storage pool. The requirements of this specification may be suspended for more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to perform maintenance, provided a 10 CFR 50.59 evaluation is prepared prior to suspension of the above requirement and all movement of fuel assemblies and crane operation with loads in the fuel storage areas are suspended. The 10 CFR50.59 evaluation for this activity was required because the activity exceeded a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> duration.

10 CFR 50.59 Evaluation:

Technical Specification 3/4.9.11 allows for the temporary reduction of SFP water level for more than four (4) hours to perform maintenance related activities if a 10 CFR 50.59 evaluation is prepared in advance.

This specification also requires suspension of all movement of fuel assemblies and crane operations in the fuel storage area. If level is not restored within 7 days, the NRC shall be notified within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. SFP level for this activity was scheduled to be restored within 2 days.

The evaluation concluded that the temporary lowering of SFP water level was acceptable and the proposed activity did not require prior NRC approval, or require a change to plant Technical Specifications.

Florida Power & Light Company L-2018-100 Attachment 1 Page 15 of 18 UFSAR CHANGE REQUEST EXTENSION OF TURBINE VALVE TEST FREQUENCY (EC 284975 Revision 0)

UNIT: 3 & 4 UFSAR CHANGE TO ALLOW EXTENSION OF THE SIX MONTH TURBINE VALVE TEST FREQUENCY TO TWELVE MONTHS SUMMARY: The turbine valve test is scheduled every six months to ensure that the valves remain reliable to close when demanded to prevent a turbine over speed and blade failure.

Turkey Point has periodically extended the periodicity of this test beyond 6 months with no reduction in reliability. The proposed change extends the test frequency to 12 months, and updates the UFSAR accordingly. The change in frequency remains within NRC acceptance criteria and reduces the number of load reductions on both units during the operating cycle AR 02055068-04 provided a risk assessment for a potential increase in the frequency of performing the turbine valve test from once per 6 months to once per 12 months. The risk assessment identifies WCAP

16054-P, "Probabilistic Analysis of Reduction in Turbine Missiles", dated April, 2003 as providing the bounding analysis. The WCAP analysis states that for an 18-month refueling cycle and 18-month stop valve disc surveillance interval, the frequency is 2.9E

-6 with 6-month intervals and 4.26E

-06 with 12-month intervals.

This remains below the NRC acceptance criteria of 1 E

-5. 10 CFR 50.59 Evaluation:

The turbine stop and control valve test is currently scheduled every six months to ensure that the valves remain reliable to close when demanded to prevent a turbine over speed and blade failure (Reference UFSAR Appendix 5E). The proposed change extends the test frequency to 12 months and updates the UFSAR accordingly. The 10 CFR 50.59 evaluation discussed the increase in the frequency of accidents previously evaluated in the UFSAR and concluded that this change does not result in more than a minimal increase in the frequency of occurrence of a turbine missile. The risk assessment performed for this activity identifies WCAP 16054

-P, "Probabilistic Analysis of Reduction in Turbine Missiles", dated April, 2003 as providing the bounding analysis (Reference UFSAR Appendix SE, Reference SE-4). The WCAP analysis states that for an 18-month refueling cycle and 18-month stop valve disc surveillance interval, the frequency of occurrence of a turbine missile is 2.9E-6 with 6-month valve test intervals and 4.26E

-06 with 12-month valve test intervals. The 10 CFR 50.59 evaluation concluded that the likelihood of a malfunction is not increased by a factor of 2 or more. Therefore this activity does not result in more than a minimal increase in the likelihood of occurrence of a malfunction previously evaluated in the UFSAR.

Based on the responses to the eight criteri a of 10 CFR 50.59, the evaluation concluded that a license amendment is not required prior to implementation of this activity. This activity can be implemented without prior NRC approval.

Florida Power & Light Company L-2018-100 Attachment 1 Page 16 of 18 Section 3

Technical Specification Bases Changes Florida Power & Light Company L-2018-100 Attachment 1 Page 17 of 18 SUMMARY FOR SECTION 3: TECHNICAL SPECIFICATION BASES CONTROL PROGRAM Amendments 222 and 217 to the Turkey Point Units 3 and 4 operating licenses, respectively, added Technical Specification 6.8.4.i, Technical Specifications Bases Control Program. Technical Specification (TS) 6.8.4.i.d requires changes to TS Bases that do not require prior NRC approval be submitted to the NRC "- on a frequency consistent with 10 CFR 50.71(e)." The report of changes made pursuant to 10 CFR 50.59 is also submitted consistent with 10 CFR 50.71(e) (the FSAR update). Therefore, changes made to the TS Bases are being submitted with this report and are contained in procedure 0-ADM-536, Technical Specification Bases Control Program

. Attachments 1 (index) and 2 (TS Bases) of procedure 0-ADM-536 are provided in Attachment 2 of this letter. A summary of TS Bases changes made since the previous update follows:

0-ADM-536 TS Bases Changes PCR (Procedure Change Request) 2140986 Sections 2.2.1 and 3/4.3.1 & 3/4.3.2 were revised to clarify that a corrective action program evaluation does not need to be completed prior to returning an out-of-tolerance instrument channel to service during a surveillance test if it can be recalibrated to within the as

-left tolerance. In this case, the functional verification is performed in the field during the surveillance test.

PCR 2169786 Revised Section 3/4.5.2 - ECCS SUBSYSTEMS - Tavg GREATER THAN OR EQUAL TO 350ºF to add an Interim Compensatory Measure for missing ACTION pertaining to the parallel injection flow paths for Safety Injection (MOV-*-843A and B) and Residual Heat Removal (MOV-*-744A and B).

PCR 2187079

Section 3/4.7.6, Snubbers, was revised to conform with the changes approved by License Amendments 272 and 267 that added the Snubber Testing Program.

PCR 2159892

Section 3/4.7.1.2, Auxiliary Feedwater System, was revised to conform with the requirements for steam supply flowpaths as approved by License Amendments 273 and 268.

PCR 2203165

Section 3/4.0, was revised to reflect a change to Specification 4.0.5and related conforming changes to implement TSTF

-545 as authorized by License Amendments 274 and 269. The use of ASME OM Code Case OMN-20 was authorized for the Inservice Testing Program.

Florida Power & Light Company L-2018-100 Attachment 1 Page 18 of 18 PCR 2190183 Section 3/4.8, Electrical Power Systems, was revised to provide further information on the application of Technical Specification 3.8.1.1, ACTIONs 'a' and 'c'.

PCR 2195391

Section 3/4.3.1 & 3/4.3.2, Reactor Trip System and Engineered Safety Features Actuation System Instrumentation, was revised to provide detail regarding a Mode 3 entry exception for performance of certain instrumentation surveillances allowed by Note 3 to Technical Specification Table 4.3

-2.

PCR 2169473

Section 3/4.7.5, Control Room Emergency Ventilation System was revised as a result of License Amendments 275 and 270.

PCR 2234452

Section 3/4.3.3.3, Accident Monitoring Instrumentation, was revised to reflect the changes to TS 3/4.3.3.3.3, Tables 3.3

-5 and 4.3-4, Accident Monitoring Instrumentation, approved by License Amendments 277 and 272. The amendments relocated the TSs for high-range noble gas effluent monitors to the Offsite Dose Calculation Manual.

PCR 2229788 Section 3/4.3.1 & 3/4.3.2, Reactor Trip System an d Engineered Safety Features Actuation System Instrumentation, was revised to change Action 23 required actions for Auxiliary Feedwater System (AFW) Functional Unit (FU) 6(d), Bus Stripping, and AFW FU 6(e), Trip of All Main Feedwater Pump Breakers, as allowed by License Amendments 276 and 271.

Florida Power & Light Company L-2018-100 Attachment 2 Attachment 2 Turkey Point Nuclear Plant Technical Specification Bases Contained in Procedure 0-ADM-536, Technical Specification Bases Control Program, Attachments 1 and 2 (This coversheet plus 1 99 pages starting with 13 of 211)

ATTACHMENT 1 Index

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ATTACHMENT 2 Technical Specification Bases NOT

NOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases NO NOT NOT

NOT NOT ATTACHMENT 2 Technical Specification Bases

NOT

ATTACHMENT 2 Technical Specification Bases NOT NOT

NOT NOT ATTACHMENT 2 Technical Specification Bases

NOT

ATTACHMENT 2 Technical Specification Bases NOT NOT

NOT NOT

ATTACHMENT 2 Technical Specification Bases NOT NOT NOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NOT NOT NOT ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

(1)

ATTACHMENT 2 Technical Specification Bases (2)

ATTACHMENT 2 Technical Specification Bases NOT NO

ATTACHMENT 2 Technical Specification Bases NOT NO

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NOT

ATTACHMENT 2 Technical Specification Bases NOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases NOT

ATTACHMENT 2 Technical Specification Bases

NOT NOT NOT NO

ATTACHMENT 2 Technical Specification Bases

NOT

ATTACHMENT 2 Technical Specification Bases

NOTNOTE

NOT ATTACHMENT 2 Technical Specification Bases

NOT

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ATTACHMENT 2 Technical Specification Bases NO ATTACHMENT 2 Technical Specification Bases NOT NOT

ATTACHMENT 2 Technical Specification Bases NOT

NOT NOT ATTACHMENT 2 Technical Specification Bases

NOT

NOT NOT NOT

ATTACHMENT 2 Technical Specification Bases NOT ATTACHMENT 2 Technical Specification Bases NOT

NOT NOT NOT NOT

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NOT NO NOT NOT NOT NO

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NOT ATTACHMENT 2 Technical Specification Bases NOT NOT NOT

ATTACHMENT 2 Technical Specification Bases

NOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases NOT

ATTACHMENT 2 Technical Specification Bases

NOT ATTACHMENT 2 Technical Specification Bases NOT Case No. Purpose Min/Max pH Small Basket Fill Height (ft) Large Basket Fill Height (ft) Initial NaTB Mass (Ibm) Dissolved Mass prior to Recirc (Ibm) pH at Recirc Long-Term pH ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases ATTACHMENT 2 Technical Specification Bases

NONOT NO ATTACHMENT 2 Technical Specification Bases

NO NOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases NOT ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NO

ATTACHMENT 2 Technical Specification Bases NOT NOT

ATTACHMENT 2 Technical Specification Bases NOT

NOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases NO

NOT

ATTACHMENT 2 Technical Specification Bases NOT

ATTACHMENT 2 Technical Specification Bases NOT NOT

ATTACHMENT 2 Technical Specification Bases NOTNOT ATTACHMENT 2 Technical Specification Bases NO

NOT ATTACHMENT 2 Technical Specification Bases

NOT ATTACHMENT 2 Technical Specification Bases

NOTNO ATTACHMENT 2 Technical Specification Bases NOT

NOT ATTACHMENT 2 Technical Specification Bases NOTNOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases NOT

NOT NOT NOT NOT NO NOT ATTACHMENT 2 Technical Specification Bases

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NOT NOT ATTACHMENT 2 Technical Specification Bases NOT

ATTACHMENT 2 Technical Specification Bases

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ATTACHMENT 2 Technical Specification Bases NOT ATTACHMENT 2 Technical Specification Bases NO

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NOT

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NOT

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NOT

ATTACHMENT 2 Technical Specification Bases

NOT NOT

ATTACHMENT 2 Technical Specification Bases NOT NOT NOT NOT

NOT

ATTACHMENT 2 Technical Specification Bases NOT ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NO ATTACHMENT 2 Technical Specification Bases

NOT NOT

NOT ATTACHMENT 2 Technical Specification Bases

NOT

ATTACHMENT 2 Technical Specification Bases NOT NO NOT ATTACHMENT 2 Technical Specification Bases NOT NOT NOT NOT NO

NOT NOT ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NOT NOT NOT

ATTACHMENT 2 Technical Specification Bases NOT NOT NOT NO NOT NOT

ATTACHMENT 2 Technical Specification Bases NO

NOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NOT NO NOT NO

ATTACHMENT 2 Technical Specification Bases

NOT NOT ATTACHMENT 2 Technical Specification Bases

Train in Service 3A 3B 4A 4B Reason MCCs NO ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NOT

ATTACHMENT 2 Technical Specification Bases

NOT ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases NOT

ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NOT ATTACHMENT 2 Technical Specification Bases

ATTACHMENT 2 Technical Specification Bases

NOT

ATTACHMENT 2 Technical Specification Bases

NOT

NOT NOT ATTACHMENT 2 Technical Specification Bases