L-2011-408, One-Time Exemption Request from Portions of 10 CFR 26.205(d)(3) - Work Hour Controls

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One-Time Exemption Request from Portions of 10 CFR 26.205(d)(3) - Work Hour Controls
ML11298A165
Person / Time
Site: Turkey Point NextEra Energy icon.png
Issue date: 10/14/2011
From: Kiley M
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2011-408
Download: ML11298A165 (11)
v • d • e


Text

0 OCT 14 2011 FPL. L-2011-408 POWERING TODAY. 10 CFR 26 EMPOWERING TOMORROW."

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Turkey Point Unit 3 Docket No. 50-250 RE: One-Time Exemption Request 10 CFR 26.205(d)(3) - Work Hour Controls Pursuant to 10 CFR 26.9, Specific exemptions, Florida Power & Light Company (FPL) hereby requests a one-time exemption from portions of 10 CFR 26.205(d)(3) for Turkey Point Unit 3.

Currently, 10 CFR 26.205(d)(4) and (d)(5) permit the use of less restrictive working hour limitations during the first 60 days of a unit outage, in lieu of the on-line working hour requirements in 10 CFR 26.205(d)(3). The proposed exemption would allow the use of less restrictive outage working hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) to support the activities related to the upcoming Unit 3 extended power uprate (EPU) refueling outage currently scheduled to start January 30, 2012 with an expected duration of greater than 116 days. The proposed exemption would apply to operations (who also compose the fire brigade), maintenance, security, chemistry and radiation protection personnel as defined in 10 CFR 26.4(a)(1) through (a)(5).

The proposed exemption request will not be applicable to personnel performing work as defined in 10 CFR 26.4(a)(1) through (a)(5) who are not involved in the specific work schedule phases described in the proposed exemption request. Personnel not working the schedules in the proposed exemption request will continue to meet the work hour controls of 10 CFR 26.205(d)(4) and (d)(5) during the first 60 days of the outage. Any needed extensions of the 60 day outage period will be implemented per 10 CFR 26.205(d)(6).

FPL requests consideration for approval of the exemption prior to the start of the Turkey Point Unit 3 refueling outage.

Details and supporting analysis for the exemption request are provided in Attachment 1. An Environmental Assessment supporting the exemption request is provided in Attachment 2. The NRC commitments made in this submittal are listed in Attachment 3.

If you have any questions or require additional information, please contact Robert Tomonto, Licensing Manager, at (305) 246-7327.

Very truly yours,

-Michael Kiley Site Vice President Turkey Point Nuclear Plant Attachments an FPL Group company

L-2011-408 Attachment 1 Page 1 of 6 Turkey Point Unit 3 One -Time Exemption Request from the Requirements of 10 CFR 26.205(d)(3)

Supportinq Analysis Summary Description Pursuant to 10 CFR 26.9, Specific exemptions, Florida Power & Light Company (FPL) hereby requests a one-time exemption from portions of 10 CFR 26.205(d)(3) for Turkey Point Unit 3.

Currently, 10 CFR 26.205(d)(4) and (d)(5) permit the use of less restrictive working hour limitations during the first 60 days of a unit outage, in lieu of the on-line working hour requirements in 10 CFR 26.205(d)(3). This proposed exemption would allow the use of less restrictive outage working hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) to support the activities related to the upcoming Unit 3 extended power uprate (EPU) refueling outage currently scheduled to start January 30, 2012 with an expected duration of greater than 116 days. The proposed exemption would allow FPL the scheduling flexibility needed during the EPU refueling outage for the outage periods when increased manpower is needed to complete activities related to the initial phase of the outage (core offload), and the final phase of the outage which includes core reload, system walkdowns, surveillance testing, and startup testing.

The proposed exemption would apply to operations (who also compose the fire brigade),

maintenance, security, chemistry and radiation protection personnel as defined in 10 CFR 26.4(a)(1) through (a)(5).

The proposed exemption request will not be applicable to personnel performing work as defined in 10 CFR 26.4(a)(1) through (a)(5) who are not involved in the work schedule phases described in the exemption request below. Personnel not working the schedules in the proposed exemption request will continue to meet the work hour controls of 10 CFR 26.205(d)(4) and (d)(5) during the first 60 days of the outage. Any needed extensions of the 60 day outage period will be implemented per 10 CFR 26.205(d)(6).

Detailed Description On January 30, 2012, Turkey Point Unit 3 will begin an EPU refueling outage. This outage is longer than normal due to extensive modifications that are being performed related to the FPL application for EPU. A typical refueling outage is usually performed in approximately 4 to 6 weeks, depending on the work scope for the particular refueling outage. The typical refueling outage can be categorized into three distinct periods: Phase 1, the period from unit shutdown to completion of core offload window; Phase 2, the defueled window; and Phase 3, the period from commencement of core reload to startup testing. The Turkey Point Unit 3 EPU refueling outage will differ from normal refueling outages in several ways:

Phase I, the period from shutdown to completion of core offload, will be extended from the normal 2 week period due to the work being performed on the Spent Fuel Pool (SFP) cooling system. A completely redundant independently powered SFP cooling loop will be added to the existing SFP cooling loop. The core offload will not commence until the SFP work is complete.

L-2011-408 Attachment 1 Page 2 of 6 During Phase 2, the defueled window, multiple projects related to the EPU will be implemented. This extended defueled window is required to facilitate implementation of multiple projects which impact the ability to close the equipment hatch within the required time to establish containment isolation, should it be required. The containment isolation requirements are only applicable when the fuel is in the core. In addition, some of the projects being implemented during this outage affect our ability to perform core reload activities due to space requirements on the refueling floor, consequently extending the time of the defueled window.

  • Phase 3 encompasses the core reload, reactor reassembly, surveillance testing and startup testing prior to power ascension. During this period the fuel will be reloaded into the core followed by startup testing. The EPU project requires the installation of new systems and modification of currently installed systems. Extensive system restoration walkdowns and testing are required to be performed prior to the restart of Turkey Point Unit 3.

As a result, the Turkey Point Unit 3 EPU refueling outage duration is currently scheduled for more than 116 days. 10 CFR 26.205(d)(4) and (d)(5) permit the use of less restrictive working hour limitations during the first 60 days of a unit outage, in lieu of the on-line working hour requirements in 10 CFR 26.205(d)(3). In addition, 10 CFR 26.205(d)(6) allows the extension of the 60-day period in 7-day increments for each non-overlapping 7-day period an individual works not more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during the first 60 days of a unit outage. Therefore, taking into consideration the allowed extension specified in 10 CFR 26.205(d)(6), the maximum number of days a licensee is permitted to use the less restrictive outage working hour limitations is 116 days. The current EPU refueling outage schedule exceeds the 116 days allowed by the 10 CFR 26.205 paragraphs (d)(4), (d)(5), and (d)(6). Under the current rules, Turkey Point must meet the on-line working hour requirements of 10 CFR 26.205(d)(3) after 116 days.

Requested Exemption FPL is requesting a one-time exemption from the requirements of 10 CFR 26.205(d)(3). The proposed one-time exemption from the provisions of 10 CFR 26.205(d)(3) would allow the application of the less restrictive outage work hours described in 10 CFR 26.205(d)(4) and (d)(5) to support Phase 3 of the Turkey Point Unit 3 EPU refueling outage. The proposed exemption would apply to operations (who also compose the fire brigade), maintenance, security, chemistry and radiation protection personnel as defined in 10 CFR 26.4(a)(1) through (a)(5).

The requested exemption will provide FPL the flexibility in scheduling needed to support the increased manpower requirements related to core reload, system walkdowns, surveillance testing and startup testing activities.

Turkey Point Unit 3 proposes to meet the less restrictive outage work hours described in 10 CFR 26.205(d)(4) and (d)(5) for Phase 1, the initial period (30- 45 days), of the EPU refueling outage. Phase 2 is the period following the initial outage period. During Phase 2, Turkey Point Unit 3 will meet the on-line working hour requirements in 10 CFR 26.205(d)(3) for a minimum of 5 weeks. This 5-week minimum period of on-line hours is a reset period that will ensure the covered workers will not be fatigued prior to starting Phase 3, the exemption period. During Phase 3, the exemption period, Turkey Point Unit 3 will meet the less restrictive outage work hours described in 10 CFR 26.205(d)(4) and (d)(5) to support the core reload and startup testing window of the refueling outage. The proposed exemption period would be applicable for 60

L-2011-408 Attachment 1 Page 3 of 6 days consistent with the requirements described in 10 CFR 26.205(d)(4) and (d)(5). The exemption period would start anytime after the minimum 5-week reset period of on-line working hours is completed. In accordance with 10 CFR 26.205(d)(6), the exemption period may be extended in 7-day increments for each non-overlapping 7-day period an individual works not more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during the first 60 days of the exemption period.

During Phase 3, the exemption period, Turkey Point Unit 3 will apply the outage work hour limitations of 10 CFR 26.205(d)(4) and (d)(5), such that the individuals specified in 10 CFR 26.4(a)(1) through (a)(3) have at least 3 days off in each successive (i.e., non-rolling) 15-day period, the individual specified in 10 CFR 26.4(a)(4) have at least 1 day off in any 7-day period, and the individuals specified in 10 CFR 26.4 (a)(5) have at least 4 days off in each successive, non-rolling 15-day period.

Provided below is a discussion of each affected work group along with the reasons for the request for the exemption during Phase 3 and the activities related to the Turkey Point Unit 3 EPU refueling outage.

Operations [10 CFR 26.4(a)(1) and (a)(3)1 Operations personnel activities include plant startup demands, which involve returning plant systems to service, post-maintenance and surveillance testing, support of instrument and valve lineups, system walkdowns, and response to emergent equipment issues. Increased Operations staffing levels during the startup period, created by implementation of the less restrictive outage work hour limits ensure adequate staffing to perform the increased activities associated with plant startups, particularly following an extensive refueling outage that involves EPU modifications. Note that at Turkey Point, the Fire Brigade members [10 CFR 26.4(a)(3)]

are on-shift operations personnel and are impacted by the activities described above.

Chemistry [10 CFR 26.4(a)(2)1 Chemistry technicians provide the on-site emergency response organization minimum shift complement per 10 CFR 26.4(a)(2). Chemistry personnel activities also include plant startup demands, which involve additional chemistry sampling and frequencies with increased demands from Operations as the plant moves through Mode changes. Increased Chemistry staffing levels during the startup period, created by implementation of the less restrictive outage work hour limits ensure adequate staffing to perform the increased activities associated with plant startups, particularly following an extensive refueling outage that involved EPU modifications.

Radiation Protection [10 CFR 26.4(a)(2)1 Radiation Protection technicians provide the on-site emergency response organization minimum shift complement per 10 CFR 26.4(a)(2). In addition, Radiation Protection provides support to Operations and Maintenance personnel accessing plant areas designated as radiologically controlled areas and provides support to demobilizing equipment from containment for off-site shipment and on-site storage. Increased Radiation Protection staffing levels during the startup period, created by implementation of the less restrictive outage work hour limits ensure adequate staffing to perform the increased activities inside radiation controlled areas.

L-2011-408 Attachment 1 Page 4 of 6 Maintenance [10 CFR 26.4(a)(4)1 Maintenance personnel activities include increased demands to support plant startup activities.

Maintenance personnel, including Instrumentation and Control (I&C), mechanical and electrical, will be required to support Operations in post-maintenance and surveillance activities.

Increased Maintenance staffing levels during the startup period, created by implementation of the less restrictive outage work hour limits ensure adequate staffing to perform the increased activities associated with surveillance testing and startup testing, particularly following an extensive refueling outage that involves EPU modifications.

Security [10 CFR 26.4(a)(5)1 Security personnel activities include compensatory measures associated with controlling access with increased work activities in addition to the increased support required for the demobilization of equipment and its removal from the protected area. Increased Security staffing levels during this period, created by implementation of the less restrictive outage work hour limits ensure adequate staffing to perform the increased activities associated with EPU modifications.

Regulatory Evaluation The one-time exemption from the requirements of 10 CFR 26.205(d)(3) is requested in accordance with 10 CFR 26.9, Specific exemptions. Specifically, the NRC may grant exemptions from the regulations that are determined to be authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest.

10 CFR 26, Subpart I, Managing Fatigue, as discussed in Federal Register Notice 73 FR 16966, dated March 31, 2008, was issued to ensure that nuclear power plant licensees ensure against worker fatigue by establishing clear and enforceable requirements. The minimum days off work hour control requirements for on-line work hours are established in 10 CFR 26.205(d)(3) to address the long-term work hour controls allowing occasional use of extended work hours for short period of time.

FPL is requesting a one-time exemption from the requirements of 10 CFR 26.205(d)(3) to implement the outage work hour controls in 10 CFR 26.205(d)(4) and (d)(5) to support Phase 3 of the Turkey Point Unit 3 EPU refueling outage. 10 CFR 26.205(d)(4) and (d)(5) permit the use of less restrictive working hour limitations during the first 60 days of a unit outage, in lieu of the on-line working hour requirements in 10 CFR 26.205(d)(3). The less restrictive days off requirements of 10 CFR 26.205(d)(4) and (d)(5) provide licensees flexibility in scheduling days off while requiring the more intensive work schedules that accompany a unit outage. In addition, 10 CFR 26.205(d)(6) allows the extension of the 60-day period in 7-day increments for each non-overlapping 7-day period an individual works not more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during the first 60 days of a unit outage. The maximum number of days a licensee is permitted to use the less restrictive outage working hour limitations is 116 days after taking into consideration the allowed extension specified in 10 CFR 26.205(d)(6). The current EPU refueling outage schedule exceeds the 116 days allowed by the 10 CFR 26.205 paragraphs (d)(4), (d)(5), and (d)(6).

Under the current rules, Turkey Point must meet the on-line working hour requirements in 10 CFR 26.205(d)(3) after 116 days. The current 10 CFR 26.205 rules are not designed to support an extended refueling outage such as the Unit 3 EPU refueling outage currently scheduled for greater than 116 days.

L-2011-408 Attachment 1 Page 5 of 6 The proposed one-time exemption would allow the less restrictive working hour limitations associated with outages, as defined in 10 CFR 26.205(d)(4) and (d)(5), to address the increased manpower requirements related to core reload, system walkdowns, surveillance testing and startup physics testing prior to returning the unit to service. The proposed exemption period (Phase 3) would be applicable for 60 days as described in 10 CFR 26.205(d)(4) and (d)(5) and the exemption period would start anytime after the minimum 5-week reset period of on-line working hours is completed. The exemption period may be extended in 7-day increments as described in 10 CFR 26.205(d)(6) for each non-overlapping 7-day period an individual works not more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during the first 60 days of the exemption period.

The proposed exemption is applicable during Phase 3 of the refueling outage. Implementation of the proposed exemption is dependent on meeting the requirements imposed during Phases 1 and 2 of the refueling outage. Phase 1 is an initial outage period (30-45 days) during which the requirements of 10 CFR 26.205(d)(4) and (d)(5) will be met. Phase 2 is a reset period scheduled for a minimum of 5 weeks. During the 5 week period, affected personnel will meet the on-line minimum days off requirements and work hour controls of 10 CFR 26.205(d)(3). The minimum days off work hour control requirements for on-line work hours are established in 10 CFR 26.205(d)(3) to address the long-term work hour controls allowing occasional use of extended work hours for short period of time. Working the more restrictive on-line work hours prior to the period of exemption will provide assurance that cumulative fatigue will not compromise the workers' ability to safely and competently perform their duties during Phase 3 of the outage, referred to as the exemption period. The outage work hour controls and minimum days off requirements defined in 10 CFR 26.205(d)(4) and (d)(5) are designed to ensure that individuals have sufficient periodic long-duration breaks to prevent cumulative fatigue from affecting their ability to safely and competently perform their duties. The outage minimum day off requirements in 10CFR 26.205(d)(4) and (d)(5) serve the same general function as the on-line minimum day off requirements of 10 CFR 26.205(d)(3). The proposed approach of implementing a reset period prior to resuming the less restrictive work hours under the exemption period is supportive of reducing worker fatigue in an extended refueling outage.

The proposed exemption would apply to operations (who also compose the fire brigade),

maintenance, security, chemistry and radiation protection personnel as defined in 10 CFR 26.4(a)(1) through (a)(5). The proposed exemption request will not be applicable to personnel performing work as defined in 10 CFR 26.4(a)(1) through (a)(5) who are not involved in the work schedule phases described in the exemption request. Personnel not working the schedules in the proposed exemption request will continue to meet the work hour controls of 10 CFR 26.205(d)(4) and (d)(5) during the first 60 days of the outage. Any needed extensions of the 60 day outage period will be implemented per 10 CFR 26.205(d)(6)

Authorized By Law The proposed one-time exemption is authorized by law in that no other law prohibits the activities that would be authorized by the exemption. The proposed one-time exemption does not result in a violation of the Atomic Energy Action of 1954, as amended, or the Commission's regulations. Notwithstanding the exemption to 10 CFR 26.205(d)(3), FPL will continue to be in compliance with all other requirements in 10 CFR 26.

L-2011-408 Attachment 1 Page 6 of 6 Will Not Endanger Life Or Property FPL is requesting the use of the outage work hour controls described in 10 CFR 26.205(d)(4) and (d)(5) following a minimum of 5-week reset period where on-line minimum days off requirements are applied to the affected work groups. The 5-week minimum period of on-line hours as described in 10 CFR 26.205(d)(3) is a reset period that will ensure the covered workers will not be fatigued prior to restarting the less restrictive outage work hours described in 10 CFR 26.205(d)(4) and (d)(5) to support the core reload and startup testing window of the refueling outage. The minimum day off requirement in 10 CFR 26.205(d)(4) and (d)(5) serves the same general function as the minimum day off requirements of 10 CFR 26.205(d)(3). The reset period will ensure that cumulative fatigue will not compromise the abilities of the individuals to safely and competently perform their duties during the exemption period. Based on these considerations, no new accident precursors are created by FPL requesting a one-time exemption to the work hour rules. Also, the consequences of postulated accidents are not increased because there is no change in the types of accidents previously evaluated.

Therefore, the proposed exemption will not endanger life or property.

Will Not Endanger the Common Defense and Security FPL is requesting a one time exemption to allow the use of less restrictive work hour limitations as described in 10 CFR 26.205(d)(4) and (d)(5). The exemption period follows the initial outage work hour period (30-45 days) and the on-line work hours reset period scheduled for a minimum of 5 weeks. Working the more restrictive on-line work hours prior to the period of exemption will provide assurance that cumulative fatigue will not compromise the workers ability to safely and competently perform their duties during the period of the exemption request. The one time exemption is requested to support the core reload and startup testing window of the refueling outage. Therefore, the proposed exemption will not endanger the common defense and security.

Otherwise in the Public Interest The proposed exemption supports the Turkey Point Unit 3 EPU refueling outage that includes activities associated with EPU modifications and the related surveillance and startup testing requirements. The proposed one time exemption would allow the less restrictive working hour limitations as described in 10 CFR 26.205(d)(4) and (d)(5). The exemption period follows the initial outage work hour period (30-45 days) and the on-line work hours reset period scheduled for a minimum of 5 weeks. Working the more restrictive on-line work hours prior to Phase 3, the exemption period, will provide assurance that cumulative fatigue will not compromise the workers ability to safely and competently perform their duties during the period of the exemption request. The outage work hour limitations increase the availability of the staff to work through the manpower intensive periods of the EPU refueling outage including core reload, system walkdowns, surveillance testing, and startup testing, all necessary prior to returning the unit to service. Therefore, the proposed exemption is in the public interest.

L-2011-408 Attachment 2 Page 1 of 3 ATTACHMENT 2 Environmental Assessment One-Time Exemption from the Requirements of 10 CFR 26.205(d)(3)

Florida Power & Light Company (FPL) is requesting a one-time exemption from portions of 10 CFR 26.205(d)(3) for the Turkey Point Unit 3 nuclear power station. The proposed exemption would allow the application of less restrictive working hour limitations described In 10 CFR 26.205(d)4) and (d)(5) in lieu of the working hour limitations described in 10 CFR 26.205(d)(3),

to support the Turkey Point Unit 3 extended power uprate (EPU) refueling outage activities. The exemption period may be extended in 7-day increments as described in 10 CFR 26.205(d)(6) for each non-overlapping 7-day period an individual works not more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during the first 60 days of the exemption period.

An environmental assessment for the proposed exemption follows.

1. Describe any changes to the types, characteristics, or quantities of non-radiological effluents discharged to the environment as a result of the proposed exemption.

There are no expected changes in the types, characteristics, or quantities of non-radiological effluents discharged to the environment as a result of the proposed exemption. The proposed exemption is administrative in nature and is limited to changing the timeframe when less restrictive hours can be worked. This does not result in any changes to the design basis requirements for the structures, systems, and components (SSCs) at Turkey Point Unit 3 that function to limit the release of non-radiological effluents during and following postulated accidents. The SSCs associated with limiting the release of offsite non-radiological effluents will continue to perform their functions, and as a result, there is no significant non-radiological effluent Impact. There are no materials or chemicals introduced into the plant that could affect the characteristics or types of non-radiological effluents. In addition, the method of operation of non-radiological waste systems will not be affected by the proposed exemption.

2. Describe any changes to liquid radioactive effluents discharged as a result of the proposed implementation.

There are no expected changes to liquid radioactive effluents discharged as a result of the proposed exemption. The proposed exemption is limited to administrative changes regarding the timeframe when less restrictive working hours can be worked and will not result in the production of any different quantity or type of radioactive material in the reactor coolant system. The proposed exemption will not result in changes to the design basis requirements for the SSCs at Turkey Point Unit 3 that function to limit the release of liquid radiological effluents during and following postulated accidents. The SSCs associated with limiting the release of liquid radiological effluents will continue to perform their functions, and as a result, there is no significant liquid radiological effluent impact.

L-2011-408 Attachment 2 Page 2 of 3

3. Describe any changes to gaseous radioactive effluents discharged as a result of the proposed exemption.

There are no expected changes to gaseous radioactive effluents discharged as a result of the proposed exemption. The proposed administrative changes to the timeframe when less restrictive working hours can be worked will not result in the production of any different quantity or type of radioactive material in the reactor coolant system. These changes will not result in changes to the design basis requirements for the SSCs at Turkey Point Unit 3 that function to limit the release of gaseous radiological effluents during and following postulated accidents. The SSCs associated with limiting the release of gaseous radiological effluents will continue to perform their functions, and as a result, there is no significant gaseous radiological effluent impact.

4. Describe any change in the type or quantity of solid radioactive waste generated as a result of the proposed exemption.

There are no expected changes to solid radioactive waste generated as a result of the proposed exemption. The proposed administrative changes to the timeframe when less restrictive working hours can be worked will not result in the production of any different quantity or type of radioactive material. These changes will not result in changes to the design basis requirements for the SSCs at Turkey Point Unit 3 that function to limit the release of solid radioactive waste during and following postulated accidents. In addition, radiation surveys will continue to be performed in accordance with plant radiation procedures. The SSCs associated with limiting the release of solid radioactive waste will continue to perform their functions, and as a result, there is no significant solid radioactive waste impact.

5. What Is the expected change in occupational dose as a result of the proposed exemption under normal and design basis accident conditions?

The request for exemption is related to the current Turkey Point Unit 3 EPU refueling outage. There is no additional work activities planned other than those related to the refueling outage. The FPL radiation protection program ensures that individual dose is maintained "as low as reasonably achievable" and that federal dose limits remain satisfied. The proposed administrative changes to the timeframe when less restrictive working hours can be worked will not result in changes to occupational dose as a result of the proposed exemption under normal and design basis accident conditions.

Therefore, the proposed exemption will not have a significant impact upon occupational dose.

L-2011-408 Attachment 2 Page 3 of 3

6. What Is the expected change In the public dose as a result of the proposed change under normal and design basis accident conditions?

Dose to the public will not be affected by the proposed exemption during either normal or design basis accident conditions. As noted in responses to Items 2, 3, and 4 above, there is no basis to contemplate an increased source of liquid, gaseous, or solid radiological effluents, which could contribute to increased public exposure during normal operations or design basis accident conditions. The proposed administrative changes to the timeframe when less restrictive working hours can be worked do not impact systems used during normal operation nor systems used to detect or mitigate a design basis accident.

7. What is the Impact to land disturbance for the proposed changes?

There is no impact to land disturbance as a result of the proposed exemption. The proposed administrative changes to the timeframe when less restrictive working hours can be worked will not result in any impact to land in the vicinity of Turkey Point Unit 3.

FPL concludes that there is no significant radiological environmental impact associated with the proposed exemption to use the less restrictive outage work hours described in 10 CFR 26.205(d)(4) and (d)(5) to support the extended outage activities for the current Turkey Point Unit 3 refueling outage. This conclusion is based on the following:

There is no significant increase in the amounts, and no significant changes in the types, of any effluents that may be released offsite; There is no significant increase in individual or cumulative occupational radiation exposure; and There is no significant increase in the potential for or consequences from a radiological accident.

L-2011-408 Attachment 3 Page 1 of 1 ATTACHMENT 3 ReQulatorv Commitments The following table identifies the actions committed to by Florida Power & Light Company (FPL) in this document. Any other actions discussed in this submittal represent intended or planned actions by FPL. They are described to the Nuclear Regulatory Commission for NRC's information and are not regulatory commitments.

Commitment Date FPL will manage overtime levels for 10 CFR The outage work hour controls of 10 CFR 26.4(a)(1) through 26.4(a)(5) personnel such 26.205(d)(4) and (d)(5) will be implemented that they will meet the outage work hour during the initial outage period (30-45 days).

controls of 10 CFR 26.205(d)(4) and (d)(5).

FPL will manage overtime levels for 10 CFR The reset period of on-line work hour controls 26.4(a)(1) through 26.4(a)(5) personnel such described in 10 CFR 26.205(d)(3) will be that they will meet the on-line work hour implemented for a minimum of 5 weeks controls of 10 CFR 26.205(d)(3). following the initial outage work hour controls period.

FPL will manage overtime levels for 10 CFR The outage work hour controls granted by the 26.4(a)(1) through 26.4(a)(5) personnel such proposed exemption will be implemented that they will meet the outage work hour anytime after completion of the 5 week controls of 10 CFR 26.205(d)(4) and (d)(5). minimum reset period of on-line work hour controls. The exemption period may be extended in 7-day increments as described in 10 CFR 26.205(d)(6) for each non-overlapping 7-day period an individual works not more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during the first 60 days of the exemption period.

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