Text

Second Response to Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide...
	ML16243A104
Person / Time
Site:	Turkey Point
Issue date:	08/11/2016
From:	Summers T; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2016-136
	Download: ML16243A104 (33)
	v • d • e

August 11, 2016 L-2016-136 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Plant, Units 3 and 4 Docket Nos. 50-250 and 50-251 Second Response to Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 48"

References:

1. Florida Power & Light Company letter L-2014-369, "License Amendment Request No. 236 Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times - RITSTF

Initiative 48'," December 23, 2014(ML15029A297)

2. NRC E-mail "Request for Additional Information re. Turkey Point 3 & 4 LAR-236 (CACs MF5455 & MF5456)," April 14, 2016(ML16105A459)

3. NRC E-mail "Request for Additional Information - Turkey Point 3 & 4 LAR-236 (CACs MF5455 & MF5456)," April 18, 2016 (ML16110A004)

4. NRC E-mail "Request for Additional Information re. Turkey Point 3 & 4 LAR-236 (CACs MF54555 & MF5456)," June 1, 2016(ML16154A339)

5. Florida Power & Light Company letter L-2016-116, "Response to Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48'," June 16, 2016 (ML16180A178)

In Reference 1, Florida Power & Light Company (FPL) submitted license amendment request (LAR) 236 for Turkey Point Units 3 and 4. The proposed amendment would revise the Technical Specifications (TS) to implement TSTF-505, Revision 1, "Provide Risk-:-lnformed Extended Completion Times RITSTF [Risk Informed TSTF] Initiative 4b."

In References 2, 3, and 4, the NRC staff requested additional information to complete its review of the LAR. Reference 5 responded to all but four questions in the requests for additional information. The Enclosure to this letter provides FPL's response to the four remaining questions (EIC8 RAI 3, EIC8 RAI 5, APLA RAI 8, and S8P8 RAI 1). FPL has included in this Florida Power & Light Company 9760 SW 344 St., Homestead, FL 33035

Florida Power & Light Company L-2016-136 Page 2of2 response a 24-hour limit on the risk informed completion time used for emergent conditions involving a loss of specified safety function or inoperability of all trains when one or more trains are PRA functional. While this response does not propose a backstop longer than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for

- a loss of function condition, FPL will continue to participate in the industry effort and may request a longer backstop in the future.

Reference 1 discussed that FPL had previously submitted LAR 212, which proposed changes to TS 3.5.2, Emergency Core Cooling Systems, and following receipt of an amendment for LAR 212, FPL would supplement LAR 236 to incorporate the amended TS. In response to LAR 212, the NRC issued Amendment Nos. 267 and 262 for Turkey Point Units 3 and 4, respectively, in November 2015. Consequently, the Enclosure to this letter also contains the supplement to LAR 236 with proposed changes to TS 3.5.2.

Attachment 1 to the enclosure provides markups of the TS showing revisions to the proposed changes. These markups supersede the corresponding markups provided in Reference 1.

Revised TS pages are provided in Attachment 2 and supersede the corresponding pages provided in Reference 1. Attachment 3 provides proposed changes to the Bases for TS 3.5.2, Emergency Core Cooling Systems. The changes included in Attachment 3 supersede the corresponding Bases changes provided in Reference 1.

This response does not alter the conclusion in Reference 1 that the changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the changes. -

No new or revised commitments are included in this letter.

Should you have any questions regarding this submittal, please contact Mr. Mitch Guth, Licensing Manager, at (305) 246-6698.

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

Executed on August _._.I I.___, 2016

~-~MAN

~~.~\If>~

Thomas Summers '"'f ~~.S Site Vice President Turkey Point Nuclear Plant Enclosure cc: NRC Regional Administrator, Region II NRC Senior Resident Inspector' NRC Project Manager Ms. Cindy Becker, Florida Department of Health

Florida Power & Light Company L-2016-136 Page 1of12 Enclosure ENCLOSURE Second Response to Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 48"

Florida Power & Light Company L-2016-136 Page 1of12 Enclosure EICB RAI 3 The LAR does not describe conditions* where instrumentation & controls (l&C) functions are INOPERABLE but PRA Functional.

A. For each l&C function where there is a proposed ACTION for the condition where there are two or more INOPERABLE redundancies, please provide some example conditions that would be considered PRA Functional.

B. For each example, please include an evaluation against the criteria in NEI 06-09 Section 2.3.1, Item No. 10 (i.e., Item No. 11 as augmented and supplemented by Section 3.2.3).

C. The staff understands that by meeting the criteria in Items Nos. 1O and 11 in NEI 06-09, Section 2.3.1, all design basis events would be protected against. Please identify if there are any associated design basis events that are NOT protected against when the criteria in Items Nos. 10 and 11 in NEI 06-09, Section 2.3.1 are met.

FPL Response A. Turkey Point Units 3 & 4 - TS Table 3.3-1, Functional Unit (FU) 1, Manual Reactor Trip; Table 3.3-2, FU 1.a, 3.a.1, and 3.b.1 (manual initiation functions); Table 3.3-1 FU 19, Reactor Trip Breakers; Table 3.3-2 FU 6.b, Auxiliary Feedwater - Stm. Gen. Water Level

- Low-Low, FU 7.a, 7.b, 7.c, Loss of Power:

Functions that are inoperable will be considered PRA functional only when the

cause of the inoperability is solely due to an administrative consideration. An example of an administrative consideration causing inoperability that will be considered to not impact PRA functionality is corrective maintenance and associated post-maintenance testing that have been successfully completed on a channel, indicating a reasonable expectation that the channel can perform its specified safety function(s), but the TS Surveillance Requirement has not yet been satisfied to declare the channel OPERABLE. This practice is consistent with the current Configuration Risk Management Program (CRMP) in use for assessing and managing configuration risk per 10 CFR 50.65(a)(4) (Maintenance Rule). Note that performance of a surveillance test that results in failure to meet its Surveillance Requirements would result in the affected channel being considered inoperable and not PRA functional and, therefore, the channel could not be credited in a RICT calculation.

For Turkey Point Units 3. & 4 - TS Table 3.3-2, Engineered Safety Features Actuation System Instrumentation: 1.c. Safety Injection Containment Pressure-High, 1.d. Safety Injection Pressurizer Pressure Low, 1.e. Safety Injection High Differential Pressure Between Steam Line Header and any Steam Line, 1.f. Safety Injection Steam Line Flow

- High Coincident with Steam Generator Pressure - Low, 1.f. Safety Injection Steam Line Flow- High Coincident with Tavg - Low, 2.b. Containment Spray Containment Pressure -

High High, 2.b. Containment Spray Containment Pressure - High-High Coincident with Containment Pressure - High:

In addition to the response above, these channels could be inoperable and PRA functional with a slightly non-conservative setpoint (fraction of a percent), or the

Florida Power & Light Company L-2016-136 Page 2of12 Enclosure intentional placement of an inoperable instrument channel in the trip condition.

These functions have a design success criterion of 2-of-3 channels. The PRA success criterion is the same. If two channels are inoperable, one channel is placed in trip, which changes the trip logic to 1-of-1. The plant would be protected with the actuation of the remaining operable channel.

B. For Turkey Point Units 3 & 4 - TS Table 3.3-1, Functional Unit (FU) 1, Manual Reactor Trip; Table 3.3-2, FU 1.a, 3.a.1, and 3.b.1 (manual initiation functions); Table 3.3-1 FU 19, Reactor Trip Breakers; Table 3.3-2 FU 6.b, Auxiliary Feedwater - Stm. Gen. Water Level - Low-Low, FU 7.a, 7.b, 7.c, Loss of Power:

The criterion of NEI 06-09-A, Section 2.3.1, item 11.2 is applicable to this example. This criterion permits consideration of the unaffected functions of the component to be PRA functional when the condition causing the inoperability is capable of being assessed by the PRA model. The corrective maintenance has restored the channel to its design configuration and associated post-maintenance testing has been completed on the channel which indicates a reasonable expectation that the channel can perform its specified safety function(s) and, therefore, the functions modeled in the PRA are no longer affected. The other PRA functionality criteria under item 11 (11.1 and 11.3) are not applicable because, as stated above, inoperable components will not be considered PRA functional, except for administrative considerations. Specifically:

NEI 06-09-A, Section 2.3.1, Item 11.1 is not applicable because degraded performance parameters will not be considered PRA functional when they are inoperable, as discussed in part A.

NEI 06-09-A, Section 2.3.1, Item 11.3 is not applicable because the affected functions for inoperable components are either modeled explicitly or modeled by surrogate inputs in the PRA, even though specific components are not modeled. The surrogates will not be considered PRA functional when the associated components are inoperable, as discussed in part A.

For Turkey Point Units 3 & 4 - TS Table 3.3-2, Engineered Safety Features Actuation System Instrumentation: 1.c. Safety Injection Containment Pressure-High, 1.d. Safety Injection Pressurizer Pressure Low, 1.e. Safety Injection High Differential Pressure Between Steam Line Header and any Steam Line, 1.f. Safety Injection Steam Line Flow

- High Coincident with Steam Generator Pressure - Low, 1.f. Safety Injection Steam Line Flow- High Coincid~nt with Tavg - Low, 2.b. Containment Spray Containment Pressure -

High High, 2.b. Containment Spray Containment Pressure - High High Coincident with Containment Pressure - High:

NEI 06-09-A, Section 2'.3.1, Item 11.1 is applicable. For non-conservative setpoints, the cause would be identified and there would be no further degradation, i.e., human error, out of calibration M&TE, or the limit to the degradation would be known to not degrade to impact functionality, i.e., relay drift analysis (similar to that in EPRI TR 3002002556).

NEI 06-09-A, Section 2.3.1, Item 11.2 is applicable to this example. -See response above and for the example of slightly non-conservative setpoint, the

Florida Power & Light Company L-2016-136 Page 3of12 Enclosure equipment PRA function will still meet design bases criteria. TS setpoints are designated with significant margin to the design bases level, i.e., containment pressure design is 55 psig, setpoint 4.0 psig, and allowable level 4.5 psig.

NEI 06-09-A, Section 2.3.1, item 11.3 is not applicable because the affected functions for inoperable components are either modeled or modeled by surrogate inputs in the PRA, even though specific components are not modeled. The surrogates will not be considered PRA functional when the associated components are inoperable, as discussed in part A.

C. All design basis events are protected when a TS actuation is inoperable solely for the cause of the above administrative considerations since the channel would be capable of performing its specified safety functions or would be capable due to still meeting design basis criteria. There are no associated design basis events that would not be protected against in the examples in part A of this response.

EICB RAI 5 of the Model Application (ADAMS Accession No. ML12032A065) for licensee adoption of TSTF-505, Revision 1, states:

This enclosure [Enclosure 1, "List of Revised Required Actions to Corresponding PRA Functions"] should provide a description of PRA functionality for each associated specified safety function that corresponds to each proposed Required Action that is applicable when all trains of equipment are inoperable as discussed in Section 2.3.1.1 O of NEI 06-09. For example, the number and identity of instrumentation and control channels (or functions) required to be PRA functional is highly dependent on the specific plant and associated equipment design. guidance is included as part of the model application because the NRC staff seeks clarity in how PRA Functional will be used during full power operation following a "loss of a specified safety function or inoperability of all required trains or divisions of a system."

In the LAR, Enclosure 1, "List of Revised Required Actions to Corresponding PRA Functions,"

the "PRA Success Criteria" is indicated as being the same as the "Design Success Criteria," that is, the same minimum number of channels actuate.

A. Please confirm that the PRA Success Criteria ensures all associated design basis events are protected against in the condition where two or more redundancies are INOPERABLE, or justify how adequate protection is maintained, if not.

B. Enclosure 1 of the LAR identifies some l&C structure, system, and components that are not modeled in the PRA. Item No. 11 in NEI 06-09, Section 2.3.1 includes criteria for determining PRA Functionality of components, and these criteria were developed based on the assumption that the function would be modeled in the PRA.

i. Please describe how PRA Functionality of these un-modeled items will be determined (i.e., how the criteria of Item No. 11 will be applied).

Florida Power & Light Company L-2016-136 Page 4of12 Enclosure ii. Please describe how PRA Functionality of surrogate and bounding models will be determined (i.e., how the criteria of Item No. 11 will be applied).

FPL Response A. For a function to be considered PRA Functional in order to permit the use of the RICT Program, the number of OPERABLE and/or PRA Functional channels must be such that the signal will actuate when the actual plant parameter exceeds the setpoint. For manual actuations, where a 1-of-2 redundancy is provided, at least one channel must be OPERABLE or PRA Functional. For automatic actuations involving either a 2'-of-3 or 2-of-4 redundancy, at least two channels must be OPERABLE or PRA Functional. This may Include an inoperable channel which is in the trip condition.

As described above in the response to EICB RAl-3, when one or more channels are INOPERABLE and PRA functional, they will be capable of performing the specified functions in the CLB and the PRA. Channels will not be considered PRA functional unless the cause of the inoperability is solely due to an administrative consideration, slightly non-conservative setpoint, or being in trip. Therefore, since the PRA success criteria are met only when the design success criteria are met, all design basis events are protected against when two channels are INOPERABLE and PRA functional.

B. Inoperable l&C SSCs not modeled, partially modeled, or modeled by use of surrogates (bounding) in the PRA may be determined PRA functional only in the case where inoperability is due solely to an administrative consideration as described in the response to EICB-RAl-3 above. Administrative in nature, the cause of the inoperability would not be expected to affect the ability of the equipment to perform its specified safety function, and therefore, would have no risk impact on the function of the equipment. Consistent with item 11.3 in NEI 06-09, PRA functionality may be applied if the function affected by the condition causing a component to be inoperable is not modeled in the PRA, and the function has been evaluated and documented in the RMTS program as having no risk impact.

APLA RAI 8 - PRA Functionality (REVISED)

Model Application to TSTF-505, Revision 1, "Proposed Revision to the Model Application for TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b'," Enclosure 1 (ADAMS Accession No. ML12032A065) states:. ,

This enclosure should provide a description of PRA functionality for each associated specified safety function that corresponds to each proposed Required Action that is applicable when all trains of equipment are inoperable as discussed in Section 2.3.1.1 O of NEI 06-09.

The TSTF-505 enclosure guidance is included as part of the model application because the NRG staff seeks clarity in how PRA Functionality will be used during full power operation following "loss of a specified safety function or inoperability of all required trains or divisions of a system." Provide justification for PRA functionality for each associated specified safety function consistent with TSTF-505 as requested below:

Florida Power & Light Company L-2016-136 Page 5of12 Enclosure A. To provide confidence that the defense-in-depth philosophy is maintained as the completion times (CTs) are extended, the NRC staff requests the following information for three of the defense-in-depth "circumstances" described in RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," Revision 1, May2011.

I. System redundancy, independence, and diversity are maintained commensurate with the expected frequency and consequences of challenges to the system (e.g.,

there are no risk outliers). The licensee should consider... whether there are appropriate restrictions in place to preclude simultaneous equipment outages that would erode the principles of redundancy and diversity.

Beyond prohibiting voluntary entry, the guidance on PRA Functionality in NEI 06-09 does not address how PRA Functionality should be defined when the systems, structures, and components (SSCs) normally relied on to perform a specified safety function are unavailable. Specifically, the PRA often includes alternative SSCs that could be used to fulfill a specified safety function when the SSCs referenced in the TSs are unavailable. Crediting alternative SSCs when the SSCs normally relied on are unavailable would represent a reduction in redundancy or diversity.

a. Please confirm that SSCs credited in a PRA Functionality determination are the same SSCs relied upon to perform the specified safety function.

b. If a PRA Functionality determination for a loss of a specified safety function or inoperability of all required trains or divisions of a system credits alternative SSCs to replace the SSCs covered by the TS (e.g., crediting the Fire Protection system as an alternative water source), please summarize each such TS and justify how appropriate redundancy and diversity is maintained.

c. If a PRA Functionality determination for a loss of a specified safety function or inoperability of all required trains or divisions of a system will not credit alternative SSCs to replace the SSCs covered by the TSs, then please add that constraint in TS 6.8.4 or propose an alternative location where changes would require prior NRC staff review and approval.

II. Over-reliance on programmatic activities as compensatory measures associated with the change in the licensing basis is avoided (e.g., the change does not use high reliability estimates that are primarily based on optimistic program assumptions).

a. Please confirm that all human actions required to achieve PRA functionality upon loss of specified safety function are modeled in the PRA (i.e., they are all explicitly proceduralized; and that they all are (1) trained on or (2) not trained on because they are so simple as to be skill of the craft).

b. If any human actions were evaluated and credited in the PRA scenarios, but not modeled in the PRA, then:

i. Summarize the action and the evaluation.

Florida Power & Light Company L-2016-136 Page 6of12 Enclosure ii. Clarify why not modelling each action will have a negligible impact on core damage frequency and large early release frequency and the associated CT that will be used when the corresponding PRA Function to TS LCO/Conditions is unavailable.

iii. If any other human actions are directly or indirectly credited in the CT length calculations, please provide the same information as in parts i and ii.

111. The intent of the plant's design criteria is maintained.

The intent of the design basis design criteria is that all design basis accident scenarios could be mitigated, i.e., the minimum specified safety function capability is available. To maintain this intent, PRA Functionality should not include any scenarios that allow any design basis accident initiator to proceed directly to core damage (e.g., Loss of Offsite Power/Loss of Coolant Accident).

Please confirm that PRA Functionality does not include any scenarios that allow any design basis accident to proceed directly to core damage or containment failure, or identify the scenarios and justify that the intent of the design criteria is maintained and describe how the PRA functionality determination will verify these requirements are met.

B. To provide confidence that sufficient safety margins are maintained, NRC Staff requests the following information for the detailed "circumstance" described in RG 1.177.

Safety analysis acceptance criteria in the final safety analysis report (FSAR) are met or proposed revisions provide sufficient margin to account for analysis and data uncertainties (e.g., the proposed TS CT or SF change does not adversely affect any assumptions or inputs to the safety analysis, or, if such inputs are affected, justification is provided to ensure sufficient safety margin will continue to exist). For TS CT

.changes, an assessment should be made of the effect on the FSAR acceptance criteria assuming the plant is in the condition addressed by the proposed CT (i.e., the subject equipment is inoperable) and there are no additional failures. Such an assessment should result in the identification of all situations in which entry into the condition addressed by the proposed CT could result in failure to meet an intended safety function.

Some TS safety functions are credited in design basis accident scenarios modelled in the PRA but are also required in other design basis accident scenarios not modelled in the internal events PRA because the other scenarios do not contribute to CDF and LERF or are not needed within the PRA mission time.

I. Please confirm that in order to enter a RICT on TS Loss of Function (LOF}, design basis success parameters that are not modeled in the design basis accident scenarios in the internal events PRA shall be met (e.g., containment spray may be credited as decay heat removal in some plants which is modeled in the PRA. It may also provide an iodine removal function for the same plants, which is not modeled in the PRA). Please add that constraint TS 6.8.4, or propose an alternative location

Florida Power & Light Company L-2016-136 Page 7of12 Enclosure where changes would require prior NRG staff review and approval. If the design basis success criteria parameters may not be met, justify how adequate safety margins are ensured, and provide some clarifying examples of the difference between design basis success parameters and the parameters allowed by the proposed TS LOF with the RICT.

II. Please confirm there are no safety functions required to reach a safe and stable state but are not included in the PRA because they are only required after the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months mission time generally used in the PRA (e.g., some alternative primary water sources may lead to excessive boron dilution after some loss-of-coolant accidents but only after at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , so boron is not modelled in the PRA) or describe how the PRA functionality determination will provide confidence the requirements credited in design basis accident scenarios are met.

Ill. In Table E1-1 of its application dated December 23, 2014, the licensee noted differences between the design basis success criteria and the PRA success criteria for certain specified safety functions. However, the application did not address how safety margin was maintained for the case of a PRA functionality determination for a loss of a specified safety function or inoperability of all required trains or divisions of a system. Please confirm that in order to enter a RICT on TS LOF, design basis success criteria parameters shall be met for design basis accident scenarios modelled in the internal events PRA. Please add that constraint in TS 6.8.4, or propose an alternative location where changes would require prior NRG staff review and approval. If the design basis success criteria parameters may not be met, then please elaborate on how adequate safety margins are maintained, and provide some clarifying examples of adequate safety margins for where the PRA success criteria parameters (e.g., flow rates, temperature limits) differ from the design criteria.

C. Extended completion times are limited to no more than 30 days, i.e., a 30-day "backstop." During the Audit, FPL mentioned the possibility of administratively limiting the time in total loss of function LCOs (i.e., both/all trains inoperable) to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when using a PRA functional argument. Explain how FPL will incorporate this 24-hour limit into the technical specifications.

D. Please identify any proposed TSs where a RICT is allowed upon loss of a specified safety function or inoperability of all required trains or divisions TSs condition that do not meet the following constraints:

Alternative SSCs' cannot replace the SSCs covered by the TSs.

Design basis success criteria parameters shall be met for design basis accident scenarios that are not modelled in the internal event PRA.

Design basis success criteria parameters shall be met for design basis accident scenarios modelled in the internal events PRA.

For every identified proposed TS that cannot meet the above constraints (e.g., allowing entering a RICT with less than 100 percent ECCS flow equipment available), justify how safety margins and defense-in-depth are maintained, or eliminate the proposed TS RICT entry.

Florida Power & Light Company L-2016-136 Page 8of12 Enclosure FPL Response A.I.a. SSCs which would be credited in a PRA Functionality determination must be the same SSCs relied upon to perform the specified safety function to meet the associated TS LCO. No credit is taken for any SSCs other than those SSCs covered by the TS LCO when establishing PRA Functionality for a loss of a specified safety function or inoperability of all required trains or divisions of a system.

A.Lb. As per response to A.I.a., no alternative SSCs are used.

A.l.c. As described in NEI 06-09, Section 2.3.1.10, one or more of the trains must be PRA Functional; in this context, "trains" refers to the "trains of equipment required by the TS LCO." Consequently, this requirement is already included. *

A.II.a. Only human actions which are modeled in the PRA are credited when establishing a RICT for loss of a specified safety function for a PRA Functional train. All such actions in the PRA model are credited consistent with the associated PRA standard as endorsed by the NRC in Regulatory Guide 1.200.

A.11.b. There are no human actions evaluated and credited in PRA scenarios not modeled in the PRA.

A.Ill. The requirement that one train of equipment bePRA Functional ensures its availability to mitigate accident scenarios in order to prevent core damage, such that no event would proceed directly to core damage or containment failure.

B. I. For safety functions which are not in the scope of the PRA, the RICT Program would not be applicable, and if the inoperability also affected these functions, the associated TS action requirements would apply and use of the RICT Program is not allowed ..

B.11. There are no safety functions not included in the PRA due to their applicability after the 24-hour mission time of the PRA.

B.111. Consistent with NEI 06-09 and the NRC safety evaluation, when no safety train is operable but one train is PRA Functional, adequate safety margin is maintained by the PRA Functional train. If the train is considered inoperable but PRA Functional based on less restrictive success criteria associated with the PRA still being met by an inoperable train, then this PRA Functional train has adequate capability to prevent core damage or a large early release, but may not meet other safety analysis assumptions. This is consistent with RG 1.177 regulatory position 2.2, which states that if the proposed TS change adversely affects any assumptions or inputs to the safety analysis, justification is provided to ensure sufficient safety margin will continue to exist. By maintaining a PRA Functional train, no core damage or large early release will occur, and this represents a justifiably sufficient safety margin for the limited period of time the RICT will be in effect, consistent with NRG-approved NEI 06-09 and TSTF-505.

Florida Power & Light Company L-2016-136 Page 9of12 Enclosure The changes to TS proposed by FPL are consistent with the NRG-approved Ghanges to standard TS in TSTF-505; therefore, there is no unique safety margin impact resulting from the proposed plant-specific TS changes.

The use of PRA Functionality as a basis for maintaining adequate plant safety while a time-limited Technical Specification action is applicable is unique to TSTF-505 as a risk-informed application. However, similar safety arguments are made and found acceptable to the NRC staff when addressing inoperable equipment for NOEDs, where the licensee evaluates the specific reason for component inoperability and justifies continued operation for a limited time period to permit restoration of the components to operable status. NEI 06-09 provides a NRG-approved method for a licensee to evaluate the cause of inoperability and to continue to operate under the provisions of the RICT Program when at least one train satisfies the PRA success criteria. This approved method complies with 10 CFR 50.36 as an alternative to a plant shutdown when the LCO is not met. The basis for decisions on PRA Functionality is required to be documented and available for NRC review.

The capability to prevent core damage and large early releases ensures that any offsite consequences (i.e., radiological releases) would be small and consistent with the principles of risk-informed regulation per RG 1.174 and RG 1.177, and provides adequate safety margin during the time-limited TS action which applies while the TS LCO is not met. Ensuring prevention of core damage and large early releases consistent with the process of NEI 06-09 is an acceptable staff-approved action when the TS LCO is not met consistent with 10CFR50.36.

C. FPL proposes to incorporate a 24-hour limit on the risk informed completion time used for emergent conditions involving a loss of specified safety function or inoperability of all trains if one or more trains are PRA functional. This limit will be included in the Risk Informed Completion Time Program that will be added to the TS in Section 6.0, Administrative Controls. Item (v) in the proposed program will be revised to state:

(v) Use of a RICT, not to exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be .

OPERABLE if one or more of the trains are considered "PRA functional" as defined in Section 2.3.1 of NEI 06-09 Attachment 1 contains a markup of the TS showing the revised proposed change, and a clean TS page is provided in Attachment 2.

D. See responses A.I.a., B.I., and A.Ill.

Florida Power & Light Company L-2016-136 Page 10of12 Enclosure SBPB RAl-1 In the event of one inoperable main steam isolation valve (MSIV}, the current TS 3.7.1.5 requires entry into "Hot Standby" after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Turkey Point LAR proposed to revise the TS to require entry into MODE 2, after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . As a basis for this change, the LAR indicates TSTF-505 contains incorrect structure, and in order to establish the correct structure for Turkey Point TS 3. 7 .1.5, FPL proposes that the required actions (RAs) for one or more inoperable MSIVs in Mode 1 require entering Mode 2, rather than Modes 3 and 4, if the MS IVs are not restored to operable status within the completion time (CT). While these changes are consistent with the STSs, this is a deviation from the current TS and allows an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in MODE 2. The staff is unable to locate a clear justification for this mode change.

Please provide a technical justification for the proposed change from Hot Standby to MODE 2.

In addition, the LAR indicates this change aligns the Turkey Point TSs with TSTF-505 and is appropriate qecause it provides a subsequent RA if entry into Mode 2 is required because two or more inoperable MSIVs in Mode 1 are not restored to operable status within the CT. For complete alignment with TSTF-505, the staff finds the following actions missing from proposed TS change: (1) TSTF-505 includes a [8] hours completion time for closing MSIV for one or more MSIVs inoperable in MODE 2 or 3, but the proposed change to TS 3. 7.1.5 does not specify a time limit for closing an inoperable MSIV in Modes 2 or 3; and (2) TSTF-505 includes a condition to verify MSIV is closed once per 7 days, but the proposed TS is missing any action for MSIV closure verification. Please provide an explanation why the LAR did not request adoption of the completion time and periodic MSIV closure verification. I FPL Response Turkey Point TS 3. 7 .1.5, MS IVs, contains two Actions, one that applies in Mode 1 and a second that applies in Modes 2 and 3. With one MSIV inoperable in Mode 1 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , current TS 3.7.1.5 requires the plant to be in Mode 3 within six hours and in Mode 4 within the following six hours. However, the Action that is applicable during operation in Modes 2 and 3 permits unlimited operation in these Modes provided the inoperable MSIV is maintained closed. As a result, a conflict exists between the two Actions. While the Mode 1 Action directs a shutdown to Mode 4, once the plant exits Mode 1, the Mode 1 Action is no longer applicable, and the Action that applies in Modes 2 and 3 establishes the remedial measures. If the inoperable MSIV is maintained closed, this Action permits unlimited operation in Modes 2 and 3. With an inoperable MSIV in the closed position, the valve is performing its specified function of isolating the steam generators. Therefore, a shutdown to Mode 4 to exit the mode of Applicability of TS 3.7.1.5, would be required only ifthe inoperable MSIV could not be maintained closed.

FPL proposes to revise the Action for an inoperable MSIV in Mode 1 to require the plant to enter Mode 2 if the MSIV is not restored to operable status within the completion time. Once the plant exits Mode 1, the Mode 1 Action, which directs a shutdown to Mode 4, no longer applies.

Therefore, it is appropriate for the Mode 1 Action to direct remedial measures for Mode 1 operation, and if the inoperable MSIV is not restored to operable status within the completion time, to direct exiting Mode 1. Once the plant enters Mode 2, the Action that applies in Modes 2 and 3 becomes effective and the Mode 1 Action is no longer applicable. Therefore, the Mode 2 and 3 Action, rather than the Mode 1 Action, is appropriate for directing a shutdown to Mode 4 when required.

Florida Power & Light Company L-2016-136 Page 11of12 Enclosure TSTF-505 modified standard TS 3.7.2, MSIVs, to (1) add a risk informed completion time to required action A.1 for an inoperable MSIV, and (2) add new condition C for two or more MSIVs inoperable in Mode 1. The required actions to close the MSIVs within eight hours and to verify the MSIVs are closed once per seven days when MSIVs are inoperable in Modes 2 and 3 existed previously and were not added by TSTF-505. Therefore, FPL did not include these required actions in the LAR. For the condition of an inoperable MSIV in Modes 2 and 3, the Turkey Point TS only require that the valve is maintained closed.

As part of adopting the MSIV related TS changes in TSTF-505, FPL proposes to incorporate additional required actions for Modes 2 and 3 to (1) close the inoperable MSIVs within eight hours, and (2) verify the inoperable MSIVs are closed once per seven days. These changes will align Turkey Point TS 3. 7 .1.5 more closely with standard TS 3. 7 .2 in TSTF-505.

The Action in TS 3. 7.1.5 is revised as shown below:

MODES 2 and 3:

With one MSIV inoperable, subsequent operation in MODE 2 or 3 may proceed provided the isolation valve is maintained closed. Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

With one or more MS/Vs inoperable, subsequent operation in MODE 2 or 3 may continue provided:

1. The inoperable MS/Vs are closed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and

2. The inoperable* MS/Vs are verified closed once per 7 days.

Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . contains a markup of the TS showing the revised proposed change, and a clean TS page is provided in Attachment 2.

Supplement to Proposed Changes Following Receipt of Amendments 267 and 262 LAR 236 discussed that it contained proposed changes to the same TS that are included in LAR 212, "Proposed Changes to Turkey Point Technical Specifications (TS) Regarding Non-conservative Action and Surveillance Requirement in TS 3/4.5.2," which FPL submitted in November 2014. LAR 236 also stated that following receipt of an amendment in response to LAR 212, FPL intended to supplement the LAR with proposed changes to the amended TS to incorporate risk informed completion times. The NRC issued Amendments 267 and 262 for Turkey Point Units 3 and 4, respectively, in November 2015 with changes to TS 3.5.2 to correct non-conservative requirements and make editorial changes to the TS. Therefore, FPL has provided in Attachment 1 revised markups of the proposed changes to TS 3.5.2. Clean pages with the proposed changes are included in Attachment 2, and Attachment 3 contains the updated Bases changes.

The change to TS 3.5.2 included the addition of new Action 'h' to restore the suction flow path from the refueling water storage tank to operable status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in hot shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . FPL proposes

Florida Power & Light Company L-2016-136 Page 12of12 Enclosure to incorporate a risk informed completion time for this action. The Turkey Point emergency core cooling system (ECCS) configuration has common suction piping from the refueling water storage tank (RWST), so loss of the flow path could render the ECCS inoperable. Action 'h' is similar to required action B.1 in TS 3.5.4 in TSTF-505 for the condition in which the RWST is inoperable for reasons other than boron concentration out of limits. For this condition, the ECCS system cannot perform its design function, and the standard TS provides a completion time of one hour or in accordance with the Rick Informed Completion Time Program to restore RWST operability. Therefore, the proposed change to Turkey Point TS 3.5.2, Action 'h' is consistent with TSTF-505 for a condition in which the ECCS cannot perform its design function.

ATIACHMENTS

1. Markup of the Technical Specifications

2. Revised Technical Specification Pages

3. Proposed Bases Changes (Information Only)

Florida Power & Light Company L-2016-136 Attachment 1 ATTACHMENT 1 Markup of the Technical Specifications (7 pages follow)

INSERT 1 or in accordance with the Risk Informed Completion Time Program, INSERT 2

Note------------------------------..:______ _

Action i is not applicable when two RHR heat exchangers or two flow paths from the containment sump intentionally made inoperable.

i. With two RHR heat exchangers or two flow paths from the containment sump inoperable:

1. Restore at least one RHR heat exchanger and one flow path from the containment

_sump to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2. With one RHR heat exchanger or one flow path from the containment sump restored to OPERABLE status, comply with ACTION a for the remaining inoperable RHR heat exchangers or flow path from the containment sump.

Note-----------------------------------------

1. Action j is not applicable when three or more of the required Safety Injection pumps or associated discharge flow paths intentionally made inoperable.

2. Action j applies to both units simultaneously.

j. With three or more of the four required Safety Injection pumps or associated discharge flow paths inoperable and the opposite unit in MODE 1, 2, or 3:

1. Restore at least all but two inoperable Safety Injection pumps and associated discharge flow paths to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2. With all but two inoperable Safety Injection pumps or associated discharge flow paths restored to OPERABLE status, comply with ACTION d for the two remaining inoperable Safety Injection pumps or associated discharge flow paths ..

~~~-~--~---~----------~---------------Note---------------------------~------~---

Action k is not applicable when two or more of the required Safety Injection pumps or associated discharge flow paths intentionally made inoperable.

k. With two or more of the three required Safety Injection pumps or associated discharge flow paths inoperable and the opposite unit in MODE 4, 5, or 6:

1. Restore at least all but one inoperable Safety Injection pump and associated discharge flow path to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2. With all but one inoperable Safety Injection pump or associated discharge flow path restored to OPERABLE status, comply with ACTION e for the remaining inoperable Safety Injection pump.

~---------------------------------Note--------------~----------------------

Action I is not applicable when two or more required Safety Injection pumps are intentionally not powered from their associated diesel generator.

I. With two or more required Safety Injection pumps OPERABLE but not capable of being powered from their associated diesel generator:

1. Restore the capability of being powered from the associated diesel generator for at least all but one Safety Injection pump within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2. With all but one Safety Injection pump capable of being powered from the associated diesel generator, comply with ACTION f for the remaining Safety Injection pump not capable of being powered from its associated diesel generator.

Note-------------------------------------------

Action m is not applicable when two RHR pumps or associated discharge flow paths intentionally made inoperable.

m. With two RHR pumps or associated discharge flow paths inoperable:

1. Restore at least one inoperable RHR pump and associated discharge flow path to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2. With one inoperable RHR pump or associated discharge flow path restored to OPERABLE status, comply with ACTION g for the remaining inoperable RHR pump or associated discharge flow path.

INSERT 5

m. Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09, "Risk-Informed Tech11ical Specifications Initiative 4b: Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0-A, November 2006. The program shall include the following:

a. The RICT may not exceed 30 days;

b. A RICT may only be utilized in MODES 1 and 2;

c. When a RICT is being used, any plant configuration change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. Use of a RICT, not to exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more of the trains are considered "PRA functional" as defined in Section 2.3.1 of NEI 06-09.

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - Tavg GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION 3.5.2 The following Emergency Core Cooling System (ECCS) equipment and flow paths shall be OPERABLE :

a. 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,*

b. Two RHR heat exchangers,

c. Two RHR pumps with discharge flow paths aligned to the RCS cold legs,

d. A flow path capable of taking suction from the refueling water storage tank as defined in Specification 3.5.4, and

e. Two flow paths capable of taking suction from the containment sump.

APPLICABILITY: MODES 1, 2, and 3**.

ACTION : INSERT 1

a. With one RHR heat exc anger or suction flow path from the containment sump inoperable, restore the inoperable RHR h t exchanger or suction flow path from the containment sump to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. In the event the ECCS is actuated and injects water in the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date since January 1, 1990.

c. With one of the four required Safety Injection pumps or its associated discharge flow path inoperable v and the -opposite unit in MODE 1, 2, or 3, restore the pump or flow path to OPERABLE status within 1 30 days or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .***

only three Safety Injection (SI) pumps (two associated with the unit and one from the opposite unit) , each y capable of being powered from its associated OPERABLE diesel generator#, with discharge flow paths aligned /I to the RCS cold leg are required if the opposite unit is in MODE 4, 5, or 6.

- The provisions of Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 3 for the Safety Injection flow paths isolated pursuant to Specification 3.4.9.3 provided that the Safety Injection flow paths are restored to OPERABLE status prior to Tavg exceeding 380°F. Safety Injection flow paths may be isolated when Tavg is less than 380°F.

- - The provisions of Specifications 3.0.4 and 4.0.4 are not applicable.

lnoperability of the required diesel generators does not constitute inoperability of the associated Safety Injection I/

pumps. 1 TURKEY POINT- UNITS 3 & 4 3/4 5-3 AMENDMENT NOS. ~AND ~

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - Tavg GREATER THAN OR EQUAL TO 350°F INSERT 1

d. With two of the four required Safety lnjectio pumps or their associated discharge flow paths inoperable and the opposite unit in MODE 2, or 3, restore one of the two inoperable pumps or flow paths to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This ACTION applies to both units simultaneously. INSERT 1

e. With one of e three required Safety Injection pumps or its associated discharge flow path inoperable and the o osite unit in MODE 4, 5, or 6, restore the pump or flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months r be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . INSERT 1

f. With a required Safety Injection pump OPERABLE but not capab of being powered from its associated diesel generator, restore the capability w ithin 14 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDO within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

at

g. With an ECCS subsystem inoperable due o an RHR pump or its associated discharge flow path being inoperable, restore the inoperable R pump or its associated discharge flow path to OPERABLE status within 7 days be in as-least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following

h. With the suction flow path from the refueling water storage tank inoperable, restore the suction flow path to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the followi 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

INSERT 1 TURKEY POINT - UNITS 3 & 4 3/4 5-4 AMENDMENT NOS. ~ AND ~

With one or more MSIVs inoperable, subsequent operation in MODE 2 or 3 may continue provided:

1. The inoperable MSIVs are closed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and

2. The inoperable MSIVs are verified closed once per 7 days.

PLANT SYSTEMS Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MAIN STEAM LINE ISOLATION VALVES HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

LIMITING CONDITION FOR OPERATION 3.7.1.5 Each main steam line isolation valve (MSIV) shall"be OPERABLE.

APPLICABILITY: MODES 1, 2 , and 3.

ACTION :

INSERT 1 MODE 1:

~ With one MSIV inoperable but open , POWER RATION may continue provided the inoperabl valve is restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; otherwise be in IHOT y~DBIY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in FlOT SFlUTDO\"Jfl.J within the followin§ hours. e MODES 2 and 3: MODE 2 a

With one MS IV ino13eraale, suasequent 013eration in MODe 2 or A1ay wooeed wo*1ided the isolation 11al11e is A1aintained olosed. Otherwise, ae in FlOT STANDBY within the next hours and in FlOT e SFlUTDOWN within the followin § e hours.

SURVEI LLANCE REQUIREMENTS 4 .7.1.5 Each MSIV shall be demonstrated OPERABLE by verifying full closure within 5 seconds when tested pursuant to Specification 4.0.5. The provisions of Specification 4.0.4 are not applicable for entry into MODE 3.

Note-------------------------------------------------

Action b not applicable when two or more MSIVs intentionally made inoperable b . With two or more MSIVs inoperable in MODE 1, restore at least all but one inoperable MSIVs to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program or be in MODE 2 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . W ith all but one inoperable MSIV restored to OPERABLE status, comply with ACTION a for the remain ing inoperable MSIV.

TURKEY POINT - UNITS 3 & 4 3/4 7-10 AMENDMENT NOS. 4-37--AND ~

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

I. Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operations are met:

a. The Surveillance Frequency Control Program shall contain a list of frequencies of those Surveillance Requirements for which the frequency is controlled by the program .

b. Changes to the frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, " Risk-Informed Method for Control of INSERT 5 Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the frequencies established in the Surveillance Frequency Control Program .

6.8.5 DELETED TURKEY POINT - UNITS 3 & 4 6-14 AMENDMENT NOS. ~ AND ~

Florida Power & Light Company L-2016-136 Attachment 2 ATTACHMENT 2 Revised Technical Specification Pages (6 pages follow)

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS -T-' GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION 3.5.2 The following Emergency Core Cooling System (ECCS) equipment and flow paths shall be OPERABLE:

a. 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,*

b. Two RHR heat exchangers,

c. Two RHR pumps with discharge flow paths aligned to the RCS cold legs,

d. A flow path capable of taking suction from the refueling water storage tank as defined in Specification 3.5.4, and

e. Two flow paths capable of taking suction from the containment sump.

APPLICABILITY: MODES 1, 2, and 3**.

ACTION:

a. With one RHR heat exchanger or suction flow path from the containment sump inoperable, restore the inoperable RHR heat exchanger or suction flow path from the containment sump to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. In the event the ECCS is actuated and injects water in the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date since January 1, 1990.

c. With one of the four required Safety Injection pumps or its associated discharge flow path inoperable and the opposite unit in MODE 1, 2, or 3, restore the pump or flow path to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .***

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 generatol, with discharge flow paths aligned to the RCS cold leg are required if the opposite unit is in MODE 4, 5, or 6.

- The provisions of Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 3 for the Safety Injection flow paths isolated pursuant to Specification 3.4.9.3 provided that the Safety Injection flow paths are restored to OPERABLE status prior to Tavg exceeding 380°F. Safety Injection flow paths may be isolated when Tavg is less than 380°F.

- - The provisions of Specifications 3.0.4 and 4.0.4 are not applicable.

lnoperability of the required diesel generators does not constitute inoperability of the associated Safety Injection pumps.

TURKEY POINT - UNITS 3 & 4 3/4 5-3 AMENDMENTNOS. AND

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - Tl!l!R GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION

d. With two of the four required Safety Injection pumps or their associated discharge flow paths inoperable and the opposite unit in MODE 1, 2, or 3, restore one of the two inoperable pumps or flow paths to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This ACTION applies.to both units simultaneously.

e. With one of the three required Safety Injection pumps or its associated discharge flow path inoperable and the opposite unit in MODE 4, 5, or 6, restore the pump or flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

f. With a required Safety Injection pump OPERABLE but not capable of being powered from its associated diesel generator, restore the capability within 14 days or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

g. With an ECCS subsystem inoperable due to an RHR pump or its associated discharge flow path being inoperable, restore the inoperable RHR pump or its associated discharge flow path to OPERABLE status within 7 days or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDSY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . *

h. With the suction flow path from the refueling water storage tank inoperable, restore the suction flow path to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Note: Action i is not applicable when two RHR heat exchangers or two flow paths from the containment sump intentionally made inoperable.

i. With two RHR heat exchangers or two flow paths from the containment sump inoperable:

1) Restore at least one RHR heat exchanger and one flow path from the containment sump to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2) With one RHR heat exchanger or one flow path from the containment sump restored to OPERABLE status, comply with ACTION a for the remaining inoperable RHR heat exchangers or flow path from the containment sump.

TURKEY POINT - UNITS 3 & 4 3/4 5-4 AMENDMENTNOS. AND

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS-T!!l!fl GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION (Continued)

Note: 1) Action j is not applicable when three or more of the required Safety Injection pumps or associated discharge flow paths intentionally made inoperable.

2) Action j applies to both units simultaneously.

j. With three or more of the four required Safety Injection pumps or associated discharge flow paths inoperable and the opposite unit in MODE 1, 2, or 3:

1) Restore at least all but two inoperable Safety Injection pumps and associated discharge flow paths to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2) With all but two inoperable Safety Injection pumps or associated discharge flow paths restored to OPERABLE status, comply with ACTION d for the two remaining inoperable Safety Injection pumps or associated discharge flow paths Note: Action k is not applicable when two or more ofJhe required Safety Injection pumps or associated discharge flow paths intentionally made'inoperable.

k. With two or more of the three required Safety Injection pumps or associated discharge flow paths inoperable and the opposite unit in MODE 4, 5, or 6:

1) Restore at least all but one inoperable Safety Injection pump and associated discharge flow path to OPERABLE status within one hour.or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2) With all but one inoperable Safety Injection pump or associated discharge flow path restored to OPERABLE status, comply with ACTION e for the remaining inoperable Safety Injection *pump.

Note: Action I is not applicable when two or more required Safety Injection pumps are intentionally not powered from their associated diesel generator.

I. With two or more required Safety Injection pumps OPERABLE but not capable of being powered from their associated diesel generator:

1) Restore the capability of being powered from the associated diesel generator for at least all but one Safety Injection pump within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2) With all but one Safety Injection pump capable of being powered from the associated diesel generator, comply with ACTION f for the remaining Safety Injection pump not capable of being powered from its associated diesel generator.

TURKEY POINT - UNITS 3 & 4 3/4 5-4a AMENDMENT NOS. AND I

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS-T' GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION (Continued)

Note: Action m is not applicable when two RHR pumps or associated discharge flow paths intentionally made inoperable.

m. With two RHR pumps or associated discharge flow paths inoperable:

1) Restore at least one inoperable RHR pump and associated discharge flow path to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2) With one inoperable RHR pump or associated discharge flow path restored to OPERABLE status, comply with ACTION g for the remaining inoperable RHR pump or associated discharge flow path.

. TURKEY POINT - UNITS 3 & 4 3/4 5-4b AMENDMENT NOS. AND I

PLANT SYSTEMS MAIN STEAM LINE ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.7.1.5 Each main steam line isolation valve (MSIV) shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

MODE 1:

a. With one MSIV inoperable but open, POWER OPERATION may continue provided the*

inoperable valve is restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or in accordance with the Risk Informed Completion Time Program; otherwise be in MODE 2 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Note: Action b is not applicable when two or more MSIVs intentionally made inoperable.

b. With two or more MSIVs inoperable in MODE 1, restore at least all but one inoperable MSIVs to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program or be in MODE 2 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With all but one inoperable MSIV restored to OPERABLE status, comply with ACTION a for the remaining inoperable MSIV.

MODES 2 and 3:

With one or more MSIVs inoperable, subsequent operation in MODE 2 or 3 may continue provided:

1. The inoperable MSIVs are closed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and

2. The inoperable MSl.Vs are verified closed once per 7 days.

Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEI LLANCE REQUIREMENTS 4.7.1.5 Each MSIV shall be demonstrated OPERABLE by verifying full closure within 5 seconds when tested pursuant to Specification 4.0.5. The provisions of Specification 4.0.4 are not applicable for entry into MODE 3.

TURKEY POINT - UNITS 3 & 4 314 7-10 AMENDMENTNOS. AND

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

I. Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operations are met:

a. The Surveillance Frequency Control Program shall contain a list of frequencies of those Surveillance Requirements for which the frequency is controlled by the program.

b. Changes to the frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the frequencies established in the Surveillance Frequency Control Program.

m. Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09, "Risk-Informed Technical Specification Initiative 4b: Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0-A, November 2006.

The program shall include the following:

a. The RICT may not exceed 30 days;

b. A RICT may only be utilized in MODES 1 and 2;

c. When a RICT is being used, any plant configuration change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. Use of a RICT, not to exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more of the trains are considered "PRA functional" as defined in Section 2.3.1 of NEI 06-09.

6.8.5 DELETED TURKEY POINT - UNITS 3 & 4 6-14 AMENDMENTNOS. AND

/

Florida Power & Light Company L-2016-136 Attachment 3 ATTACHMENT 3 Proposed Bases Changes (Information Only)

(2 pages follow)

REVISION NO.: PROCEDURE TITLE: PAGE:

17 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 128 of 209 PROCEDU RE NO. :

O-ADM-536 TURKEY POINT PLANT ATTACHMENT 2 Technical Specification Bases (Page 111 of 192) 3/4 .5.2 & 3/4.5 .3 (Continued)

TS 3 .5 .2 , Action g. provides an allowed outage/action completion time (AOT) of up to 7 days or in accordance with the Risk Informed Completion Time Program to restore an inoperable RHR Pump to OPERABLE status, provided the affected ECCS Subsystem is inoperable only because its associated RHR pump is inoperable . This 7 day AOT is based on the results of a deterministic and probabilistic safety assessment, and is referred to as a Risk-Informed AOT Extension . Planned entry into this AOT requires that a Risk Assessment be performed in accordance with the Configuration Risk Management Program (CRMP}, which is described in the administrative procedure that implements the Maintenance Rule pursuant to 10 CFR 50.65. If an RHR pump suction isolation valve (3/4-752A or B) is CLOSED, then one of the two required flow paths from the containment sump becomes INOPERABLE and TS LCO 3 .5.2.e is NOT met. In this case , TS 3.5.2, Action a , is entered and the AOT for the inoperable flow path is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

TS 3.5 .2 , Action h. limits the allowed outage time for an inoperable RWST flow path from the RWST(s) required by TS 3 .5.4 to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months consistent with the allowed outage time for a required RWST.

TS 3. 5.2, Action i With two RHR heat exchangers or two flow paths from the containment sump inoperable, Action i requires restoring the inoperable heat exchangers or flow paths to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program.

The Action is modified by a Note stating it is not applicable when two RHR heat exchangers or two flow paths from the containment sump intentionally made inoperable.

This Action is not intended for voluntary removal of redundant systems or components from service. The Action is only applicable if one RHR heat exchanger or flow path is inoperable for any reason and a second RHR heat exchanger or flow path is found inoperable, or if two RHR heat exchangers or flow paths are found inoperable at the same time.

TS 3. 5. 2. Action j With three or more of the four required Safety Injection pumps or associated discharge flow paths inoperable and the opposite unit in MODE 1, 2, or 3, Action j requires restoring Safety Injection pumps and associated discharge flow paths to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program. The Action is modified by a Note stating it is not applicable when three or more of the required Safety Injection pumps or associated discharge flow paths are intentionally made inoperable. This Action is not intended for voluntary removal of redundant systems or components from service. The Action is only applicable if two Safety Injection pumps or associated discharge flow paths are inoperable for any reason and additional Safety Injection pumps or associated discharge flow paths are found inoperable, or if three or more Safety Injection pumps or associated discharge flow paths are found inoperable at the same time.

TS 3. 5. 2. Action k With two or more of the three required Safety Injection pumps or associated discharge flow paths inoperable and the opposite unit in MODE 4, 5, or 6, Action k requires restoring Safety Injection pumps and associated discharge flow paths to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program. The Action is modified by a Note stating it is not applicable when two or more of the required Safety Injection pumps or associated discharge flow paths are intentionally made inoperable. This Action is not intended for voluntary removal of redundant systems or components from service. The Action is only applicable if one Safety Injection pump or associated discharge flow paths is inoperable for any reason and additional Safety Injection pumps or associated discharge flow paths are found inoperable, or if two or more Safety Injection pumps or associated discharge flow paths are found inoperable at the same time.

TS 3. 5. 2. Action I With two or more required Safety Injection pumps OPERABLE but not capable of being powered from their associated diesel generator, Action I requires restoring capability within two hours or in accordance with the Risk Informed Completion Time Program.

The Action is modified by a Note stating it is not applicable when two or more required Safety Injection pumps intentionally not powered from their associated diesel generator.

This Action is not intended for voluntary removal of redundant systems or components from service. The Action is only applicable if one Safety Injection pump is not capable of being powered from its associated diesel generator for any reason and additional Safety Injection pumps are found incapable of being powered from their associated diesel generator, or if two or more Safety Injection pumps are found incapable at the same time .

.TS 3. 5. 2. Action m With two RHR pumps or associated discharge flow paths inoperable, Action I requires restoring the RHR pumps and flow paths to OPERABLE status within one hour or in accordance with the Risk Informed Completion Time Program. The Action is modified by a Note stating it is not applicable when two RHR pumps or associated discharge flow paths are intentionally made inoperable. This Action is not intended for voluntary removal of redundant systems or components from service. The Action is only applicable if one RHR pump or associated flow path is inoperable for any reason and the other RHR pump or associated flow path is found inoperable, or if two RHR pumps or associated flow paths are found inoperable at the same time.

v t e Letter Sequence Response to RAI
CAC:MF5455, Provide RISK-INFORMED Extended Completion Times - RITSTF Initiative 4B (Approved, Closed)
Initiation Request, Request, Request, Request, Request Acceptance... Supplement, Supplement Administration Questions 27 June 2017 3 August 2017 18 July 2017 19 April 2018 14 April 2016 18 April 2016 1 June 2016 30 March 2017 10 August 2017 1 March 2018 17 May 2018 Answers 16 June 2016 11 August 2016 Results Approval Other: ML16036A307, ML16154A012, ML18151A434, ML18303A243
MONTHYEAR2017-06-27 [Table View]

L-2016-136, Second Response to Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide...

Text

References:

Navigation menu

L-2016-136, Second Response to Request for Additional Information Regarding License Amendment Request 236, Revision to the Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide...

Text

References:

Navigation menu

Search