ML12067A176

Issuance of Amendments Regarding Control Room Habitability Technical Specification Task Force (TSTF)-448 (TAC Nos. ME4277 & ME4278)

ML12067A176
Person / Time
Site:	Turkey Point
Issue date:	03/30/2012
From:	Jason Paige Plant Licensing Branch II
To:	Nazar M Florida Power & Light Co
Paige J
References
TAC ME4277, TAC ME4278
Download: ML12067A176 (30)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 30, 2012 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT PLANT, UNIT NOS. 3 AND 4 - ISSUANCE OF AMENDMENTS REGARDING CONTROL ROOM HABITABILITY TECHNICAL SPECIFICATION TASK FORCE (TSTF)-448 (TAC NOS. ME4277 AND ME4278)

Dear Mr. Nazar:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Arn~ndment No. 248 to Renewed Facility Operating License No. DPR-31 and Amendment No. 244 to Renewed Facility Operating License No. DPR-41 for the Turkey Point Plant, Units Nos. 3 and 4, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated July 16, 2010, as supplemented by letters dated July 18, 2011, August 1, 2011, October 27, 2011, and March 13, 2012.

The amendments revise the TS requirements related to control room envelope habitability in accordance with Technical Specification Task Force (TSTF) Change Traveler TSTF-448, Revision 3, "Control Room Habitability." TSTF-448 was made available by the NRC on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/} ----

,/

Jason C. Paige, 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. 248 to DPR-31

2. Amendment No. 244 to DPR-41

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

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-250 TURKEY POINT PLANT, UNIT NO.3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 248 Renewed License No. DPR-31

1.

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

A.

The application for amendment by Florida Power and Light Company (the licensee) dated July 16, 2010, as supplemented by letters dated July 18, 2011, August 1, 2011, October 27, 2011, and March 13, 2012, 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

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.B 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. 248 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.

FOR THE NUCLEAR REGULATORY COMMISSION Douglas A. Broaddus, 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: March 30, 2012

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT PLANT UNIT NO.4 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 244 Renewed License No. DPR-41

1.

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

A.

The application for amendment by Florida Power and Light Company (the licensee) dated July 16, 2010, as supplemented by letters dated July 18, 2011, August 1, 2011, October 27, 2011, and March 13, 2012, 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

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.B 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. 244 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.

FOR THE NUCLEAR REGULATORY COMMISSION Douglas A. Broaddus, 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: March 30, 2012

ATTACHMENT TO LICENSE AMENDMENT AMENDMENT NO. 248 RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AMENDMENT NO. 244 RENEWED FACILITY OPERATING LICENSE NO. DPR-41 DOCKET NOS. 50-250 AND 50-251 Replace Page 3 of Renewed Operating License DPR-31 with the attached Pages 3,6, and 7.

Replace Page 3 of Renewed Operating License DPR-41 with the attached Pages 3, 6, and 7.

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 area of change.

Remove pages Insert pages 3/47-16 3/47-16 3/47-16a 3/47-16a 3/47-16b 3/47-16b 3/47-17 3/47-17 6-18b 6-18b 6-18c 6-18c

3 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 2300 megawatts (thermal).

B.

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 248 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.

248

6

3.

The CREVS compensatory filtration unit, which is being installed by FPL as part of the AST methodology implementation at Turkey Point will be designed in accordance with the Class I Structures, Systems, and Equipment Design Requirements defined in Appendix SA of the Turkey Point UFSAR. As such, the compensatory filtration unit will be designed so that the stress limits found in Table SA-1 of the Turkey Point UFSAR will not be exceeded due to the loadings imposed by a maximum hypothetical earthquake. FPL shall ensure that the design of the compensatory filtration unit satisfies these stress limits prior to the implementation of the proposed AST methodology at Turkey Point.

I.

Control Room Habitability Upon implementation of Amendment No. X* for Unit 3 and Y* for Unit 4 adopting TSTF-448 Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.5.g, in accordance with Technical Specification (TS) 6.8.4.k.c.(i), the assessment of CRE habitability as required by Specification 6.8.4.k.c.(ii), and the measurement of CRE pressure as required by Specification 6.8.4.k.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.5.g, in accordance with Specification 6.8.4.k.c.(i), shall be within the specified Frequency of 3 years, plus the 9 month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test. *

(b)

The first performance of the periodic assessment of CRE habitability, Specification 6.8.4.k.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31,2009, the date of the most recent tracer gas test.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.8.4.k.d, shall be within 36 months on a STAGGERED TEST BASIS, plus the 138 days allowed by SR 4.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days of license amendment implementation if not performed previously.

• The most recent tracer gas test (July 31, 2009) was unsuccessful in that there was a measured 9 cfm control room inleakage: the acceptance criteria is 0 cfm. In accordance with Regulatory Guide (RG) 1.197 Rev. 0, a recalculation ofthe consequences to the control room operators was performed, and the results were acceptable for continued CREVS operability. Consistent with RG 1.197, a full test is to be conducted three years later to ascertain whether the CRE's integrity has continued to degrade.

Renewed License No. DPR-31 Amendement No. 248

7

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 8 - Environmental Protection Plan Date of Issuance: June 6, 2002 Renewed License No. DPR-31 Amendment No. 248

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 2300 megawatts (thermal).

B.

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 244 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. 244

6

3.

The CREVS compensatory filtration unit, which is being installed by FPL as part of the AST methodology implementation at Turkey Point will be designed in accordance with the Class I Structures, Systems, and Equipment Design Requirements defined in Appendix SA of the Turkey Point UFSAR. As such, the compensatory filtration unit will be designed so that the stress limits found in Table SA-1 of the Turkey Point UFSAR will not be exceeded due to the loadings imposed by a maximum hypothetical earthquake. FPL shall ensure that the design of the compensatory filtration unit satisfies these stress limits prior to the implementation of the proposed AST methodology at Turkey Point.

I.

Control Room Habitability Upon implementation of Amendment No.248 for Unit 3 and244 for Unit 4 adopting TSTF-448 Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.5.g, in accordance with TeChnical SpeCification (TS) 6.8.4.k.c.(i), the assessment of CRE habitability as required by Specification 6.8.4.k.c.(ii), and the measurement of CRE pressure as required by SpeCification 6.8Ak.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.5.g, in accordance with Specification 6.8.4.k.c.(i), shall be within the specified Frequency of 3 years, plus the 9 month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test. *

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.8.4.k.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.

(c)

The first performance of the periodic measurement of CRE pressure, Specification 6.8.4.k.d, shall be within 36 months on a STAGGERED TEST BASIS, plus the 138 days allowed by SR 4.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days of license amendment implementation if not performed previously.

• The most recent tracer gas test (July 31, 2009) was unsuccessJul in that there was a measured 9 cJm control room inleakage: the acceptance criteria is 0 cJm. In accordance with Regulatory Guide (RG) 1.197 Rev. 0, a recalculation oJthe consequences to the control room operators was perJormed, and the results were acceptable Jor continued CREVS operability. Consistent with RG 1.197, a Jull test is to be conducted three years later to ascertain whether the CRE's integrity has continued to degrade.

Renewed License No. DPR-41 Amendment No. 244

7

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 Amendment No. 244

PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.5 The Control Room Emergency Ventilation System shall be OPERABLE* with:

a.

Three air handling units,

b.

Two of three condensing units,

c.

Two control room recirculation fans,

d.

Two recirculation dampers,

e.

One filter train, f

Two isolation dampers in the normal outside air intake duct,

g.

Two isolation dampers in the emergency outside air intake duct,

h.

Two isolation dampers in the kitchen area exhaust duct, and

i.

Two isolation dampers in the toilet area exhaust duct.

APPLICABILITY:

All MODES.

ACTION:

MODES 1, 2, 3 and 4:

a.1 With one air handling unit inoperable, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable air handling unit to OPERABLE status or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

a.2 With two condensing units inoperable, immediately suspend all movement of irradiated fuel and, within 7 days, restore at least one of the inoperable condensing units to OPERABLE status or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously. be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

a.3 With one recirculation fan inoperable, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable fan to OPERABLE status or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

• The Control Room Envelope (CRE) boundary may be opened intermittently under administrative control.

TURKEY POINT - UNITS 3 & 4 3/4 7-16 A~NDt1ENT NOS. 248 AND 24"

PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued) a.4 With one recirculation damper inoperable, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or place and maintain at least one of the recirculation dampers in the open position and place the system in recirculation mode**

or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

a.5 With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable recirculation fans, and/or two inoperable recirculation dampers, immediately suspend all movement of irradiated fuel, and, immediately initiate action to implement mitigating actions (e.g., use of the compensatory filtration unit is required to be immediately initiated), and, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits and, within 7 days, restore the filter train to OPERABLE status.

With the above requirements not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

a.6 With an inoperable damper in the normal outside air intake, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or place and maintain at least one of the normal outside air intake isolation dampers in the closed position and place the system in recirculation mode** or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

a.7 With an inoperable damper in the emergency outside air intake, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or place and maintain at least one of the emergency outside air intake isolation dampers in the open position** or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

a.8 With an isolation damper inoperable in the kitchen area exhaust duct, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or isolate the flow path*'" or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

a.9 With an isolation damper inoperable in the toilet area exhaust duct, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or isolate the flow path** or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units Simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

• • If action is taken such that indefinite operation is permitted and the system is placed in recirculation mode, then movement of irradiated fuel may resume.

TURKEY POINT - UNITS 3 & 4 3/47-16a AMENDMENT NOS. 248 AND 244

PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATIONjcontinued)

b.

With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary, immediately suspend all movement of irradiated fuel in the spent fuel pool, and immediately initiate action to implement mitigating actions, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits and CRE occupants are protected from smoke hazards, and restore CRE boundary to OPERABLE status within 90 days, or:

1.

With the requirements not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

2.

If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5 and 6:

c.

With the Control Room Emergency Ventilation System inoperable, immediately suspend all operations involving CORE ALTERATIONS, movement of irradiated fuel in the spent fuel pool, or positive reactivity changes. This ACTION shall apply to both units simultaneously.

4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 120°F;

b.

At least once per 31 days by initiating, from the control room, flow throL1gh the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes***;

c.

At least once per 18 months or (1) after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (3) following exposure of the filters to effluents from painting, fire, or chemical release in any ventilation zone communicating with the system that may have an adverse effect on the functional capability of the system, or (4) after complete or partial replacement of a filter bank by:

• • • As the mitigation actions of TS 3.7.5 Action a.5 may include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room and TS 4.7.5.c and d.

TURKEY POINT - UNITS 3 & 4 3/47-16b AMENDMENT NOS. 248 ANn 244

PLANT SYSTEMS

1)

Verifying that the air cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of greater than or equal to 99% DOP and halogenated hydrocarbon removal at a system flow rate of 1000 cfm +/-10%***.

2)

Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, and analyzed per ASTM D3803 - 1989 at 30°C and 95% relative humidity, meets the methyl iodide penetration criteria of less than 2.5% or the charcoal be replaced with charcoal that meets or exceeds the stated performance requirement***, and

3) Verifying by a visual inspection the absence of foreign materials and gasket deterioration ***.

d.1 At least once per 12 months by verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 1000 cfm +/-1 0% ***;

d.2 On a staggered test basis every 36 months, test the supply fans (trains A and B) and measure CRE pressure relative to external areas adjacent to the CRE boundary.

e.

At least once per 18 months by verifying that on a Containment Phase "An Isolation test signal the system automatically switches into the recirculation mode of operation,

f.

At least once per 18 months by verifying operability of the kitchen and toilet area exhaust dampers, and

g.

By performing required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

• • • As the mitigation actions of TS 3.7.5 Action a.5 may include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room and TS 4.7.5.c and d.

TURKEY POINT - UNITS 3 & 4 3/47-17 AMENDMENT NOS. 248 AND 244

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

d.

Provisions for SG tube inspections. Periodic SG tube inspections shall be performed.

The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube repair criteria. For Unit 3 through Refueling Outage 25 and the next operating cycle, and for Unit 4 during Refueling Outage 25 and the subsequent operating cycles until the next scheduled inspection, the portion of the tube below 17.28 inches from the top of the tubesheet is excluded from inspection. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. An assessment of degradation shall be performed to determine the type and location of flaws to which the tube may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.

1.

Inspect 100% of the tubes in each SG during the first refueling outage following SG replacement.

2.

Inspect 100% of the tubes at sequential periods of 120, 90, and, thereafter, 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outages nearest the end of the period. No SG shall operate for more than 48 effective full power months or two refueling outages (whichever is less) without being inspected.

3.

If crack indications are found in any portion of a SG tube not excluded above, then the next inspection for each SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s),

then the indication need not be treated as a crack.

e.

Provisions for monitoring operational primary-secondary leakage.

k.

Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a.

The definition of the CRE and the CRE boundary.

b.

Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

TURKEY POINT - UNITS 3 & 4 6-18b AMENDMENT NOS. 248 AND 2Lf4

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

c.

Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision O.

d.

Measurement, at designated locations, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation of the CREVS, operating at the flow rate required by Surveillance Requirement 4.7.5.d, at a Frequency of 18 months. Additionally. the supply fans (trains A and B) will be tested on a staggered test basis (defined in Technical SpeCification definition 1.29 every 36 months). The results shall be trended and the CRE boundary assessed every 18 months.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SpeCification 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

6.8.5 DELETED TURKEY POINT - UNITS 3 & 4 6-18c AMENDMENT NOS. 248 AND 244

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 248 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AND AMENDMENT NO. 244 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-41 FLORIDA POWER AND LIGHT COMPANY TURKEY POINT PLANT, UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251

1.0 INTRODUCTION

By application dated July 16, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102010386), as supplemented by letters dated July 18, 2011 (No. ML11202A021), August 1, 2011 (No. ML11215A013), October 27, 2011 (No. ML11304A184), and March 13, 2012 (No. ML12088A008), Florida Power & Light Company (the licensee) requested changes to the Technical Specifications (TSs) for Turkey Point Plant, Unit Nos. 3 and 4 (TP 3 and 4). The supplements provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on January 25, 2011 (76 FR 4386).

On August 8, 2006, the commercial nuclear electrical power generation industry owners group Technical Specifications Task Force (TSTF) submitted a proposed change, TSTF-448, Revision 3, to the improved standard technical specifications (STSs) (NUREGs 1430-1434) on behalf of the industry (TSTF-448, Revisions 0, 1, and 2 were prior draft iterations). TSTF-448, Revision 3, is a proposal to establish more effective and appropriate action, surveillance, and administrative STS requirements related to ensuring the habitability of the control room envelope (CRE).

In the U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2003-01 (Reference 1),

licensees were alerted to findings at facilities that existing TS surveillance requirements for the Control Room Envelope Emergency Ventilation System (CREEVS) may not be adequate.

Specifically, the results of ASTM E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance is not a reliable method for demonstrating CRE boundary operability. Licensees were requested to address existing TS as follows:

Provide confirmation that your technical specifications verify the integrity

[i.e., operability] of the eRE boundary, and the assumed unfiltered inleakage rates ofpotentially contaminated air. If you currently have a differential pressure

- 2 surveillance requirement to demonstrate CRE boundary integrity, provide the basis for your conclusion that it remains adequate to demonstrate CRE integrity in light of the ASTM E741 testing results. If you conclude that your differential pressure surveillance requirement is no longer adequate, provide a schedule for:

1) revising the surveillance requirement in your technical specification to reference an acceptable surveillance methodology (e.g., ASTM E741), and

2) making any necessary modifications to your CRE boundary so that compliance with your new surveillance requirement can be demonstrated.

If your facility does not currently have a technical specification surveillance requirement for your CRE integrity, explain how and at what frequency you confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.

To promote standardization and to minimize the resources that would be needed to create and process plant-specific amendment applications in response to the concerns described in the GL, the industry and the NRC proposed revisions to CRE habitability system requirements contained in the STSs, using the STS change traveler process. This effort culminated in Revision 3 to traveler TSTF-448, "Control Room Habitability," which the NRC staff approved on January 17, 2007.

Consistent with the traveler as incorporated into NUREG-1431, the licensee proposed revising action and surveillance requirements in TS 3/4.7.5, "Control Room Emergency Ventilation System (CREVS)," and adding a new Administrative Controls - Procedures and Programs, TS Section 6.8.4.k. "CRE Habitability Program." The purpose of the changes is to ensure that CRE boundary operability is maintained and verified through effective surveillance and programmatic requirements, and that appropriate remedial actions are taken in the event of an inoperable CRE boundary.

Some editorial and plant-specific changes were incorporated into this safety evaluation resulting in minor deviations from the model safety evaluation text in TSTF-448, Revision 3.

2.0 REGULATORY EVALUATION

2.1 Control Room and Control Room Envelope NRC Regulatory Guide (RG) 1.196, "Control Room Habitability at Light-water Nuclear Power Reactors," Revision 0, May 2003, (Reference 4) uses the term "control room envelope" in addition to the term "control room" and defines each term as follows:

Control Room: The plant area, defined in the facility licensing basis, in which actions can be taken to operate the plant safely under normal conditions and to maintain the reactor in a safe condition during accident situations. It encompasses the instrumentation and controls necessary for a safe shutdown of the plant and typically includes the critical document reference file, computer room (if used as an integral part of the emergency response plan), shift supervisor's office, operator wash room and kitchen, and other critical areas to which frequent personnel access or continuous occupancy may be necessary in the event of an accident.

- 3 Control Room Envelope: The plant area, defined in the facility licensing basis that in the event of an emergency, can be isolated from the plant areas and the environment external to the CRE. This area is served by an emergency ventilation system, with the intent of maintaining the habitability of the control room. This area encompasses the control room, and may encompass other non critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident.

The NRC RG 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003 (Reference 5), also contains these definitions, but uses the term CRE to mean both. This is because the protected environment provided for operators varies with the nuclear power facility. At some facilities, this environment is limited to the control room; at others, it is the CRE. In this safety evaluation, consistent with the proposed changes to the STSs, the CRE will be used to designate both. For consistency, facilities should use the term CRE with an appropriate facility-specific definition derived from the above CRE definition.

2.2 Control Room Emergency Ventilation System (CREVS)

The CREVS (the term used at TP 3 and 4 for the Control Room Envelope Emergency Ventilation System, CREEVS) provides a protected environment from which operators can control the unit, during airborne challenges from radioactivity, hazardous chemicals, and fire byproducts, such as fire suppression agents and smoke, during both normal and accident conditions.

OPERABILITY of the CREVS ensures that: (1) the ambient air temperature does not exceed the allowable temperature for continuous-duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for occupants during and following an uncontrolled release of radioactivity, hazardous chemicals or smoke. The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the CRE to 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The radiological limits are consistent with the requirements of Title 10 ofthe Code of Federal Regulations (10 CFR), Section 50.67. CRE occupants are protected from chemical hazards in accordance with the limits of RG 1.78.

The CREVS consists of three air handling units, three condensing units, two control room recirculation fans, two recirculation dampers, one filter train, two isolation dampers in the normal outside air intake duct, two isolation dampers in the emergency outside air intake duct, two isolation dampers in the kitchen area exhaust duct and two isolation dampers in the toilet area exhaust duct. TSTF-448, Revision 3 considers [CREEVSj to be operable when there are two trains operable, which is different from Turkey Point's CREVS design. Turkey Point's CREVS is considered operable when the individual components necessary to limit operator exposure are operable. To compensate for a second train, Turkey Point's design includes a compensatory filtration unit. Turkey Point's design is acceptable and meets the intent of TSTF-448, Revision 3 due to the redundancy established with the compensatory filtration unit. The CREVS is considered operable when the associated:

• Three air handling units are operable

• Two of three condensing units are operable

- 4

• Two control room recirculation fans are operable

• Two recirculation dampers are operable

• One filter train is operable

• Two isolation dampers in the normal outside air intake duct are operable

• Two isolation dampers in the emergency outside air intake duct are operable

• Two isolation dampers in the kitchen area exhaust duct are operable, and

• Two isolation dampers in the toilet area exhaust duct are operable.

The CRE boundary is considered operable when the measured unfiltered air inleakage is less than or equal to the inleakage value assumed by the licensing basis analyses of design basis accident consequences to CRE occupants.

2.3 Regulations Applicable to Control Room Habitability In Appendix A. "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production, and Utilization Facilities," General Design Criteria (GDC) 1, 2, 3, 4, 5, and 19 apply to CRE habitability. A summary of these GDC follows. Facilities not licensed under the GDC from 10 CFR Part 50 are licensed under similar plant-specific design criteria, as described in the facility's licensing basis documents.

Section 1.3 of Turkey Point Final Safety Analysis Report (FSAR) "General Design Criteria" states the following:

The general design criteria define or describe safety objectives and approaches incorporated in the design. These general design criteria are addressed explicitly in the pertinent sections in this report [Turkey Point FSAR]. The remainder of this section, 1.3, presents a brief description of related features which are provided to meet the design objectives reflected in the criteria. The description is developed more fully in those succeeding sections of the report indicated by the references.

The parenthetical numbers following the section headings indicate the numbers of the 1967 proposed draft General Design Criteria.

GDC 1, "Quality Standards and Records," requires that structures, systems and components (SSCs) important to safety be designed, fabricated, erected and tested to quality standards commensurate with the importance of the safety functions performed.

GDC 2, "Design Basis for Protection Against Natural Phenomena," requires that SSCs important to safety be designed to withstand the effects of earthquakes and other natural hazards.

GDC 3, "Fire Protection: requires SSCs important to safety be designed and located to minimize the effects of fires and explosions.

- 5 GDC 4, "Environmental and Dynamic Effects Design Bases," requires SSCs important to safety to be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents (LOCAs).

GDC 5, "Sharing of Structures, Systems, and Components," requires that SSCs important to safety not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including in the event of an accident in one unit, the orderly shutdown and cool-down of the remaining units.

GDC 19, "Control Room," requires that a control room be provided from which actions can be taken to operate the nuclear reactor safely under normal conditions and to maintain the reactor in a safe condition under accident conditions, including a LOCA Adequate radiation protection is to be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of specified values.

Prior to incorporation of TSTF-448, Revision 3, the STS requirements addressing CRE boundary operability resided only in the following CREVS specifications:

NUREG-1430, TS 3.7.10, "Control Room Emergency Ventilation System (CREVS)";

NUREG-1431, TS 3.7.10, "Control Room Emergency Filtration System (CREFS),,;

NUREG-1432, TS 3.7.11, "Control Room Emergency Air Cleanup System (CREACS),,;

NUREG-1433, TS 3.7.4, "Main Control Room Environmental Control (MCREC) System";

and NUREG-1434, TS 3.7.3, "Control Room Fresh Air (CRFA)] System."

In these specifications, the surveillance requirement (SR) associated with demonstrating the operability of the CRE boundary requires verifying that one CREVS train can maintain a positive pressure relative to the areas adjacent to the CRE during the pressurization mode of operation at a makeup flow rate as specified in the TSs. Facilities that pressurize the CRE during the emergency mode of operation of the CREVS have similar SRs. Other facilities that do not pressurize the CRE have only a system flow rate criterion for the emergency mode of operation.

Regardless, the results of ASTM E741 (Reference 2) tracer gas tests to measure CRE unfiltered inleakage at facilities indicated that the differential pressure surveillance (or the alternative surveillance at non pressurization facilities) is not a reliable method for demonstrating CRE boundary operability. That is, licensees were able to obtain differential pressure and flow measurements satisfying the SR limits even though unfiltered inleakage was determined to exceed the value assumed in the safety analyses.

In addition to an inadequate surveillance requirement, the action requirements of these specifications were ambiguous regarding CRE boundary operability in the event CRE unfiltered in leakage is found to exceed the analysis assumption. The ambiguity stemmed from the view that the CRE boundary may be considered operable but degraded in this condition, and that it would be deemed inoperable only if calculated radiological exposure limits for CRE occupants exceeded a licensing basis limit (e.g., as stated in GDC 19), even while crediting compensatory measures.

NRC Administrative Letter 98-10 (AL 98-10), "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," states that the discovery of an improper or inadequate TS

-6 value or required action is considered a degraded or nonconforming condition, which is defined in NRC Inspection Manual Chapter 9900; see latest guidance in Regulatory Information Summary (RIS) 2005-20 (Reference 3). "Imposing administrative controls in response to the improper or inadequate TS is considered an acceptable short-term corrective action. The NRC staff expects that, following the imposition of administrative controls, an amendment to the inadequate TS, with appropriate justification and schedule, will be submitted in a timely fashion."

Licensees that have found unfiltered inleakage in excess of the limit assumed in the safety analyses and have yet to either reduce the inleakage below the limit or establish a higher bounding limit through re-analysis, have implemented compensatory actions to ensure the safety of CRE occupants, pending final resolution of the condition, consistent with RIS 2005-20.

However, based on GL 2003-01 and AL 98-10, the NRC staff expects each licensee to propose TS changes that include a surveillance to periodically measure CRE unfiltered inleakage in order to satisfy 10 CFR 50.36{c)(3), which requires a facility's TSs to include SRs, which it defines as "requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that limiting conditions for operation will be met." (Emphasis added.)

The NRC staff also expects facilities to propose unambiguous remedial actions, consistent with 10 CFR 50.36(c){2), for the condition of not meeting the limiting condition for operation (LCO) due to an inoperable CRE boundary.

The action requirements should specify a reasonable completion time to restore conformance to the LCO before requiring a facility to be shut down. This completion time should be based on the benefits of implementing mitigating actions to ensure CRE occupant safety and sufficient time to resolve most problems anticipated with the CRE boundary, while minimizing the chance that operators in the CRE will need to use mitigating actions during accident conditions.

2.4 Adoption of TSTF-448. Revision 3, by Turkey Point, Units 3 and 4 Adoption of TSTF-448, Revision 3, will assure that the facility's TS LCO for the CREVS is met by demonstrating unfiltered leakage into the CRE is within limits (Le., the operability of the CRE boundary). In support of this surveillance, which specifies a test interval (frequency) described in RG 1.197, TSTF-448 also adds TS administrative controls to assure the habitability of the CRE between performances of the ASTM E741 test. In addition, adoption of TSTF-448 will establish clearly stated and reasonable required actions in the event CRE unfiltered inleakage is found to exceed the analysis assumption.

The changes made by TSTF-448 to the STS requirements for the CREVS and the CRE boundary conform to 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3). Their adoption will better assure that TP 3 and 4 CRE will remain habitable during normal operation and design basis accident conditions. These changes are, therefore, acceptable from a regulatory standpoint.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the proposed changes against the corresponding changes made to the STSs by TSTF-448, Revision 3, which the NRC staff has found to satisfy applicable regulatory requirements, as described above in Section 2.0. The emergency operational mode of the

-7 CREVS at TP 3 and 4 pressurizes the CRE to minimize unfiltered air inleakage. The proposed changes are consistent with this design.

3.1 Proposed Changes The proposed amendment would strengthen CRE habitability TS requirements by changing TS 3/4.7.5, "CREVS," and adding a new TS administrative controls program on CRE habitability.

Accompanying the proposed TS changes are appropriate conforming technical changes to the TS Bases. The proposed revision to the Bases also includes editorial and administrative changes to reflect applicable changes to the corresponding STS Bases, which were made to improve clarity, conform to the latest information and references, correct factual errors, and achieve more consistency among the STS NUREGs. Except for plant-specific differences, all of these changes are consistent with STSs as revised by TSTF-448, Revision 3.

The NRC staff compared the proposed TS changes to the STSs and the STS markups and evaluations in TSTF-448. The staff verified that differences from the STSs were adequately justified on the basis of plant-specific design or retention of current licensing basis. The NRC staff also reviewed the proposed changes to the TS Bases for consistency with the STS Bases and the plant-specific design and licensing bases, although approval of the Bases is not a condition for accepting the proposed amendment. However, TS 6.8.4.i, "TS Bases Control Program," provides assurance that the licensee has established and will maintain the adequacy of the Bases. The proposed Bases for TS 3/4.7.5 refer to specific Nuclear Energy Institute (NEI) guidance in NEI 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001 (Reference 6), which the NRC staff has formally endorsed, with exceptions, through RG 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," dated May 2003 (Reference 4).

3.2 Editorial Changes The licensee proposed editorial changes to TS 3/4.7.5, "CREVS," to establish standard terminology, such as "control room envelope (CRE)" in place of "control room," except for the plant-specific name for the CREVS (plant specific name for CREEVS), and "radiological, chemical, and smoke hazards (or challenges)" in place of various phrases to describe the hazards that CRE occupants are protected from by the CREVS. Turkey Point TSs retained the plant-specific name for the CREVS and used the phrase "radiological and chemical hazards will not exceed limits, and CRE occupants are protected from smoke hazards" to describe the hazards that CRE occupants are protected from by the CREVS. These changes improve the usability and quality of the presentation of the TSs, have no impact on safety, and therefore, are acceptable.

3.3 TS 3/4.7.5, CREVS The licensee proposed to establish a new Condition b and Action requirements for TS 3/4.7.5, "CREVS," for an inoperable CRE boundary. This is accomplished by ensuring Condition a excludes Condition b, while Condition b address an inoperable CREVS due to an inoperable CRE boundary as follows:

Condition a:

CREVS inoperable in MODES 1,2,3, and 4 for reasons other than Condition b.

- 8 Condition b:

CREVS inoperable due to inoperable CRE boundary in MODE 1, 2, 3, and

4.

This change clarifies how to apply the action requirements in the event the CREVS is unable to ensure CRE occupant safety within licensing basis limits because of an inoperable CRE boundary. Currently, if the CREVS is determined to be inoperable due to an inoperable CRE boundary, existing Action a would apply and require restoring the CREVS (and the CRE boundary) to operable status in 7 days.

The licensee proposed to add new Condition b and Action requirements, "With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary, immediately suspend all movement of irradiated fuel in the spent fuel pool, and immediately initiate action to implement mitigating actions, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits, and CRE occupants are protected from smoke hazards, and restore CRE boundary to OPERABLE status within 90 days."

The 24-hour Completion Time of the new Action requirements of Condition b is reasonable based on the low probability of a design-basis accident (DBA) occurring during this time-period, and the use of mitigating actions as directed by the Action requirements of Condition b. The 90 day Completion Time of the new Action requirements of Condition b is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. The 90-day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most anticipated problems with the CRE boundary.

Therefore, proposed Condition b and Action requirements are acceptable.

The proposed CRE inleakage measurement SR states, "By performing required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program." The CRE Habitability Program TS, proposed TS 6.8.4.k, requires that the program include "Requirements for determining the unfiltered air in leakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0" (Reference 5). This guidance references ASTM E741 (Reference 2) as an acceptable method for ascertaining the unfiltered leakage into the CRE.

The licensee has proposed to follow this method. Therefore, the proposed CRE inleakage measurement SR is acceptable.

The licensee also proposed to modify the CREVS LCO by adding a note allowing the CRE boundary to be opened intermittently under administrative controls. As stated in the LCO Bases, this Note "only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated." The allowance of this note is acceptable because the administrative controls will ensure that the opening will be quickly sealed to maintain the validity of the licensing basis analyses of DBA consequences.

- 9 3.4 TS 6.8.4.k, CRE Habitability Program The proposed administrative controls program TS is consistent with the model program TS in TSTF-448, Revision 3. In combination with SR 3/4.7.5.g this program is intended to ensure the operability of the CRE boundary, which as part of an operable CREVS will ensure that CRE habitability is maintained such that CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident.

A CRE Habitability Program TS acceptable to the NRC staff requires the program to contain the following elements:

Definitions of CRE and CRE boundary. This element is intended to ensure that these definitions accurately describe the plant areas that are within the CRE, and also the interfaces that form the CRE boundary, and are consistent with the general definitions discussed in Section 2.1 of this safety evaluation. Establishing what is meant by the CRE and the CRE boundary will preclude ambiguity in the implementation of the program.

Configuration control and preventive maintenance of the CRE boundary. This element is intended to ensure the CRE boundary is maintained in its design condition. Guidance for implementing this element is contained in RG 1.196 (Reference 4), which endorsed, with exceptions, NEI 99-03 (Reference 6). Maintaining the CRE boundary in its design condition provides assurance that its leak-tightness will not significantly degrade between CRE inleakage determinations.

Assessment of CRE habitability at the frequencies stated in Sections C.1 and C.2 of RG 1.197, Revision 0 (Reference 5). and measurement of unfiltered air leakage into the CRE in accordance with the testing methods and at the frequencies stated in Sections C.1 and C.2 of RG 1.197. This element is intended to ensure that the plant assesses CRE habitability consistent with Sections C.1 and C.2 of RG 1.197. Assessing CRE habitability at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not go undetected between CRE in leakage determinations. Determination of CRE inleakage using test methods acceptable to the NRC staff assures that test results are reliable for ascertaining CRE boundary operability. Determination of CRE inleakage at the NRC accepted frequencies provides assurance that significant degradation of the CRE boundary will not occur between CRE inleakage determinations Measurement of CRE pressure with respect to all areas adjacent to the CRE boundary at designated locations for use in assessing the CRE boundary at a frequency of 18 months on a staggered test basis (with respect to the CREVS). This element is intended to ensure that CRE differential pressure is regularly measured to identify changes in pressure warranting evaluation of the condition of the CRE boundary. Obtaining and trending pressure data provides additional assurance that significant degradation of the CRE boundary will not go undetected between CRE inleakage determinations.

Quantitative limits on unfiltered inleakage. This element is intended to establish the CRE inleakage limit as the CRE unfiltered infiltration rate assumed in the CRE occupant radiological

- 10 consequence analyses of design basis accidents. Having an unambiguous criterion for the CRE boundary to be considered operable in order to meet LCO 3.7.5, will ensure that associated action requirements will be consistently applied in the event of CRE degradation resulting in inleakage exceeding the limit.

Consistent with TSTF-448, Revision 3, the program states that the provisions of SR 4.0.2 are applicable to the program frequencies for performing the activities required by program paragraph number c, parts (i) and (ii) (assessment of CRE habitability and measurement of CRE inleakage), and paragraph number d (measurement of CRE differential pressure). This statement is needed to avoid confusion. SR 4.0.2 is applicable to the surveillance that references the testing in the CRE Habitability Program. However, SR 4.0.2 is not applicable to Administrative Controls unless specifically invoked. Providing this statement in the program eliminates any confusion regarding whether SR 4.0.2 is applicable, and is acceptable.

Consistent with TSTF-448, Revision 3, proposed TS 6.8.4.k states that (1) a CRE Habitability Program shall be established and implemented, (2) the program shall include all of the NRC staff required elements, as described above, and (3) the provisions of SR 4.0.2 shall apply to program frequencies. Therefore, TS 6.8.4.k, which is consistent with the model program TS approved by the NRC staff in TSTF-448, Revision 3, is acceptable.

3.5 Implementation of New Surveillance and Assessment Requirements by the Licensee The licensee has proposed license conditions regarding the initial performance of the new surveillance and assessment requirements. The new license conditions adopted the conditions in section 2.3 of the model application published in the Federal Register on January 17, 2007 (72 FR 2022). Plant specific changes were made to these proposed license conditions. The proposed plant specific license conditions are consistent with the model application, and are acceptable.

4.0 STATE CONSULTATION

Based upon a letter dated May 2, 2003, from Michael N. Stephens of the Florida Department of Health, Bureau of Radiation Control, to Brenda L. Mozafari, Senior Project Manager, U.S. Nuclear Regulatory Commission, the State of Florida does not desire notification of issuance of license amendments.

5.0 ENVIRONMENTAL CONSIDERATION

These amendments involve a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements.

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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (76 FR 4386). Accordingly, these 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.

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6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, 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) 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.

7.0 REFERENCES

1. NRC Generic Letter 2003-01, "Control Room Habitability," dated June 12, 2003.

2. ASTM E 741 - 00, "Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution," 2000.

3. NRC Regulatory Issue Summary 2005-20: Revision to Guidance Formerly Contained in NRC Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," dated September 26, 2005.

4. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, dated May 2003.

5. Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003.

6. NEI 99-03, "Control Room Habitability Assessment Guidance," Revision 0, dated June 2001.

Principal Contributor: Harold Walker Date: March 30, 2012

March 30, 2012 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT PLANT, UNIT NOS. 3 AND 4 - ISSUANCE OF AMENDMENTS REGARDING CONTROL ROOM HABITABILITY TECHNICAL SPECIFICATION TASK FORCE (TSTF)-448 (TAC NOS. ME4277 AND ME4278)

Dear Mr. Nazar:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 248 to Renewed Facility Operating License No. DPR-31 and Amendment No. 244 to Renewed Facility Operating License No. DPR-41 for the Turkey Point Plant, Units Nos. 3 and 4, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated July 16, 2010, as supplemented by letters dated July 18, 2011, August 1, 2011, October 27, 2011, and March 13, 2012.

The amendments revise the TS requirements related to control room envelope habitability in accordance with Technical Specification Task Force (TSTF) Change Traveler TSTF-448, Revision 3, "Control Room Habitability." TSTF-448 was made available by the NRC on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, IRA by Trace Orf forI Jason C. Paige, 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. 248 to DPR-31

2. Amendment No. 244 to DPR-41

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

PUBLIC RidsOgcRp RidsRgn2MailCenter LPL2-2 R/F RidsAcrsAcnwMailCenter RidsNrrPMTurkeyPoint RidsNrrDorlLpl2-2 RidsNrrDssStsb HWalker. NRR RidsNrrLABClayton RidsNrrDorlDpr RidsNrrDssScvb ADAMS Accession No ML12067A176 OFFICE LPL2-2/PM LPL2-2/LA STSB/BC OGC NLO LPL2-2/BC LPL2-2/PM NAME JPaige BClayton RElliolt LSubin wi comment DBroaddus JPaige (TOrt for)

DATE 03/09/12 03/09/12 03/23/12 03120112 03130/12 03130/12 OFFICIAL RECORD COpy