L-2015-045, License Amendment Request No. 216 - Transition to 10 CFR 50.48(c) - NFPA 805Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

License Amendment Request No. 216 - Transition to 10 CFR 50.48(c) - NFPA 805Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

ML15069A158
Person / Time
Site:	Turkey Point
Issue date:	02/18/2015
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15069A130	List: L-2015-045, License Amendment Request No. 216 - Transition to 10 CFR 50.48(c) - NFPA 805Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)
References
L-2015-045, TAC MF0602, TAC MF0603
Download: ML15069A158 (18)

Text

Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035 0 February 18, 2015 FPL. L-2015-045 10 CFR 2.390 10 CFR 50.90 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Generating Station Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request No. 216 - Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

References:

1. Florida Power & Light Company letter L-2012-092, "License Amendment Request No.

216 - Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," June 28, 2012.

2. Florida Power & Light Company letter L-2014-303, "Response to Request for Additional Information Regarding License Amendment Request No. 216 - Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," November 5, 2014.

3. USNRC letter, "Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Issuance of Amendments Regarding Operating License Conditions and Technical Specifications (TAC NOS. MF0602 and MF0603)," June 13, 2014.

By letter L-2012-092 dated June 28, 2012, (Reference 1), FPL requested an amendment to the Renewed Facility Operating License (RFOL) for Turkey Point Nuclear Generating Station Units 3 and 4. The License Amendment Request (LAR) would enable FPL to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide (RG) 1.205.

FPL letter L-2012-092 discussed the schedule for transitioning to the new fire protection licensing basis. Specifically, FPL committed to implementation of the new NFPA 805 fire protection program to include procedure changes, process updates, and training to affected plant personnel within 180 days after NRC approval of the LAR, unless that date fell within a scheduled outage window. In that case, implementation would occur 60 days after startup from that scheduled outage.

The purpose of this letter is to request a change to the schedule for implementation of the new NFPA 805 fire protection program from the referenced schedule above to implementation no later than 12 months after issuance of the license amendment. The requested program implementation extension is based on site resources required to prepare and support the Turkey Point Unit 3 refueling outage scheduled in the Fall of 2015 and the Turkey Point Unit 4 refueling outage scheduled in the Spring of 2016. The revised implementation schedule will ensure implementation of the fire protection program falls after the Turkey Point Unit 3 Fall 2015 refueling outage and prior to the Unit 4 Spring 2016 refueling outage. The requested 12 month Security-Related Information - Withhold From Public Disclosure Under 10 CFR 2.390. to this letter contains security-related information. Upon removal of Enclosure 1, this letter is uncontrolled. (e "k4dA

L-2015-045 Page 2 of 2 program implementation period is consistent with other licensee approved fire protection program implementation periods including Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, and Cooper Nuclear Station (CNS).

The NFPA 805 fire protection program implementation schedule is reflected in LAR Attachment S, Table S-3, Implementation Items, LAR Attachment M, License Condition Changes, and LAR Attachment N, Technical Specification Changes. Enclosure 1 to this letter provides the revision to LAR Attachment S, Table S-3, Implementation Items, reflecting the 12 month implementation period. Specifically, Enclosure 1 replaces Table S-3 page S-22 previously submitted to the NRC by Reference 2. Enclosure 2 to this letter provides the revision to LAR Attachment M, License Condition Changes, reflecting the 12 month implementation period. Specifically, replaces page M-4 of the License Condition Changes Section of Attachment M, previously submitted to the NRC by Reference 2. Enclosure 3 to this letter provides the revision to LAR Attachment N, Facility Operating License, Technical Specifications Retype Section, reflecting the 12 month implementation period. Enclosure 3 replaces the LAR Attachment N, Facility Operating License, Technical Specifications Retype Section, originally submitted to the NRC by Reference 1. In addition, Enclosure 3 provides the retyped Technical Specification 6.8, Procedures and Programs, revised to reflect the TS page number updated per Amendment 260 to Renewed Facility Operating License No. DPR-31 and Amendment No. 255 to Renewed Facility Operating License No. DPR-41 for Turkey Point Units 3 and 4, respectively, issued on June 13, 2014 (Reference 3). to this letter contains sensitive Security-Related Information; therefore, FPL requests that it be withheld from public disclosure in accordance with 10 CFR 2.390.

The information provided in this letter does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in FPL letter L-2012-092.

If you should have any questions regarding this application, 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 February ., 2015.

Michael Kiley Vice President Turkey Point Nuclear Generating Station Enclosures cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point USNRC Project Manager for Turkey Point Ms. Cindy Becker, Florida Department of Health Security-Related Information -Withhold From Public Disclosure Under 10 CFR 2.390. to this letter contains security-related information. Upon removal of Enclosure 1, this letter is uncontrolled.

Enclosure 2 to L-2015-045 License Amendment Request No. 216 Florida Power and Light Company Turkey Point Nuclear Generating Station Units 3 and 4 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Updated LAR Attachment M, License Condition Changes Page M-4

L-2015-045 Enclosure 2 Florida Power & Light Attachment M- License Condition Changes protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. and 3.

below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2.

above.

2. The licensee shall implement the modifications to its facility, as described in Enclosure 1, Attachment S, Table S-2, "Plant Modifications Committed," of FPL letter L-2014-303, dated 11/05/2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the end of the second refueling outage (for each unit) following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Enclosure 1, Attachment S, Table S-3, "Implementation Items," of FPL letter L-2014-303, dated 11/05/2014, with the exception of items 12, 18 and 19, no later than 12 months after NRC issuance of the license amendment. Items 12, 18 and 19 are associated with modifications in Table S-2 and will be completed in accordance with Transition License Condition 2 above. Item 22 will be completed within 6 months of the NRC approval of the Flowserve RCP Seal Topical Report.

Revision 2 Page M-4

Enclosure 3 to L-2015-045 License Amendment Request No. 216 Florida Power and Light Company Turkey Point Nuclear Generating Station Units 3 and 4 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Updated LAR Attachment N, Facility Operating License, Technical Specifications Retype 13 Pages Attached

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 excess of 2644 megawatts (thermal).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 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.

4 D. Fire Protection FPL shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated 6/28/12, (and supplements dated 9/19/12, 3/18/13, 4/16/13, 5/15/13, 1/7/14, 4/4/14, 6/6/14, 7/18/14, 09/12/14, 11/05/14, 12/2/14, and 2/18/15), and as approved in the safety evaluation dated XX/XX/XX. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may nhake changes to the fire protection program without prior approval of the Commission ifthose changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1xl 0-7 /year (yr) for CDF and less than 1xl 0 8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

Renewed License No. DPR-31 Amendment No.

5 Other Changes that May Be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3.8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.10); and

• "Passive Fire Protection Features" (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated XX/XX/XX to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. DPR-31 Amendment No.

6 Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2.

and 3. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Enclosure 1, Attachment S, Table S-2, "Plant Modifications Committed," of FPL letter L-2014-303, dated 11/05/2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the end of the second refueling outage (for each unit) following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Enclosure 1, Attachment S, Table S-3, "Implementation Items," of FPL letter L-2014-303, dated 11/05/2014, with the exception of items 12, 18 and 19, no later than 12 months after issuance of the license amendment. Items 12, 18 and 19 are associated with modifications in Table S-2 and will be completed in accordance with Transition License Condition 2 above. Item 22 will be completed within 6 months of the NRC approval of the Flowserve RCP Seal Topical Report.

E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Florida Power and Light Turkey Point Nuclear Plant Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program - Revision 15" submitted by letter dated August 3, 2012.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Turkey Point Nuclear Generating Station CSP was approved by License Amendment No. 245 as supplemented by a change approved by Amendment No. 256.

Renewed License No. DPR-31 Amendment No.

I 7

F. 1. The licensee shall restrict the combined number of fuel assemblies loaded in the existing spent fuel pool storage racks and cask pit rack to no more than the capacity of the spent fuel pool storage racks. This condition applies at all times, except during activities associated with a reactor core offload/reload refueling condition. This restriction will ensure the capability to unload and remove the cask pit rack when cask loading operations are necessary.

2. The licensee shall establish two hold points within the rack installation procedure to ensure proper orientation of the cask rack in each unit's spent fuel pool. Verification of proper cask pit rack orientation will be implemented by an authorized Quality Control inspector during installation of the racks to ensure consistency with associated spent fuel pool criticality analysis assumptions.

G. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders Renewed License No. DPR-31 I

8 H. PAD TCD Safety Analyses

1. PAD 4.0 TCD has been specifically approved for use for the Turkey Point licensing basis analyses. Upon NRC's approval of a revised generic version of PAD that accounts for Thermal Conductivity Degradation (TCD), FPL will within six months:

a. Demonstrate that PAD 4.0 TCD remains conservatively bounding in licensing basis analyses when compared to the new generically approved version of PAD w/TCD, or

b. Provide a schedule for the re-analysis using the new generically approved version of PAD w/TCD for any of the affected licensing basis analyses.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight July 19, 2032.

FOR THE NUCLEAR REGULATORY COMMISSION Signed by Samuel J. Collins, Director Office of Nuclear Reactor Regulation Attachments:

Appendix A - Technical Specifications for Unit 3 Appendix B - Environmental Protection Plan Date of Issuance: June 6, 2002 Renewed License No. DPR-31 I

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 excess of 2644 megawatts (thermal).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 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.

4 D. Fire Protection FPL shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated 6/28/12, (and supplements dated 9/19/12, 3/18/13, 4/16/13, 5/15/13, 1/7/14, 4/4/14, 6/6/14, 7/18/14, 09/12/14, 11/05/14, 12/2/14, and 2/18/15), and as approved in the safety evaluation dated XX/XX/XX. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10-7/year (yr) for CDF and less than 1 X10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

Renewed License No. DPR-41 Amendment No.

5 Other Chanaqes that May Be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3.8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.10); and

• "Passive Fire Protection Features" (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated XX/XX/XX to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. DPR-41 Amendment No.

6 Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2.

and 3. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Enclosure 1, Attachment S, Table S-2, "Plant Modifications Committed," of FPL letter L-2014-303, dated 11/05/2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the end of the second refueling outage (for each unit) following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Enclosure 1, Attachment S, Table S-3, "Implementation Items," of FPL letter L-2014-303, dated 11/05/2014, with the exception of items 12, 18 and 19, no later than 12 months after issuance of the license amendment. Items 12, 18 and 19 are associated with modifications in Table S-2 and will be completed in accordance with Transition License Condition 2 above. Item 22 will be completed within 6 months of the NRC approval of the Flowserve RCP Seal Topical Report.

E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Florida Power and Light Turkey Point Nuclear Plant Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program - Revision 15" submitted by letter dated August 3, 2012.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Turkey Point Nuclear Generating Station CSP was approved by License Amendment No. 241 as supplemented by a change approved by Amendment No. 252.

Renewed License No. DPR-41 Amendment No.

7 F. 1. The licensee shall restrict the combined number of fuel assemblies loaded in the existing spent fuel pool storage racks and cask pit rack to no more than the capacity of the spent fuel pool storage racks. This condition applies at all times, except during activities associated with a reactor core offload/reload refueling condition. This restriction will ensure the capability to unload and remove the cask pit rack when cask loading operations are necessary.

2. The licensee shall establish two hold points within the rack installation procedure to ensure proper orientation of the cask rack in each unit's spent fuel pool. Verification of proper cask pit rack orientation will be implemented by an authorized Quality Control inspector during installation of the racks to ensure consistency with associated spent fuel pool criticality analysis assumptions.

G. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders Renewed License No. DPR-41 I

8 H. PAD TCD Safety Analyses

1. PAD 4.0 TCD has been specifically approved for use for the Turkey Point licensing basis analyses. Upon NRC's approval of a revised generic version of PAD that accounts for Thermal Conductivity Degradation (TCD), FPL will within six months:

a. Demonstrate that PAD 4.0 TCD remains conservatively bounding in licensing basis analyses when compared to the new generically approved version of PAD w/TCD, or

b. Provide a schedule for the re-analysis using the new generically approved version of PAD w/TCD for any of the affected licensing basis analyses.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight April 10, 2033.

FOR THE NUCLEAR REGULATORY COMMISSION Signed by Samuel J. Collins, Director Office of Nuclear Reactor Regulation Attachments:

Appendix A - Technical Specifications for Unit 4 Appendix B - Environmental Protection Plan Date of Issuance: June 6, 2002 Renewed License No. DPR-41 I

ADMINISTRATIVE CONTROLS 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

a. The applicable procedures required by the Quality Assurance Topical Report.

b. The emergency operating procedures required to implement the requirements of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Generic Letter No. 82-33;

c. Process Control Program implementation;

d. Offsite Dose Calculation Manual implementation;

e. Quality Control Program for effluent monitoring using the guidance in Regulatory Guide 1.21, Revision 1, June 1974;

f. DELETED

g. Quality Control Program for environmental monitoring using the guidance in Regulatory Guide 4.1, Revision 1, April 1975; and

h. Diesel Fuel Oil Testing Program implementation.

6.8.2 DELETED 6.8.3 DELETED TURKEY POINT - UNITS 3 & 4 6-5 AMENDMENTNOS. AND