ML15205A174

Issuance of Amendments Regarding Removal of Reactor Coolant System Chemistry Requirements from the Technical Specifications and Relocation of Requirements in Licensee-Controlled Documents

ML15205A174
Person / Time
Site:	Turkey Point
Issue date:	08/14/2015
From:	Audrey Klett Plant Licensing Branch II
To:	Nazar M Nextera Energy
Klett A
References
TAC MF4725, TAC MF4726
Download: ML15205A174 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 14, 2015 Mr. Mano Nazar President and Chief Nuclea~ Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 - ISSUANCE OF AMENDMENTS REGARDING REMOVAL OF REACTOR COOLANT SYSTEM CHEMISTRY REQUIREMENTS FROM THE TECHNICAL SPECIFICATIONS AND RELOCATION OF REQUIREMENTS IN LICENSEE-CONTROLLED DOCUMENTS (TAC NOS. MF4725 AND MF4726)

Dear Mr. Nazar:

The U.S. Nuclear Regulatory Commission (NRG or the Commission) has issued the enclosed Amendment No. 265 to Renewed Facility Operating License (RFOL} No. DPR-31 arid Amendment No. 260 to RFOL No; DPR-41 for the Turkey Point Nuclear Generating Unit Nos. 3 and 4, respectively. The amendments change the Technical Specifications (TSs) in response to the application from Florida Power & Light Company (the licensee) dated August 29, 2014.

The amendments remove TS 3/4.4.7, "Chemistry," from the TSs and require inclusion of those specifications in the Updated Final Safety Analysis Report and related procedures, which the licensee is required to control by the provisions set forth in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.59, "Changes, tests, and experiments." The removal of TS 3/4.4.7 is consistent with the requirements in 10 CFR, Section 50.36, "Technical specifications."

M. Nazar I The NRC staff's safety evaluation of the amendments is enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Audrey L. Klett, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosures:

1. Amendment No. 265 to DPR-31

2. Amendment No. 260 to DPR-41

3. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-250 TURKEY POINT NUCLEAR GENERATING UNIT NO. 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 265 Renewed License No. DPR-31

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power & Light Company (the licensee) dated August 29, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Operating License and Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.8 of Renewed Facility Operating License No. DPR-31 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in, Appendix A, as revised through Amendment No. 265 are hereby incorporated into this renewed license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environ,mental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance. Implementation of the amendment shall also include revision of the Updated Final Safety Analysis Report and related procedures as described in the licensee's letter dated August 29, 2014.

• FOR THE NUCLEAR REGULATORY COMMISSION Shana R. Helton, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications

• Date of Issuance: August 1 4, 201 5

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT NUCLEAR GENERATING UNIT NO. 4 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 260 Renewed License No. DPR-41

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power & Light Company (the licensee) dated August 29, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will .operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Operating License and Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.8 of Renewed Facility Operating License No. DPR-41 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 260 are hereby incorporated into this renewed license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance. Implementation of the amendment shall also include revision of the Updated Final Safety Analysis Report and related procedures as described in the licensee's letter dated August 29, 2014.

FOR THE NUCLEAR REGULATORY COMMISSION Shana R. Helton, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear ReactorRegulation

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: August 1 4 , 201 5

ATTACHMENT TO LICENSE AMENDMENTS AMENDMENT NO. 265 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AMENDMENT NO. 260 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-41 DOCKET NOS. 50-250 AND 50-251 Replace page 3 of Renewed Facility Operating License DPR-31 with the attached page 3. The

• revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Replace page 3 of Renewed Facility Operating License DPR-41 with the attached page 3. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert vii vii 3/4 4-18 3/4 4-18 3/4 4-19 3/4 4-19 3/4 4-20 3/4 4-20 Attachment

3 E. Pursuant to the Act and 10 CFR Parts 40 and 70 to receive, possess, and use at any time 100 milligrams each of any source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactively contaminated apparatus; F. Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of Turkey Point Units Nos. 3 and 4.

3. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified below:

A. Maximum Power Level The applicant is authorized to operate the facility at reactor core power levels not in exce_ss of 2644 megawatts (thermal).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 265 are hereby incorporated into this renewed license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

C. Final Safety Analysis Report The licensee's Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d), as revised on November 1, 2001, describes certain future inspection activities to be completed before the period of extended operation.

The licensee shall complete these activities no later than July 19, 2012.

The Final Safety Analysis Report supplement as revised on November 1, 2001, described above, shall be included in the next scheduled update to the Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Unit 3 Renewed License No. DPR-31 Amendment No. 265

3 E. Pursuant to the Act and 10 CFR Parts 40 and 70 to receive, possess, and use at any time 100 milligrams each of any source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactively contaminated apparatus; F. Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of Turkey Point Units Nos. 3 and 4.

3. This renewed operating license shall be deemed to contain and is subject to the condi.tions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified below:

A. Maximum Power Level The applicant is authorized to operate the facility at reactor core power levels not in excess of 2644 megawatts (thermal).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 260 are hereby incorporated into this renewed license. The Environmental Protection Plan* contained in Appendix B is hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

C. Final Safety Analysis Report The licensee's Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d}, as revised on November 1, 2001, describes certain future inspection activities to be completed before the period of extended.operation.

The licensee shall complete these activities no later than April 10, 2013.

The Final Safety Analysis Report supplement as revised on November 1, 2001, described above, shall be included in the next scheduled update to the Final Safety Analysis Report required by 10 CFR 50.71 (e)(4}, following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

Unit 4 Renewed License No. DPR-41 Amendment No. 260

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION 314.4 REACTOR COOLANT SYSTEM 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION Startup and Power Operation......................................................................... 314 4-1 Hot Standby ..............................................................<<.................................... 314 4-2 Hot Shutdown................................................................................................. 314 4-3 Cold Shutdown - Loops Filled .................................. :...................................... 314 4-5 Cold Shutdown - Loops Not Filled.................................................................. 314 4-6 314.4.2 SAFETY VALVES Shutdown 314 4-7 Operating .. . ...... .. .. .. ......... .. .............. .. ........... .. ........ ................. .. .. ........ .. ..... 314 4-8 3/4.4.3 PRESSURIZER.............................................................................................. 314 4-9 3/4.4.4 RELIEF VALVES ........................................................................................... 314 4-10 3/4.4.5 STEAM GENERATOR (SG) TUBE INTEGRITY............................................ 314 4-12 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE Leakage Detection Systems ....................... :................................................... 314 4-13 Operational Leakage...................................................................................... 314 4-14 TABLE 3.4-1 REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES............ 314 4-17 3/4.4.7 DELETED TABLE 3.4-2 DELETED TABLE 4.4-3 DELETED 314.4.8 SPECIFIC ACTIVITY ................................................................... :.................. 314 4-21 TABLE 4.4-4

• REACTOR COOLANT SPECIFIC ACTIVITY SAMPLE AND ANALYSIS...... 314 4-22 TURKEY POINT - UNITS 3 & 4 vii AMENDMENT NOS. 265 AND 260

REACTOR COOLANT SYSTEM 3/4.4.7 DELETED TURKEY POINT - UNITS 3 & 4 3/4 4-18 AMENDMENT NOS. 265 AND 260

TABLE 3.4-2 DELETED TURKEY POINT- UNITS 3 & 4 3/4 4-19 AMENDMENT NOS. 265 AND 260

TABLE 4.4-3 DELETED TURKEY POINT UNITS 3 & 4 314 4-20 AMENDMENT NOS. 265 AND 260

• UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR

• AMENDMENT NO. 265 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AND AMENDMENT NO. 260 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-41 FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4

.DOCKET NOS. 50-250 AND 50-251

1.0 INTRODUCTION

By application dated August 29, 2014, 1 Florida Power & Light Company (the licensee) requested changes to the Technical Specifications (TSs) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point), which are contained in Appendix A of Renewed Facility Operating Licenses DPR-31 and DPR-41. The licensee proposed to remove Reactor Coolant System (RCS) chemistry requirements from the tss and maintain them in licensee-controlled documents. The licensee requested the elimination of the TS 3/4.4.7, "Chemistry," from the TSs and the inclusion of these requirements the Turkey Point Updated Final Safety Analysis Report (UFSAR) and related procedures. The U.S. Nuclear Regulatory Commission (NRC) staff's proposed no significant hazards consideration (NSHC) for this amendment was published in the Federal Register(FR) on November 25, 2014 (79 FR 70216).

2.0 REGULATORY EVALUATION

2.1. Description of the Turkey Point Design and Operation regarding RCS Chemistry The Turkey Point UFSAR states that each of the plants' nuclear steam supply systems consist of a pressurized water reactor, an RCS, and associated auxiliary fluid ~ystems. The RCS is arranged as three closed reactor coolant loops connected in parallel to the reactor vessel, each loop containing a reactor coolant pump and a steam generator. An electrically heated pressurizer is connected to one of the loops. Auxiliary systems charge the 'RCS and add makeup water, purify reactor coolant water, provide chemicals for corrosion inhibition and reactor control, and sample reactor coolant water. The materials of construction of the pressure 1

Agencywide Documents Access and Management Systems (ADAMS) Accession Number ML14252A230.

boundary of the RCS are protected by control of coolant chemistry from corrosion phenomena, which might otherwise reduce the system structural integrity during its service lifetime.

TS 3/4.4.7 contains a limiting condition for operation (LCO), which states that at all times, the RCS chemistry shall be maintained within the steady-state and transient limits provided in this TS. This TS also contains action statements for the licensee to follow when those limits are not met. This TS also contains a surveillance requirement for determining whether RCS chemistry is within the TS limits.

The Turkey Point TS Bases for TS 3/4.4.7, which are contained in Attachment 2 of the licensee's letter dated April 22, 2015, 2 state:

The limitations on [RCS] chemistry ensure that corrosion of the [RCS] is minimized and reduces the potential for [RCS] leakage or failure due to stress corrosion. Maintaining the chemistry within the Steady-State limits provides adequate corrosion protection to ensure the structural integrity of the [RCS] over the life of the plant. The associated effects of exceeding the oxygen, chloride, and fluoride limits are time and temperature dependent. Corrosion studies show that operation may be continued with contaminant concentration levels in excess of the Steady-State limits, up to the Transient Limits, for the specified limited time intervals without having a significant effect on the structural integrity of the [RCS].

The time interval permitting continued operation within the restrictions of the Transient Limits provides time for taking corrective actions to restore the contaminant concentrations to within the Steady[-]State limits.

The Surveillance Requirem~nts provide adequate assurance that concentrations in excess of the limits will be detected in sufficient time to take corrective action.

2.2 Regulatory Review The licensee requested to delete TS 3/4.4. 7 from the TSs. The licensee also requested that these requirements be relocated to the UFSAR_and related procedures and be controlled in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.59, "Changes, tests, and experiments." The NRC staff considered the following regulatory requirements, guidance, and plant-specific licensing and design basis information during its .

review of the licensee's request.

Section 50.36, "Technical Specifications," of 10 CFR contains the requirements for items that must be in the TSs. Paragraph 50.36(c)(2)(ii) of 10 CFR states that a TS LCO of a nuclear reactor must be established for each item meeting one or more of the following criteria:

Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

2 ADAMS Accession No. ML15139A080.

Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and*

safety.

In the FR notice that announced the final rulemaking that added t.hese four criteria to 10 CFR 50.36 (60 FR 36953; July 19, 1995), the NRC staff stated that the rule codifies criteria for determining .the content of TSs, and that each licensee covered by these regulations may .

voluntarily use the criteria as a basis to propose the relocation of existing TSs that do not meet any of the criteria from the facility license to licensee-controlled documents. The staff also stated in this FR notice that related surveillance requirements and actions would be retained for each LCO that remains in the TSs.

In its letter dated May 9, 1988, 3 from the Director of the Office of Nuclear Reactor Regulation, Thomas E. Murley, to Walter S. Wilgus of the Babcock and Wilcox Owners Group, the NRC staff documented its conclusions as to ~hich specifications must be retained in the Standard Technical Specifications (STSs) and which specifications could be relocated to other

• licensee-controlled documents, based on the staff's review of the Commission's Interim Policy Statement on Technical Specification Improvements, dated February 6, 1987 (52 FR 3788).

Appendix B, "Staff Review of Nuclear Steam Supply System Vendor Owners Groups' Application of the Commission's Interim Policy Statement," of the May 9, 1988, letter's enclosure lists Westinghouse STS LCO 3.4.7, "Chemistry," as an LCO that may be relocated to licensee-controlled documents.

Paragraph 50.34(b) of 10 CFR states that the final safety analysis report (FSAR) shall include information that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole. This regulation also states that the FSAR shall include a description and analysis of the structures, systems, and components of the facility, with emphasis upon performance

• requirements, the bases, with technical justification therefor, upon which such requirements have been established, and the evaluations required to show that safety functions will be accomplished. Such items as the RCS shall be discussed insofar as they are pertinent.

Paragraph 50.59(c)(1) states that a licensee can make changes in the facility or procedures as described in the UFSAR and conduct tests or experiments not described in the UFSAR without obtaining a license amendment pursuant to 10 CFR 50.90 if none of the criteria in 3 ADAMS Accession Number ML11264A057.

10 CFR 50.59(c)(2) are met. Paragraph 50.59(c)(3) of 10 CFR states that the UFSAR is considered to include FSAR changes resulting from evaluations performed pursuant to 10 CFR 50.59 and analyses performed pursuant to 10 CFR 50.90 since submittal of the last UFSAR pursuant to 10 CFR 50.71.

Section 4.2.8, "Water Chemistry," of the Turkey Point UFSAR states that water chemistry is selected to provide the necessary boron content for reactivity control and to minimize corrosion of RCS surfaces. The UFSAR states that during Mode 1, periodic analyses of the coolant chemical composition are performed to monitor the adherence of the system to the reactor coolant water quality specifications listed in UFSAR Table 4.2-2, "Reactor Coolant Water Chemistry Specificaiton (Mode 1 Normal Values)." The UFSAR states that the chemistry specifications and limits for shutdown and startup conditions are maintained as outlined in the Florida Power and Light Nuclear Chemistry Parameters Manual and the Turkey Point Chemistry Procedures. Maintenance of water quality to minimize corrosion is accomplished using the Chemical and Volume Control System and Sampling System.

Section 4.2.5, "Materials of Construction," of the Turkey Point UFSAR states that RCS materials exposed to the coolant are corrosion-resistant, consist of stainless steels and lnconel, and are chosen for specific purposes at various locations within the system for their superior compatibility with the reactor coolant. During Mode 1, the chemical composition of the reactor coolant is maintained within the specifications listed in UFSAR Table 4.2-2.

Table 4.2.2 of the Turkey Point UFSAR specifies values for the following items for Mode 1 operation: electrical conductivity; solution pH; oxygen; chloride; fluoride; hydrogen, total suspended solids, pH control agent, and boric acid.

3.0 TECHNICAL EVALUATION

In its application dated August 29, 2014, the licensee requested to delete TS 3/4.4.7 from the TSs. The NRC staff compared the proposed deletion of TS 3/4.4. 7 against the regulatory requirements of 10 CFR 50.36(c) and the guidance provided in the staff's letter dated May 9, 1988. TS 3/4.4. 7 provides limits on the oxygen, chloride, and fluoride content in the RCS to minimize corrosion. Maintaining chemistry parameters within limits provides protection from corrosion, which reduces the potential for RCS leakage or failure caused by corrosion mechanisms. Chemistry control can minimize corrosion over the long term, and inservice inspection of components can identify corrosion before significant degradation occurs.

Section 50.36 of 10 CFR contains the requirements for items that must be in the TSs.

Paragraph 50.36(c)(2)(ii) provides four criteria for determining when a TS LCO must be established. The NRC staff reviewed the current RCS Chemistry TS against each of these four criteria to determine whether this TS needs to continue to be included in the TSs. The NRC staff determined that the RCS chemistry limits do not meet Criterion 1 because the RCS chemistry limits are not installed instrumentation that is used to detect excessive RCS leakage.

The NRC staff determined that the RCS chemistry limits do not meet Criterion 2 because the RCS chemistry limits are not a process variable, design feature, or operating restriction that is an initial condition of a OBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The NRC staff determined that the RCS chemistry limits do not meet Criterion 3 because the RCS chemistry limits are not structures,

systems, or components that are part of the primary success path and which function or actuate to mitigate a OBA or transient that either assumes the failure of or presents a challenge to the integfity of a fission product barrier. The NRC staff determined that the RCS chemistry limits do not meet Criterion 4 because the RCS chemistry limits are not structures, systems, or components which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Because the RCS chemistry limits do not meet any of these criteria, the NRC staff determined that the licensee is not required to retain this LCO and its associated applicability, actions, and surveillance requirements in the TSs. This determination is also consistent with the NRC letter dated May 9, 1988, from Thomas E. Murley, to Walter S. Wilgus. Therefore, the NRC staff determined it is acceptable to delete TS 3/4.4.7 from the TSs.

In its application dated August 29, 2014, the licensee requested that TS 3/4.4. 7 be relocated to the UFSAR and related procedures. The licensee stated that following NRC approval of this*

proposed amendment, changes to the relocated requirements will be controlled by the provisions of 10 CFR 50.59 to determine if prior NRC approval is required. The NRC staff determined that relocation of the TS RCS chemistry TS 3/4.4.7 requirements, such as the steady-state and transient limits and the limits on oxygen, chloride, and fluoride content in the RCS, into the UFSAR and related procedures provides reasonable assurance that the licensee will inspect and maintain RCS chemistry to minimize corrosion of reactor coolant surfaces and ensure plant operation conforms with the design bases. Section 50.59 of 10 CFR requires the licensee to determine whether any changes to the chemistry requirements relocated into the UFSAR will need prior NRC approval via a license amendment.

Based on the aforementioned considerations, the NRC staff has concluded that it is acceptable to delete TS 3/4.4. 7 from the TSs and relocate such requirements to the UFSAR and related procedures to be controlled by the licensee in accordance with 10 CFR 50.59.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the NRC staff notified the State of Florida official (Ms. Cynthia Becker, M.P.H., Chief of the Bureau of Radiation Control, Florida Department of Health) on June 30, 2015, 4 of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued.a proposed finding that the amendrpents involve no significant hazards consideration, and there has been no public comment on suer finding 4 The NRC staff notified the State official by telephone and by e-mail. The e-mail is in ADAMS under Accession No. ML15189A456.

published in the FR on November 25, 2014 (79 FR70216). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

Based on the aforementioned considerations, the NRC staff concluded that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Matthew Yoder Candace Pfefferkorn Audrey Klett Date: August 14, 2015

ML15205A174 *by memorandum OFFICE NRR/DORL/LPL2-2/PMiT NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DE/ESGB/BC*

NAME CPfefferkorn A Klett

• BClayton GKulesa DATE 07/28/15 07/28/15 07/27/15 03/17/15 OFFICE NRR/DSS/STSB/BC OGCINLO NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME RElliott BHarris SHelton A Klett DATE 07/28/15 08/01 /15 . 08/14/15 08/14/15