Text

Regarding License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS)
	ML16230A003
Person / Time
Site:	Turkey Point
Issue date:	08/03/2016
From:	Summers T; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2016-246
	Download: ML16230A003 (43)
	v • d • e

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE:

Turkey Point Nuclear Plant, Units 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating Licenses DRR-31 and DPR-41 L-2016-246 10 CFR 50.90 August 3, 2016 License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS)

Pursuant to 1 O CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests an amendment to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant (Turkey Point) Units 3 and 4, respectively. The proposed license amendment modifies Turkey Point Units 3 and 4 Technical Specification (TS) 3.7.5, Control Room Emergency Ventilation System, by revising the TS Limiting Conditions for Operation, ACTION(s), and Surveillance Requirements to reflect the current system design and to align more closely with NUREG 1431, Revision 4.0, Standard Technical Specifications - Westinghouse Plants. Enclosure 1 provides FPL's evaluation of the proposed changes. Attachment 1 to the enclosure provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides the retyped (clean copy) TS pages with revision bars to identify the proposed changes. Attachment 3 provides existing TS Bases pages marked up to show the proposed changes. The TS Bases changes are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment.

FPL has determined that the proposed changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and there are no significant environmental impacts associated with the change. The Turkey Point Plant Nuclear Safety Committee has reviewed the proposed license amendment. In accordance with 1 O CFR 50.91 (b)(1 ), a copy of the proposed amendments is being forwarded to the designee for the State of Florida.

FPL requests approval and issuance of the proposed license amendment by August 3, 2017. Once approval is received, the amendment will be implemented within 90 days.

This letter contains no new or revised regulatory commitments.

Florida Power & Light Company 9760 SW 344 St., Homestead, FL 33035

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Should you have any questions regarding this application, please contact Mr. Mitch Guth, Turkey Point Licensing Manager, at (305)246-6698.

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

Executed on the 3rd day of August 2016.

Sincerely,

~.s~~--~~~~--

Site Vice President Turkey Point Nuclear Plant Enclosure cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health L-2016-246 Page 2 of2

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Enclosure Evaluation of the Proposed Change Turkey Point Units 3 and 4 License Amendment Request (LAR) No. 246 L-2016-246 Enclosure Page 1 of 20 Changes to Technical Specification 3/4.7.5, Control Room Emergency Ventilation System 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1

System Description

2.2 Current Technical Specification Requirements 2.3 Description of Proposed Changes

3.0 TECHNICAL EVALUATION

3.1 Turkey Point Design vs. Westinghouse Standard Technical Specifications 3.2 Immediate Suspension of Irradiated Fuel Movement 3.3 Control Room Kitchen and Lavatory Ventilation Exhaust Dampers

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

- Proposed Technical Specification Pages (markup) - Proposed Technical Specification Pages (clean copy) - Proposed Technical Specification Bases Pages (markup)

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 License Amendment Request No. LAR-246 L-2016-246 Enclosure Page 2 of 20 Technical Specification 3/4.7.5, Control Room Emergency Ventilation System Turkey Point Units 3 and 4 1.0

SUMMARY

DESCRIPTION Florida Power & Light Company (FPL) hereby requests an amendment to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant (Turkey Point) Units 3 and 4, respectively. The proposed license amendment modifies Turkey Point Units 3 and 4 Technical Specification (TS) 3.7.5, Control Room Emergency Ventilation System, by changing the required ACTION(s) for inoperable Control Room Emergency Ventilation System (CREVS) recirculation fans, air handlers, condensing units, ventilation dampers and the Control Room Envelope (CRE) boundary. The changes are proposed in order to align TS 3.7.5 more closely with Westinghouse Standard Technical Specification (STS) 3.7.10 of NUREG 1431, Revision 4 (Reference 6.1 ). Consequently, the requirements to immediately suspend irradiated fuel movement are relocated, in most cases, to coincide with the commencement of Unit(s) shutdown in the event the allowable outage time (AOT) cannot be met for an inoperable CREVS component or CRE boundary. As such, the proposed license amendment aligns the current TS 3.7.5 ACTION(s) with the STS 3. 7.10 ACTION(s) for an inoperable CREVS train.

The proposed license_amendment also eliminates the TS Limiting Conditions for Operation (LCO), ACTION(s) and Surveillance Requirements (SRs) associated with the CREVS kitchen and lavatory ventilation exhaust duct isolation dampers. In 2012, FPL permanently isolated the kitchen and lavatory ventilation exhaust flow paths with seismic Class 1 solid plates as a means to ensure the CRE will satisfy Title 10 of the Code of Federal Regulations (10 CFR), Section 50, Appendix A, General Design Criteria (GDC) 19, Control Room. The proposed license amendment removes the CREVS from long term ACTION(s) TS 3.7.5.a.8 and TS 3.7.5 a.9 by aligning the CREVS licensing basis with its current design.

2.0 DETAILED DESCRIPTION 2.1

System Description

The CREVS 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 the 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 the 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 10 CFR 50.67, Accident Source Term. CRE occupants are protected from chemical hazards in accordance with the limits of Regulatory Guide 1. 78, Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 3 of20 The function of the Control Room ventilation system, including the CREVS, is to provide a controlled environment for the comfort and safety of Control Room personnel and to assure the operability of Control Room components during normal operation, anticipated operational occurrences, and design basis accident conditions. The design basis of the system with respect to radiological emergencies is to be capable of automatically starting under accident conditions to initiate emergency Control Room pressurization and filtration, assuming the occurrence of a single active damper or supply fan failure. The design basis of the system with respect to other emergencies that could affect the Control Room environment is to be capable of manual actuation.

The Control Room ventilation system, which normally draws in fresh air from the outside, has the capability to go into a recirculation mode that is part of the CREVS. In the recirculation mode, fresh air provided from the CREVS intake piping and recirculated air from the Control Room is processed through the recirculation high efficiency particulate air (HEPA) filters and charcoal filters (single train filtration unit) and supply fans to maintain an acceptable Control Room environment during adverse radiological conditions. A compensatory filtration unit is provided as a qualified backup to the CREVS recirculation filter train and is manually aligned for operation should the CREVS recirculation filter train become non-functional.

The Control Room ventilation emergency mode is initiated by manual containment isolation Phase "A" or Phase "B" initiation, a high radiation signal from the containment atmosphere radiation monitors, manual initiation from a test switch, or a high radiation signal from the redundant monitors in the control room normal air intake. Following initiation, all exhaust fans are shut off, and the redundant exhaust isolation dampers in series are closed. Redundant normal air intake isolation dampers in series are closed, and redundant emergency air intake dampers in parallel are opened. The recirculation air path is opened, and a single air supply fan is energized to move the appropriate mixture of recirculating Control Room air and new outdoor air through the HEPA and charcoal filter system.

2.2 Current Technical Specification Requirements Immediate Suspension of Irradiated Fuel Movement TS ACTION(s) 3.7.5.a.1 through 3.7.5.a.4, 3.7.5.a.6 and 3.7.5.a.7 specify the required ACTION(s) for inoperable CREVS air handlers, condensing units, recirculation fans, and the normal outside air intake, recirculation and emergency outside air intake isolation dampers. Each requires the immediate suspension of irradiated fuel movement upon the determination of inoperability. In the case of an inoperable normal outside air intake, recirculation or emergency outside air intake isolation damper, a footnote allows irradiated fuel movement to resume after placing the redundant normal outside air intake, recirculation or emergency outside air intake damper in its fail-safe position and placing CREVS in emergency recirculation mode, and this configuration is allowed indefinitely.

TS ACTION(s) 3.7.5.a.1 through 3.7.5.a.4, 3.7.5.a.6 and 3.7.5.a.7 are currently as 1

indicated below:

ACTION:

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page4 of 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 h.ours.

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hol!rs.

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

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

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

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

- 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.

TS ACTION 3. 7.5.a.5 specifies the required ACTION for an inoperable filter train. The immediate suspension of irradiated fuel movement and the immediate action to initiate

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 5 of 20 action to place the compensatory filtration unit in service are required. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the mitigating ACTION(s) must be verified to ensure that CRE occupant radiological exposures will not exceed allowable limits.

TS ACTION 3.7.5.a.5 is currently as indicated below:

ACTION:

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

TS ACTION 3.7.5.b specifies the required ACTION for an inoperable CRE boundary.

The immediate suspension of irradiated fuel movement and the immediate action to initiate mitigating actions are required. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the mitigating actions must be verified to ensure that CRE occupant radiological exposures and chemical hazards will not exceed allowable limits.

TS ACTION 3.7.5.b is currently as indicated below:

ACTION:

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

2)

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

TS ACTION 3.7.5.c specifies the required ACTION for an inoperable CREVS in Modes 5 and 6. The immediate suspension of irradiated fuel movement, core alterations and positive reactivity changes are required. A footnote allows the resumption of irradiated fuel movement, core alterations and positive reactivity changes for an inoperable normal outside air intake, recirculation, or emergency outside air intake isolation damper after

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 6 of 20 placing the associated redundant isolation damper in its fail-safe position and placing CREVS in the emergency recirculation mode, and this configuration is allowed indefinitely. The same footnote allows the resumption of irradiated fuel movement, core alterations and positive reactivity changes for an inoperable kitchen or lavatory area exhaust isolation damper after isolating the associated kitchen or lavatory area flow path and placing CREVS in the emergency recirculation mode. This condition is allowed indefinitely.

TS ACTION 3.7.5.c is currently as indicated below:

ACTION:

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.

++If action per ACTIONS a.4, a.6, a.7, a.8, or a.9 is taken that permits indefinite operation and the system is placed in recirculation mode, then CORE AL TERA TIONS, movement of irradiated fuel in the spent fuel pool, and positive reactivity changes may resume.

Kitchen and Lavatory Exhaust Ventilation Dampers TS LCO(s) 3.7.5.h and 3.7.5.i, TS ACTION(s) 3.7.5.a.8 and 3.7.5 a.9, and TS SR 4.7.5.f, specify the current LCOs, ACTION(s) and SR associated with the CREVS kitchen and lavatory area exhaust isolation dampers. In the event a kitchen or lavatory area exhaust isolation damper becomes inoperable, ACTION(s) 3.7.5.a.8 and 3.7.5 a.9 require the immediate suspension of irradiated fuel movement. A footnote allows irradiated fuel movement to resume after isolating the associated kitchen or lavatory area flow path and placing CREVS in emergency recirculation mode, and this configuration is allowed indefinitely.

TS LCO(s) 3.7.5.h and 3.7.5.i, TS ACTION(s) 3.7.5.a.8 and 3.7.5 a.9, and TS SR 4.7.5.f are currently as indicated below:

LIMITING CONDITION FOR OPERATION 3.7.5 The Control Room Emergency Ventilation System shall be OPERABLE*

with:

h.

Two isolation dampers in the kitchen area exhaust duct, and

i.

Two isolation dampers in the toilet area exhaust duct.

ACTION:

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 7 of 20 ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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

- 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.

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

f.

In accordance with the Surveillance Frequency Control Program by verifying operability of the kitchen and toilet area exhaust dampers, and 2.3 Description of the Proposed Changes Immediate Suspension of Irradiated Fuel Movement for Inoperable CREVS Component(s)

TS ACTION(s) 3.7.5.a.1 through 3.7.5.a.4, 3.7.5.a.6 and 3.7.5.a.7 specify the required ACTION(s) for inoperable CREVS air handlers, condensing units, recirculation fans, and the normal outside air intake, recirculation and emergency outside air intake isolation dampers. Each requires the immediate suspension of irradiated fuel movement upon determination of inoperability. However, the immediate suspension of irradiated fuel movement is more conservative than the Westinghouse STS for an inoperable CREVS train. In addition, a seven-day allowable outage time (AOT) for two inoperable condensing units is more conservative than the thirty-day AOT provided in the Westinghouse STS for one of two inoperable Control Room Emergency Air Temperature Control System (CREATCS) trains. The CREVS contains three condensing units each of which is capable of fulfilling the specified cooling function. The proposed changes align the TS ACTION(s) with the STS by relocating the requirement to suspend irradiated fuel movement from the determination of inoperability to expiration of the AOT and by extending the AOT for two inoperable condensing units from seven to thirty days. The proposed changes render the Note indicated by the double-asterisk (**) unnecessary for TS ACTION(s) 3.7.5.a.4, 3.7.5.a.6 and 3.7.5.a.7, and is thereby deleted.

The proposed changes to TS ACTION(s) 3.7.5.a.1 through 3.7.5.a.4, 3.7.5.a.6 and 3.7.5.a.7 are as indicated below:

ACTION:

a.1 With one air handling unit inoperable, immediate!)' suspend al!

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 8 of20 moveme11t of 51'.:"'.ildfated luel a11d, within 7 days, restore the inoperable air handling unit to OPERABLE status or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.2 With two condensing units inoperable, fmmedfatel)* suspe11d all me1.1eme11t ef k1:adiated lue/ aRd, within Jo 30 days, restore at least one of the inoperable condensing units to OPERABLE status or, immediately suspend all movement of irradiated fuel and be in at least HOT ST AND BY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.3 With one recirculation fan inoperable, 5mmediatety suspend alt me1.1eme11t ef k1:adiated lue! md, within 7 days, restore the inoperable fan to OPERABLE status or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.4 With one recirculation damper inoperable, immed5ate!y suspe11d a!!

mo*,*eme11t ef imJdffated lue/ amt, 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 mod~ or, immediately suspend all movement of irradiated fuel and be in at least HOT ST AND BY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.6 Wtth an inoperable damper in the normal outside air intake, immediate!y suspe11d at.' movem911t of fnad!ated lue! a11d, 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 mod~ or, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.7 With an inoperable damper in the emergency outside air intake, ffmmedffate!)' suspend al! meveme11t of inadiated lue! 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, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 9 of20 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

. ;!;;!;,Jf aetioR 5s takeR sueh that imJe'fin!te epe."atioR is pe!'.mitted aRfi the system is plaeed in Ff3ei!'.eulatioR mode, theR mo*.1emeRf of i:"."adiated file! may.oresume.

Immediate Suspension of Irradiated Fuel Movement for Inoperable CREVS Filter Train TS ACTION 3.7.5.a.5 specifies the required ACTION for an inoperable filter train. The immediate suspension of irradiated fuel movement and the immediate action to initiate action to place the compensatory filtration unit in service are required. However, alternative mitigating actions are available which ensure that CRE occupant radiological and chemical exposures will not exceed allowable limits, though placing the compensatory filtration unit in service would remain the preferred mitigating action. In addition, the immediate suspension of irradiated fuel movement is more conservative than the Westinghouse STS for an inoperable CREVS train. The proposed change requires the immediate suspension of irradiated fuel movement for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during which the mitigating actions are verified to ensure CRE occupant radiological exposures will not exceed limits and following which irradiated fuel movement may resume. The proposed change also allows alternative mitigating actions, in the event the compensatory filtration unit is unavailable, by changing to a recommendation the requirement to place the compensatory filtration unit in service. With the exception of the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the proposed change aligns the TS ACTION with the STS by relocating the requirement to immediately suspend irradiated fuel movement from the determination of inoperability to expiration of the AOT.

The proposed change to ACTION TS 3.7.5.a.5 is as indicated below:

ACTION:

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, andr immediately7 initiate action to implement mitigating actions, [e.g., use of the compensatory filtration unit] is C'equ5.'r9rl te be ffmmerlffate!y ffRfftiatefi}, aRrl w. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits, following which* irradiated fuel movement may resume, and, within 7 days, restore the filter train to OPERABLE status.

With the above requirements not met, immediately suspend all movement of irradiated fuel, and, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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

Immediate Suspension of Irradiated Fuel Movement for an Inoperable CRE Boundarv TS ACTION 3.7.5.b specifies the required ACTION for an inoperable CRE boundary.

The immediate suspension of irradiated fuel movement and the immediate action to initiate mitigating actions are required. However, the immediate suspension of irradiated

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 10 of 20 fuel movement is more conservative than the Westinghouse STS for an inoperable CRE boundary. The proposed change requires the immediate suspension of irradiated fuel movement for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during which the mitigating actions are verified to ensure CRE occupant radiological and chemical exposures will not exceed applicable limits and CRE occupants are protected from smoke hazards, and following which irradiated fuel movement may resume. With the exception of the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the proposed change aligns the TS ACTION with the STS by relocating the requirement to immediately suspend irradiated fuel movement from the determination of inoperability to expiration of the AOT. For consistency with the STS, the proposed change deletes the reference to the spent fuel pool with regard to irradiated fuel movement.

The proposed change to ACTION TS 3. 7.5.b is as indicated below:

ACTION:

b.

With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary, immediately suspend all movement of irradiated fuel i11 the spSRt his/ pee!, and immediately initiate action to implement mitigating actions..aml=wWithin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits, and CRE occupants are protected from smoke hazards, following which movement of irradiated fuel may resume, and restore CRE boundary to OPERABLE status within 90 days, or:

1)

With the requirements not met, immediately suspend all movement of irradiated fuel, and, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

2)

If this ACTION applies to both units simultaneously, immediately suspend all movement of irradiated fuel, and, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Immediate Suspension of Irradiated Fuel Movement for Inoperable CREVS during Modes 5 and 6 TS ACTION 3.7.5.c specifies the required ACTION for CREVS inoperability in Modes 5 and 6. The immediate suspension of irradiated fuel movement, core alterations and positive reactivity changes are required. However, the immediate suspension of irradiated fuel movement, core alterations and positive reactivity changes is more conservative than the Westinghouse STS for an inoperable CREVS train in Modes 5 and

6. The proposed change aligns TS 3.7.5 with the STS by deleting TS ACTION 3.7.5.c in its entirety and expanding the applicability of TS ACTlON(s) 3.7.5.a through 3.7.5.a.7 and 3.7.5.b, to MODES 1, 2, 3, 4, 5, 6 or anytime during the movement of irradiated fuel (e.g.

during core offload operations). For consistency with the STS, the proposed change eliminates the requirement to suspend core alterations and positive reactivity changes during Modes 5 and 6. In addition, the proposed change renders the Note denoted by a double-cross(++) unnecessary and is thereby deleted.

The proposed changes to the TS 3.7.5 Applicability and ACTION TS 3.7.5.c are as indicated below:

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 LIMITING CONDITION FOR OPERATION L-2016-246 Enclosure Page 11 of 20 3.7.5 The Control Room Emergency Ventilation System shall be OPERABLE*

with:

APPLICABILITY:

,D.!J MODES MODES 1, 2, 3, 4, 5 and 6 or during movement of irradiated fuel assemblies ACTION:

MO/JES 1, 21 3 and 4:

11110/JSS fi and ti:

e.

With the Control Reem Jimergem;y Ventf.'atffen System ffnopemb.'e*+, JmmedJate/)' suspend a!! epe.iratfens !nvo!vffllg CORJiAJ..TliRl'.1'.JONS, mevement eflrradffatedfue!in the spoot f=uel peel, erpes!tive.'r.&aet5v5't)' eha11ges. Fh!s ACTtO.\\' shall app!)'

te beth un5ts s5mu!taneeusly.

+!faction perfl.CTJO.\\'S a.4, a.6; a.11 a.B, e.ra.9 !s taken that pe,:mfts 511dsfh1lte epemt!sn aRd the &)'Stem 5s plaeefl 511 ree!."'eu.'atfen mede, then COREl~.J..TERATtOJVS, me'>rement ef ffrradJated f=ue/ Jn the spent f=uel poet, and pesitlve.ireaeti*.rity Ghanges ma)' resume.

Control Room Kitchen and Lavatory Exhaust Ventilation Damper Requirements TS LCO(s) 3.7.5.h and 3.7.5.i, TS ACTION(s) 3.7.5.a.8 and 3.7.5 a.9, and TS SR 4.7.5.f, specify the current LCOs, ACTION(s) and SR associated with the CREVS kitchen and lavatory area exhaust isolation dampers. In 2012, the kitchen and lavatory area ventilation exhaust flow paths were permanently isolated with seismic Class 1 solid plates in order to enhance CRE boundary reliability. The CREVS has since been in TS ACTION(s) 3.7.5.a.8 and 3.7.5.a.9 for inoperable kitchen and lavatory area exhaust isolation dampers. The proposed change aligns the CREVS licensing basis with its current design by eliminating LCO(s) 3.7.5.h and 3.7.5.i, ACTION(s) 3.7.5.a.8 and 3.7.5 a.9, and SR 4.7.5.f. Consequently, the proposed change renumbers LCO 3.7.5.j and SR 4.7.5.g, modifies the reference to SR 4.7.5.g in the Note denoted by a triple-asterisk(-),

and modifies the triple asterisk (:...)to become a double asterisk (-).

The proposed changes to TS LCO(s) 3.7.5.h and 3.7.5.i, TS ACTION(s) 3.7.5.a.8 and 3.7.5 a.9, and TS SR 4.7.5.f, and the Note currently denoted by a triple-asterisk(-*) are as indicated below:

LIMITING CONDITION FOR OPERATION 3.7.5 The Control Room Emergency Ventilation System shall be OPERABLE*

with:

h.

Tt*10 Jso.'atJen dampers Jn the k-Jtehefl area exhaust duet, and u

Tv10 !se!-atJen r/-ampeFS Jn the tefflet area exhaust duct.

h.

Control Room Envelope.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 ACTION:

L-2016-246 Enclosure Page 12 of 20 a.S With a11 ise!atie11 damperi11eperable i11 the kitehe11 aFea eNhaust duet, jmmsd.=ate/y susp911d a.'! mo*.rems11t ef Jrrad!atsd fuel anr/1 v1ffthi11 7 da}'SJ ~ste:'l'6 the i11eper<abf.e damper te OPERAB!.E status er isolate the flew path** er be in at least HOT STANDBY within the RMt 6 hsurs a11d i11 COLD SHUTIJOW.V withff11 the te!le'IJ..V:lg 39 hours4.513889e-4 days 0.0108 hours 6.448413e-5 weeks 1.48395e-5 months . !f this ACT!ON app!ies te beth ooffts s5mu!ta11eeusly, be in HOT STANDBY withff11 12 hews aml 511 CO!.D SHU1DOW-'l wffth.w the tellewing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.9 With a11 iselatie11 damper!11eperable ff11 the teJleta."'9a Mhaust duet, immediately suspend a!J movement ef irradiated tue! ood, v1ffth!11 7 da}fSJ."'9ste~ the i11epe.-rable damper te OPERAS!.E status er isolate the flew path** er be in at !east HOT STANDBY within the 119Jft 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months aml !11 CO!.D SHU'f:IJOWN wffthff11 the tellew5Rg 30 hews. !f thJs A CFJOA' applies te beth u11ffts sfmu!taReeus/)', be 511 HOT STA,JDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months a11d.w COL.D SHU'f:IJOWN with5R the te!Jewing 30 heura SURVEILLANCE REQUIREMENTS 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:

f.

/11 aeeerda11ee with the Surv&5lla11ee J!reque11ey Centre/

Program by ver5ty5Rg eperabff!ffty et the kitehe11 and teJ/et atrea exhaust dampers, and

f.

By performing required CRE unfiltered air in-leakage testing in accordance with the Control Room Envelope Habitability Program.**.;!;

- '!;,As the mitigation actions of TS 3.7.5 Action a.5 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, d and fg.

3.0 TECHNICAL EVALUATION

3.1 Turkey Point Design vs. Westinghouse Standard Technical Specifications (STS)

The Westinghouse STS considers the CREVS to be operable when there are two CREVS trains operable. In contrast, the Turkey Point CREVS has one emergency recirculation filter train with redundant active components designed to satisfy the single failure criterion. The CREVS is considered operable when the CREVS emergency recirculation filter train components that are necessary to limit operator exposure are considered operable.

To compensate for the absence of a redundant recirculation filter train, a safety-related Control Room compensatory filtration unit is maintained that must be manually placed in service. The compensatory filtration unit is designed as a qualified backup in the event the CREVS emergency recirculation filter train cannot be operated. As such, the TS SRs

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 13 of 20 associated with the CREVS emergency recirculation filter train also apply to the compensatory filtration unit. The Turkey Point design is acceptable due to the redundancy established within the CREVS emergency recirculation filter train and the availability of the compensatory filtration unit as a fully-qualified backup.

Currently, the Turkey Point CREVS is considered operable when the following components are operable:

Three air handling units Two of 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 The CRE boundary is considered operable when the measured unfiltered air in-leakage is less than or equal to the in-leakage value assumed by the licensing basis analyses of design basis accident consequences to CRE occupants.

3.2 Immediate Suspension of Irradiated Fuel Movement The proposed change relocates the requirement to immediately suspend irradiated fuel movement in the event of an inoperable CREVS air handler, two condensing units, recirculation fan, CRE boundary, or a normal outside air intake, recirculation or emergency outside air intake isolation damper. Prior to adopting TSTF-448 (References 6.2, 6.3 and 6.4), TS 3. 7.5 specified that the CREVS shall be operable and required Uie immediate suspension of irradiated fuel movement should the CREVS become inoperable. However, the uniqueness of Turkey Point's Control Room and CREVS design is such that conforming to the Westinghouse STS with only one CREVS train warranted additional considerations. As part of the request to adopt TSTF-448, FPL proposed in FPL letter L-2010-083 (Reference 6.5), newly created LCOs, ACTION(s) and SRs for each emergency recirculation filter train component relied upon to fulfill the CREVS specified safety function. The newly formed ACTION(s) were reasonable based upon the low probability of occurrence of a design basis accident challenging Control Room Habitability during the period of inoperability and the capability of the redundant components to perform their specified safety functions. However, in keeping with the previous TS format for an inoperable CREVS, the requirement to immediately suspend irradiated fuel movement was conservatively applied to each newly formed TS ACTION.

In the case of an inoperable air handler or two condensing units, as addressed in TS ACTIONs 3.7.5.a.1 and 3.7.5.a.2, respectively, the CREVS does not provide for additional trains or components which assure CREVS' capability to perform its specified cooling function assuming a single failure. As such, the proposed changes are less restrictive since they eliminate the immediate suspension of irradiated fuel movement.

However Westinghouse STS 3. 7.1 O.A provides for a seven-day AOT without the suspension of irradiated fuel movement for an inoperable CREVS train. In contrast, TS ACTION 3. 7.5.a.1 imposes a seven-day AOT and the immediate suspension of irradiated fuel movement for an inoperable air handler. Similarly, STS 3.7.11, ACTION A provides for a thirty-day AOT without the suspension of irradiated fuel movement for an inoperable CREATCS train, whereas TS ACTION 3.7.5.a.2 imposes a seven-day AOT and the

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 14 of 20 suspension of irradiated fuel movement for two inoperable condensing units. (The CREVS contains three condensing units each of which is capable of fulfilling the specified cooling function). As such, relocating the requirement to immediately suspend irradiated fuel movement from the determination of inoperability to expiration of the AOT and extending the AOT for two inoperable condensing units from seven to thirty days maintains a commensurate level of safety when judged against the current regulatory standards established in the Westinghouse STS for an inoperable filter train and is thereby reasonable.

In the case of one inoperable recirculation fan, the seven-day AOT of TS ACTION 3.7.5.a.3 provides a commensurate level of safety as the seven-day AOT in Westinghouse STS ACTION 3. 7.1 O.A for one inoperable CREVS train. However, STS ACTION 3.7.10.A does not require the immediate suspension of irradiated fuel movement. As such, relocating the requirement to immediately suspend irradiated fuel movement from the determination of inoperability to expiration of the AOT maintains a commensurate level of safety when judged against the current regulatory standards established in the Westinghouse STS for an inoperable filter train and is thereby reasonable.

In the case of one inoperable recirculation damper or normal outside air intake damper, the seven-day AOT of TS ACTIONs 3.7.5.a.4 and 3.7.5.a.6, respectively, provides a commensurate level of safety as the seven-day AOT in Westinghouse STS ACTION 3.7.10.A for one inoperable CREVS train. However, STS ACTION 3.7.10.A does not require the immediate suspension of irradiated fuel movement. Furthermore, aligning the redundant normal outside air intake or recirculation damper in its fail-safe position and placing CREVS in emergency recirculation mode, as required in TS ACTION(s) 3.7.5.a.4 and 3. 7.5.a.6, fulfills the CREVS specified safety function indefinitely. As such, relocating the requirements to immediately suspend irradiated fuel movement from the determination of inoperability to expiration of the AOT maintains a commensurate, if not a greater level of safety when judged against the current regulatory standards established in the Westinghouse STS for an inoperable filter train and is thereby reasonable.

In the case of an inoperable filter train, the proposed change modifies TS ACTION 3.7.5.a.5 by changing to a recommendation the requirement to immediately place the compensatory filtration unit in service, thereby allowing for alternative mitigating actions.

In addition, the proposed change allows irradiated fuel movement to resume after verifying within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the mitigating actions ensure CRE occupant radiological exposures will not exceed allowable limits. The compensatory filtration unit is a fully-qualified backup to the emergency filtration unit and will remain the preferred mitigating action in the event of an inoperable CREVS filter train. However alternative mitigating actions may be necessary in the event the compensatory filtration unit cannot be manually aligned within the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allotted before the Unit(s) must commence shutdown. Station procedures would specify alternative process or engineering controls that manage the radioactivity in the air. However, consistent with 10 CFR 20.1701 and 10 CFR 20.1702, these alternative controls would not include the use of potassium-iodide (Kl) pills and self-contained breathing apparatus (SCBA) respirators except as a last resort in accordance with emergency operating procedures. Allowing irradiated fuel movement to resume following verification during the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that Control Room occupant exposure limits would not be contravened does not reduce safety because the qualified mitigating actions would be in place prior to the resumption of irradiated fuel movement. Furthermore, relocating the suspension of irradiated fuel movement to coincide with the expiration of the seven-day AOT is consistent with Westinghouse STS ACTION 3.7.1 O.A upon expiration of the AOT for an inoperable CREVS train. As such, changing the requirement to place the compensatory filtration unit in service to a

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 15 of 20 recommendation, allowing the resumption of fuel movement upon verification within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of effective mitigating actions and, with the exception of the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , relocating the requirement to suspend irradiated fuel movement from the determination of inoperability to expiration of the AOT maintains a commensurate, if not a greater level of safety when judged against the current regulatory standards established in the Westinghouse STS for an inoperable filter train and is thereby reasonable.

In the case of an inqperable emergency outside air intake damper, TS ACTION 3.7.5.a.7 does not require placing the Control Room in the emergency recirculation mode.

However, the seven-day AOT provides a commensurate level of safety as that currently established in Westinghouse STS ACTION 3.7.10.A for an inoperable CREVS train and STS ACTION 3.7.10.A does not require the immediate suspension of irradiated fuel movement. In addition, a redundant emergency outside air intake flowpath is available.

and placing it's associated o'utside air intake damper in the open position, as required in TS ACTION 3.7.5.a.7, assures the capability of the CREVS to fulfil its specified safety function if called upon. As such, relocating the requirement to immediately suspend irradiated fuel movement from the determination of inoperability to expiration of the AOT maintains a commensurate, if not a greater level of safety when judged against the current regulatory standards established in the Westinghouse STS for an inoperable filter train and is thereby reasonable.

In the case of an inoperable CRE boundary, the current TS ACTION 3.7.5.b does not require placing the Control Room in the emergency recirculation mode nor does the CREVS provide for a redundant component or train which assures CREVS specified functionality given a single failure. However Westinghouse STS ACTION 3.7.10.B provides for a ninety-day AOT without the suspension of irradiated fuel movement after first verifying within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that mitigating actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed allowable limits and CRE occupants are protected from smoke hazards. In contrast, TS ACTION 3.7.5.b requires the suspension of irradiated fuel movement for the duration of the 90-day AOT even after first verifying within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that mitigating actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed allowable limits and CRE occupants are protected from smoke hazards. FPL proposes for an inoperable CRE boundary for all plant MODES, the immediate suspension of fuel movement for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , during which mitigating actions would be verified to ensure CRE occupant exposures to radiological and chemical hazards will not exceed allowable limits and CRE occupants are protected from smoke hazards, and following which irradiated fuel movement may resume. Irradiated fuel movement would also be suspended if the 90-day AOT cannot be met. Though relaxing the requirement to suspend fuel movement for the duration of the 90-day AOT is less restrictive than the current Turkey Point TS, the proposed change maintains a commensurate level of safety when judged against the current regulatory standards established in the Westinghouse STS for an inoperable CRE boundary and is thereby reasonable.

In the case of an inoperable CREVS in MODES 5 and 6, the proposed change removes ACTION 3.7.5.c in its entirety and instead, imposes proposed ACTION(s) 3.7.5.a.1 through 3.7.5.a.7 on both Units regardless of plant MODE [see below for ACTION(s) 3.7.5.a.8 and 3.7.5.a.9]. Turkey Point Units 3 and 4 share the same Control Room and as a result, entry into current ACTION(s) 3.7.5.a.1 through 3.7.5.a.9 for the operating Unit render the CREVS inoperable for the shutdown Unit, thereby immediately invoking ACTION 3.7.5.c on the shutdown Unit. By removing ACTION 3.7.5.c and modifying the TS 3.7.5 APPLICABILTY to apply to MODE(s) 1, 2, 3, 4, 5, 6, or during the movement of irradiated fuel assemblies, the redundancy of tracking separate ACTION(s) based upon plant MODE for a shared Control Room CREVS is eliminated. Furthermore, TS ACTION

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 16 of 20 3.7.5.c requires the immediate suspension of irradiated fuel movement, core alterations and positive reactivity changes for an inoperable CREVS. However, in keeping with the format of the Westinghouse STS, the immediate suspension of core alterations and positive reactivity changes are not STS specified ACTION(s) and thereby should be removed from TS 3.7.5. Additionally, the immediate suspension of irradiated fuel movement is not required by the Westinghouse STS for an inoperable CREVS filter train or an inoperable CRE boundary unless the respective AOT(s) cannot be met. Hence relocating in TS ACTION(s) 3.7.5.a.1 through 3.7.5.a.7, the requirement to immediately suspend fuel movement from the determination of inoperability to expiration of the AOT, as discussed earlier, and expanding their applicability to all plant MODES during which irradiated fuel movement might occur, maintains a commensurate level of safety when judged against the current regulatory standards established in the Westinghouse STS for

,

an inoperable CREVS train in Modes 5 and 6 and is thereby reasonable.

The proposed changes for an inoperable CREVS air handler, two condensing units, a recirculation fan, a normal outside air intake, recirculation or emergency outside air intake isolation damper, a CREVS train or the CRE boundary conform to the requirements of 10 CFR 50.36 with regard to establishing LCOs for SSCs relied upon to mitigate design basis accidents and following remedial actions permitted by the Technical Specifications until the inoperable condition is remedied. As proposed, the TS ACTION(s) provide a commensurate level of safety when compared with the current regulatory standards established in the Westinghouse STS for a single operable CREVS train or an inoperable CRE boundary based on the low probability of occurrence of a design basis accident challenging the Control Room Habitability during the time period and the continued capability of the remaining *system components to perform the CREVS specified safety function. Moreover, for an inoperable normal outside air intake, recirculation or emergency air intake isolation damper, or CREVS filter train, or the CRE boundary, the Turkey Point TS require additional mitigating and/or compensatory actions beyond that currently required in the Westinghouse STS. These include placing applicable dampers in their fail-safe position(s) and placing the CREVS in emergency recirculation mode. In the changes proposed by FPL, the suspension of irradiated fuel movement would occur upon expiration of the AOT regardless of whether the CREVS is in emergency recirculation mode or the compensatory filtration unit is in service. As such, there is no reduction in safety in the proposal to relocate the requirement to immediately suspend fuel movement in the manner requested by this license amendment request.

3.3 Control Room Kitchen and Lavatory Ventilation Exhaust Dampers The proposed change removes TS LCO(s) 3.7.5.h and 3.7.5.i, TS ACTION(s) 3.7.5.a.8 and 3.7.5 a.9, and TS SR 4.7.5.f, all associated with the kitchen and lavatory area exhaust isolation dampers. The Turkey Point CREVS is currently in long term TS ACTION(s) 3.7.5.a.8 and TS 3.7.5.a. 9 following the installation of solid plates sealing off the kitchen and lavatory ventilation exhaust pathways and removing the fuses to the motor-operated ventilation exhaust dampers. Per the current footnote associated with TS 3.7.5.a.8 and TS 3.7.5.a.9, Turkey Point may stay in this configuration indefinitely.

However, the CREVS must be placed in the emergency recirculation mode whenever Turkey Point desires to move irradiated fuel. The solid plates were installed as seismic Class 1, coated in accordance with engineering specification SPEC-C-004, Protective Coatings for Areas Outside the Reactor Containment, and are forthwith considered part of the CRE boundary. The modification increased CRE boundary reliability by replacing two active components with two robust, passive barriers. The leak tightness of the solid plates is verified during periodic air in-leakage (e.g. tracer gas) testing performed in accordance with the current TS 4.7.5.g. As such, there is no reduction in safety by the

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 17 of 20 elimination of LCO(s) 3.7.5.h and 3.7.5.i, ACTION(s) 3.7.5.a.8 and 3.7.5 a.9, and SR 4.7.5.f, and the proposed change is thereby reasonable.

4.0 REGULATORY SAFETY ANALYSIS 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50, Appendix A, General Design Criteria (GDC) for Nuclear Power Plants, Criterion 19 - Control Room, states that a Control Room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. GDC Criterion 19 further states that adequate radiation protection shall be provided to permit access and occupancy of the Control Room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.

10 CFR 50.36(c)(2)(ii), Criterion 3, states that a LCO must be established for a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

10 CFR 50.36(d)(2)(i) states that LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. 10 CFR 50.36(d)(2)(i) further states that when a LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.

10 CFR 20.1701 states that the licensee shall use, to the extent practical, process or other engineering controls (e.g., containment, decontamination, or ventilation) to control the concentration of radioactive material in air.

10 CFR 20.1702(a) states that when it is not practical to apply process or other engineering controls to control the concentrations of radioactive material in the air to values below those that define an airborne radioactivity area, the licensee shall, consistent with maintaining the total effective dose equivalent ALARA, increase monitoring and limit intakes by one or more of the following means -

(1) Control of access; (2) Limitation of exposure times; (3) Use of respiratory protection equipment; or (4) Other controls.

FPL complies with each of the aforementioned rules as they relate to the Turkey Point CREVS.

4.2 No Significant Hazards Consideration The proposed change revises TS 3.7.5, Control Room Emergency Ventilation System (CREVS), by relocating the requirement to immediately suspend the movement of irradiated fuel from the determination of inoperability to the expiration of the allowable outage time (AOT) for an inoperable CREVS component or Control Room Envelope (CRE) boundary. In addition, the proposed change removes from the Technical Specifications the requirements associated with the Control Room kitchen and lavatory

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 18 of 20 area exhaust isolation dampers which are no longer functional following the permanent isolation of the ventilation exhaust pathways with passive barriers. As required by 10 CFR 50.91 (a), FPL has evaluated the proposed changes using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

(1)

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No Relocating the requirement to immediately suspend irradiated fuel movement from the determination of inoperability to the expiration of the AOT is consistent with the Westinghouse Standard Technical Specifications (STS) for an inoperable CREVS train and thereby establishes a commensurate level of safety.

This change does not impact the functioning of the fuel handling system and so does not significantly increase the probability of a fuel handling accident. The removal of the kitchen and lavatory area exhaust damper requirements aligns t!ie licensing basis with the current design and enhances the reliability of the CRE.

The CREVS is not an initiator of an accident. Hence, neither of the proposed changes increase the probability of an accident previously evaluated.

The proposed changes do not impair the CREVS' capability to provide a protected environment from which operators can control the Units for all postulated events in the presence of a single failure. For an inoperable CRE boundary in any plant MODE, the suspension of fuel movement for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , during which the effectiveness of the mitigating actions are verified, ensures no increase in the consequences of a fuel handling accident. The proposed change aligns the licensing bases for the kitchen and lavatory ventilation exhaust pathways with a more reliable physical barrier design.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2)

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No Relocating the requirement to immediately suspend irradiated fuel movement until expiration of the AOT is consistent with the Westinghouse STS and hence does not introduce a new type of accident than previously evaluated or change the methods governing normal plant operation. Aligning the Control Room kitchen and lavatory ventilation exhaust pathway licensing bases with their current design does not introduce new failure modes for existing equipment or result in any new limiting single failure modes. The proposed changes do not challenge the performance or integrity of any safety-related system.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 19 of 20 (3)

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed changes align the current CREVS TS ACTION(s) with the Westinghouse STS and the licensing bases for the Control Room kitchen and lavatory ventilation exhaust pathways with their current design. As such, the proposed changes do not involve changes to any safety analyses assumptions, safety limits, or limiting safety system settings nor do they adversely impact plant operating margins or the reliability of equipment credited in the safety analyses.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above analysis, FPL concludes that the proposed amendment does not involve a significant hazards consideration, under the standards set forth in 10 CFR 50.92, "Issuance of Amendment," and accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusion In conclusion, based on the considerations discussed above, (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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or changes an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22c(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 NUREG-1431, Revision 4.0, "Standard Technical Specifications - Westinghouse Plants' (Accession No. ML12100A222) 6.2 Technical Specification Task Force (TSTF) - 448, Revision 3, "Control Room Habitability" (Accession No. ML070330657) 6.3 J. Paige to M. Nazar, dated March 30, 2012, "Turkey Point Units 3 and 4 - Issuance of Amendments Regarding Control Room Habitability Technical Specification Task Force (TSTF)-448 (TAC Nos. ME4277 and ME4278)," (Accession No. ML12067A176).

I

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2016-246 Enclosure Page 20 of20 6.4 F. E. Saba to M. Nazar, dated November 5, 2012, "Turkey Point Units 3 and 4 -

"Issuance of Amendments Regarding Revision to Technical Specification 3.7.5 "Control Room Emergency Ventilation System" (TAC Nos. ME9211 and ME9212)," (Accession No. ML12291A730) 6.5 FPL letter L-2010-083, dated May 21, 2010, "Supplement to License Amendment Request (LAR) 196 and 3/24/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST)" (Accession No. ML101440050)

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION PAGES (MARKUP)

(4 pages follow)

L-2016-246

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,

i.

Twe iselatiGFl aa~!i)BFS iR tl::ie teilet area eJd;iawst awst.

fil-7......r.---

Control Room Envelope.

.--~~~~~~~~~~~~~~~~~~~~~~~~~~----,

APPLICABILITY:

All MOIJ5S Modes 1, 2, 3, 4, 5 and 6 or during movement of irradiated fuel assemblies ACTION :_

immediately suspend all movement of irradiated fuel and With one air handling unit inoperable, *

in 7 days, restore the inoperable air handling unit to OPERABLE status

, be in at least HOT STAN e next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to bot taneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

1 o condensing units inoperable,=+l* ~::ieEil+<*@l¥~~~j.aj~~emoo~~;;iQl~~~i=aP~

within + days, restore at least one of the inoperable condensing units to OPERABLE sta

, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 1vai-

.u_f this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in C DOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.3 With one recirculation fan inoperabl,

within 7 days, restore the inoperable fan to OPERABLE status

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

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

TURKEY POINT - UNITS 3 & 4 3/4 7-18 AMENDMENT NOS. ~ AND ~

PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued) a.4 immediately suspend all movement of irradiated fuel and With one recirculation damper inoperable, il"FlFFle1iately s1o1s~eFl1 all FFieveFFieFlt ef irFa1iate1 f1o1el aFl1, 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**

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

. Within With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable ecirculation fans, a

or two inoperable recirculation dampers, immediately suspend all movem nt of irradiated fue ~ a

~ immediately~ initiate action to implement mitigating actions, [e.g., us of the compensa filtration unit] *

, *

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , verify mitigating actio ensure CRE occupant radiological exposures will not exceed limits and, within 7 days, restore the filt ain to OPERABLE status.

~~~~~~~~~~~~~~~~~~~~~~~~

, following which movement of irradiated fuel may resume, With t bove requirements not m, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SH OWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.6 With an inoperable damper i e normal outside air intake, iFF1FF1e6liately st.1Sf3SF161 all FF1e¥eFF1eF1t ef irra1iate1 f1o1el aF11, within 7 days, tore the inoperable damper to OPERABLE status or, place and maintain at least one of the normal ou

e air intake isolation dampers in the closed position and place the system in recirculation mod~, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

"th an inoperable damper in the emergency outside air intake, immediately suspend all movement ffi-lfRIQ!ate{Jl-ruel-CmG, within 7 days, restore the inoperable damper to OPERABLE status or, place and ma1 in 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.a

'A'itR aF1 iselatieFI 1aFFi~er iFle~eraele iFI t!;ie l~itsReFI area ei1!;ia1o1st 11o1st, iFRFFie1iately s1o1s~eF11 all FFieveFFieFlt ef irra1iate1 f1o1el Ern1, witRiFI 7 lays, rnstern t!;ie iFle~eraele 1aFFi~er te OPl§RABb~ stat1o1s er iselate tRe flew f3atR** er l;Je iFI at least f.=IGT aTMJQQY witRiFI tRe Fle><t i Ret.1rs aF16l iFI CGbQ l9f.=llJTQGIJ'!~J witRiFI tRe fellewiF19 dQ Re1.1rs. If tRis ACTlmJ af3f3lies te l;JetR t.1F1its siFF11.1ltaF1ee1.1sly, l;Je iFI lelOT STMJDBY witRiFI 12 !;ie1o1rs aF11 iFI GObD Slasll.ITDOWM witRiFI t!;ie fellewiFI~ ;§Q !;ie1o1rs.

a.Q

'A'itR aF1 iselatieFI 1aFFi~er iFle~eraele iFI t!;ie teilet area 9l<Ra1o1st 11o1st, iFFiFFie1iately s1o1s~eFl1 all FF1e';eFF1eF1t ef irraetiateet f1.1el aF161, witRiFI 7 etays, restere tRe iFlef3eral;Jle 6laFFlf39F te GPeRA!ilbe stat1.1s er iselate t!;ie flew ~at!;i** er 9e iFI at least lelOT STA~JDBY wit!;iiri t!;ie Fl9llt ij !;ie1o1rs ari1 iFl GObD Si..tl.ITDO'A'M witRiFI t!;ie fellewiFI~ 3Q !;ie1o1rs. If t!;iis AGTIO~J a~~liss te 9et!;i lolFlits SiFFl1o1ltaFlse1o1sl;', 99

__........... iFl las!OT STAMDBY witRiFl 12 !;ie1o1rs aPJ1 iFl GObD Sj.,ILJTDO'A'M witRiFI t!;is fellewiFl~ 3Q !;ie1o1rs.

- If astieFl is takeFl st.iGR tt;;iat iFl1efiFlite ef3eratieFl is f39Fmitte1 aF11 t!;ie syster:;i;i is ~lase! iFl resirs1o1latieF1 FRe1e, tReFl mevemeFlt ef irra1iate1 f1o1el FFiay res1o1r:Re.

TURKEY POINT-UNITS 3 & 4 3/4 7-19 AMENDMENT NOS. ~ AND ~

PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued)

. Within

b.

With the Control Room Emergency Ventilation System inoperable du to an inoperable CRE boundary, immediately suspend all movement of irradiated fuel *

, and immediately initiate action to implement mitigating actions, er;il witi"liR 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits1 and CRE occupants are protected from smoke hazards, and restore CRE boundary to OPERABLE status within 90 days, or:

1)

2) following which movement of irradiated fuel may resume, With the requirements not me be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN withi he following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

If this ACTION applies both units simultaneousl be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD S UTDOWN within the folio ng 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

immediately suspend all movement of irradiated fuel and

s.

\\AJitl:i tl:is CeRtFel iateer:i::i ~r:i::l9F!J9Rs;* VeRtiletieR l!l;*stsr:i::i iR9f39Fe81e++, ir:i::ir;;iselietely SWSf39Rel ell 9~@reti@FIS iRv@l':'iR~ CORI!! AlT~RATIO~J\\i, r:i::l@'a'QF;l@Rt ef irreilieit@l ft.1@1 iR Orn Sfil@Flt ft.1@1 r;i@@I, @F r;i@sitive ree&tivity &RiiFl!!JSS. TR is ACTIQM SRiill er;ir;il;* t@ B@ll"l i.rnits SiFJiwlteR8Elt.1Sly.

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

a.

In accordance with the Surveillance Frequency Control Program by verifying that the control room

{'

air temperature is less than or equal to 120°F;

b.

In accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at I least 15 minutes**~ ;

c.

In accordance with the Surveillance Frequency Control Program or (1) after 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 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:

++ If e&ti0R r;ier ACTIQMS e.4, e.0, e.7, e. ~. er e.Q is tel(9FI tl"let r;ierFJiits ir;ilefir;iite er;ieretier;i er;il tl"le systsFJi is r;ile&el iFI re&irewleti@R Fl1@le, lR9FI CQR!i! AHl!!RUIO~IS, Fl19¥9Ffl9Flt @f irreliatel flsfel iFI tl"le Sfil9Rt ft.1el fil@Ell, aRl r;issitive rse&tivity &RiiR!!JSS Fflay rest.1Ffle.

- ~As the mitigation actions of TS 3.7.5 Action a.5 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, d and ~

TURKEY POINT - UNITS 3 & 4 3/4 7-20 AMENDMENT NOS. ~ AND ~

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS <Continued) d.1

1)

Verifying that the air cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of greater than or equal to 99.95% DOP and 99%

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 03803 - 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**~.

In accordance with the Surveillance Frequency Control Program 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 +/-10% **~ ;

d.2 In accordance with the Surveillance Frequency Control Program, test the supply fans (trains A and B) and measure CRE pressure relative to external areas adjacent to the CRE boundary. **~

I

e.

In accordance with the Surveillance Frequency Control Program by verifying that on a Containment Phase "A" Isolation test signal the system automatically switches into the recirculation mode of operation, l~ite;t;ier;i arH~ teilet area eict;iaeist 1ai:i:1i;iers, ar;i1 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 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, d and lf:S.

TURKEY POINT - UNITS 3 & 4 3/4 7-21 AMENDMENT NOS. ~

AND ~

1

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION PAGES (CLEAN COPY)

(4 pages follow)

L-2016-246

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.

Control Room Envelope.

APPLICABILITY:

Modes 1, 2, 3, 4, 5 and 6 or during movement of irradiated fuel assemblies ACTION:

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

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

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

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

TURKEY POINT - UNITS 3 & 4 3/4 7-18 AMENDMENTNOS.

AND

PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued) a.4 With one recirculation damper inoperable, 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, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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]. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits, following which movement of irradiated fuel may resume and, within 7 days, restore the filter train to OPERABLE status.

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

a.6 With an inoperable damper in the normal outside air intake, 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, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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

TURKEY POINT - UNITS 3 & 4 3/4 7-19 AMENDMENTNOS.

AND

PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued)

b.

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

1)

With the requirements not met, immediately suspend all movement of irradiated fuel and be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

2)

If this ACTION applies to both units simultaneously, immediately suspend all movement of irradiated fuel and be in HOT STANDBY within 12* hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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

a.

In accordance with the Surveillance Frequency Control Program by verifying that the control room air temperature is less than or equal to 120°F;

b.

In accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes**;

c.

In accordance with the Surveillance Frequency Control Program or (1) after 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months 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 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, d and f.

TURKEY POINT - UNITS 3 & 4 3/4 7-20 AMENDMENTNOS.

AND

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS <Continued)

1)

Verifying that the air cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of greater than or equal to 99.95% DOP and 99%

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 03803 - 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 In accordance with the Surveillance Frequency Control Program 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 +/-10% **;

d.2 In accordance with the Surveillance Frequency Control Program, test the supply fans (trains A and B) and measure CRE pressure relative to external areas adjacent to the CRE boundary.**

e.

In accordance with the Surveillance Frequency Control Program by verifying that on a Containment Phase "A" Isolation test signal the system automatically switches into the recirculation mode of operation,

f.

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 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, d and f.

TURKEY POINT - UNITS 3 & 4 3/4 7-21 AMENDMENTNOS.

AND

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 ATTACHMENT 3 L-2016-246 PROPOSED TECHNICAL SPECIFICATION BASES PAGES (MARKUP)

(1 O pages follow)

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163 of 209 3/4.7.4 (Continued)

For the verification of UHS average supply water temperature, an appropriate instrument uncertainty will be subtracted from the Acceptance Criteria to ensure the Technical Specification limit is NOT exceeded.

3/4.7.5 Control Room Emergency Ventilation System The OPERABILITY of the Control Room Emergency Ventilation System (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 envelope (CRE) 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 10 CFR Part 50.67.

CRE occupants are protected from chemical hazards in accordance with the limits of Regulatory Guide 1.78.

The Control Room Emergency Ventilation System (CREVS) is considered to be OPERABLE (Ref: JPN_PTN_SENP-92-017) when :

1)

Three Air Handling Units (AHUs) (three out of three) are

OPERABLE,

2)

Two Condensing (air conditioning (A/C)) Units (two out of three) are OPERABLE,

3)

Two Recirculation Fans are OPERABLE,

4)

Two Recirculation Dampers are OPERABLE,

5)

One Recirculation Filter unit is OPERABLE,

6)

Two Normal Outside Air Intake Dampers are OPERABLE,

7)

Two Emergency Outside Air Intake Dampers are OPERABLE'f.

~)

T*.ve iselatieR lam~ers (eRe meter e~eratel lam~er aRl IRS

~ravity 8aeklraft lam~er) iR Urn kiteRBR area exl;iawst lwet are OPER'\\E!U'.:, aRl

9)

Twe iselatieR lam~ers (eRe meter e~eratel lam~er aRl eRe

~ravity 8aeklraft lam~er) iR tt;ie teilet area BMRawst lwet are OP E!! R/\\~b~.

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164 of 209 3/4.7.5 (Continued)

The reason three AH Us are required is that in the event of a single failure, only two AH Us would be available to supply air to the suction of the recirculation filter and fan. This is the configuration tested to support Technical Specification operability for flow through the Emergency Charcoal Filter Unit. Taking one AHU out of service renders the system incapable of operating in accordance with the tested configuration assuming an accident and a single failure, i.e., only one air handling unit available instead of the two assumed in the analysis. Any one of the three condensing (A/C) units is capable of maintaining Control Room equipment within environmental limits for temperature and humidity.

Thus, one condensing unit can be taken out of service without impacting the ability of CREVS to accomplish its intended function under single failure conditions.

The LCO actions allow inoperability of the redundant active CREVS components (one AHU, two Condensing Units, one Recirculation Fan, one Recirculation Damper, one Normal Outside Air Intake Damper, and/or one Emergency Outside Air Intake Damper) for a period of up to 7 day consistent with the approach provided in the Westinghouse St Clard Technical Specifications and based on the low probability of ccurrence of a Design Basis Accident (OBA) challenging the Control (30 days tor Room Habitability during this time period and the continued capability of two inoperable the remaining operable system components to perform the required condensing CREVS safety function. In effect, this temporarily suspends the single

~un_it_s) ___ ~ failure criterion for the affected components while assuring the continued functionality of the syste The kitchen and toilet area exhaust ventilation ducts have been permanently blocked off with seismic Class 1 solid plates coated in accordance with SPEC-C-004. The kitchen and toilet area motor operated and gravity backdraft dampers are no longer credited for CREVS operability.

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165 of 209 3/4.7.5 (Continued)

Indefinite operation in the RECIRCULATION Mode is allowed since the CREVS safety function is being met.

When one damper in the ormal Outside Air Intake is inoperable, it can either be restored within days or one of the two in-series dampers CLOSED and CREVS ru in RECIRCULATION Mode. When one Recirculation Damper is i operable, it can either be restored r one of the two paralleled dampe OPENED and the CREVS run in RECIRCULATION Mode. With one or both Emergency Outsid Air Intake Dampers inoperable, they can either be restored without adversely impacting the NORMAL or EMERGEN Mode f operati (See TSA 03-03-025-024 for evaluation). The pla ampers in their "fail-safe" position in lieu of restoration is all as the dampers fail "as-is" in the event of loss of offsite power (exce for the emergency outside air intake dampers which go to their emergency OPEN position) and are in their EMERGENCY Mode position in the event of receipt of an emergency actuation signal.

The 7 day allowable outage time for an inoperable Normal Outside Air Intake damper, Recirculation damper or Emergency Outside Air Intake damper is consistent with the approach provided in the Westinghouse Standard Technical Specifications for a single operable CREVS train.

Indefinite operation is allowed with an opened Emergency Outside Air Intake Damper since the CREVS is capable of performing its safety function.

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166 of 209 3/4. 7.5 (Continued)

I following which movement of irradiated fuel may resume I I.. I When the filter train is inoperable for reasons other thar an inoperable CRE 1rrad1ated boundary, e.g., the filter is inoperable, and/or two recirc 1lation fans are

~ inoperable, and/or two recirculation dampers are inopen ble, all movement of fuel iR Urn £~eRt F1;Jel Peel is required to be immediate!* suspended and mitigating action~

(e.g., use of the Compensatory filtration Unit) is required to be immediately initiated., Erne, wWithin 24 h( urs, the mitigating actions are required to be verified to be in place to ensL e the Control Room occupant radiological exposures will NOT exceed limits',' and, within 7 days, the inoperable filter train is required to be restored to OPERABLE status.

Consistent with O-ADM-211 and NUREG-1431, "immediately" indicates that the required action should be pursued without delay and in a controlled manner~

(e.g., placing the compensatory filtration unit into service should be completed within approximately one hour). The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance is reasonable based on the low probability of a OBA occurring during this time period, and the use of mitigating actions, e. ~.. Ge~~eRsateF)' filtratieR 1;JRit.

The mitigating actions to be verified should include the proper operation of the compensatory filtration unit, the integrity of the CRE and its capacity to perform its design function, and the associated mitigating actions specified in the Emergency Plan, e.g., SCBA, Kl, etc., as applicable. The 7 day AOT is reasonable based on the determination that the mitigating actions, i.e., U~e Ge~~eRsateF)' f.iltratieR 1;JRit, will continue to provide for the capability of the system to perform the required CREVS safety function and ensure protection of Control Room occupants within analyzed limits. As with the active components, this has the effect of temporarily suspending the single failure criterion for the affected components while assuring the continued functionality of the system. The 7 day AOT is also a reasonable time to diagnose, plan, repair, and test most problems with the inoperable filter train.~

and is consistent with the approach provided in the Westinghouse Standard Technical Specifications for a single operable CREVS train.

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167 of 209 3/4.7.5 (Continued)

The compensatory filtration unit is designed as a manual, safety-related, Seismic Class I backup to the installed system with the same functional and operational capabilities as the installed filter train. In addition, the unit is surveillance tested in accordance with the same requirements as those imposed on the installed filter train per TS 4.7.5.b, c, and d except that the requirements of TS 4.0.1 - 4.0.4 do NOT apply to the compensatory unit as it is NOT included in CREVS LCO.

Regarding exposure of the filters to effluents that may have an adverse effect on the functional capability of the system, painting, fire, or chemical releases are considered "NOT communicating" with the HEPA filter or adsorber if the system is NOT in operation, the isolation dampers for the system are closed, and there is NO pressure differential across the filter housing. This provides reasonable assurance that air is NOT passing through the filters and adsorbers.

In addition, the CREVS includes the Emergency Outside Air Intakes, located beyond the southeast and northeast corners of the Auxiliary Building. The CREVS Emergency Outside Air Intakes are considered OPERABLE when: 1) both flow paths are available, 2) have balanced intake flow rates and 3) a flow path capable of drawing outside makeup air from only the analyzed intake locations. The Alternative Source Term radiological analyses assume both emergency outside air intake flow paths are available with parallel dampers ensuring outside makeup air can be drawn through both intake locations during a design basis accident and a single active failure. These analyses rely on a provision in Regulatory Guide 1.194 Section 3.3.2 that allows a reduction in the atmospheric dispersion factors (X/Qs) for dual intake arrangements with balanced flow rates to one half of the more limiting X/Q value provided the two intakes are NOT within the same wind direction window for each release I receptor location. Accordingly, any maintenance on the emergency outside intake dampers or associated duct work that would prevent the CREVS from accomplishing these functions would require entering action statement a.7. The provisions of LCO 3.0.6 apply to the surveillance testing required to demonstrate operability of the emergency intake flow paths.

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168 of 209 3/4.7.5 (Continued)

System components are NOT subject to rapid deterioration, having lifetimes of many years, even under continuous flow conditions. Visual inspection and operating tests provide assurance of system reliability and will ensure early detection of conditions which could cause the system to fail or operate improperly. The filters performance tests prove that filters have been properly installed, that NO deterioration or damage has occurred, and that all components and subsystems operate properly. The in-situ tests are performed in accordance with the methodology and intent of ANSI N510 (1975) and provide assurance that filter performance has NOT deteriorated below returned specification values due to aging, contamination, or other effects.

Charcoal samples are tested using ASTM 03803-1989 in accordance with Generic Letter 99-02. The test conditions (30°C and 95% relative humidity) are as specified in the Generic Letter. Table 1 of the ASTM standard provides the tolerances that must be met during the test for each test parameter. The specified methyl iodide penetration value is based on the assumptions used in the LOCA Analysis.

Units 3 and 4 share a common CRE. The CRE is the area within the confines of the CRE boundary that contains the spaces that Control Room occupants inhabit to control the units during normal and accident conditions. This area encompasses the Control Room, including the Control Room offices, rack area, kitchen, and lavatory, and mechanical equipment room located below the Control Room which contains the CREVS equipment. The CRE is protected during normal operation, natural events, and accident conditions. The CRE Boundary is the combination of walls, floor, roof, ducting, doors, penetrations, and equipment that physically form the CRE. The operability of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will NOT exceed the inleakage assumed in the radiological dose consequence analyses and that CRE occupants are protected from hazardous chemicals and smoke. The CRE and its boundary are defined in Control Room Envelope Habitability Program.

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PAGE:

169 of 209 3/4.7.5 (Continued)

The location of CREVS components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. CREVS provides airborne radiological protection for the CRE occupants, as demonstrated by radiological dose consequence analyses for the most limiting design basis accident presented in UFSAR Chapter 14. CREVS also provides protection from chemical hazards and smoke hazards.

CREVS pressurizes the CRE relative to external areas adjacent to the CRE boundary. The analysis of hazardous chemical releases for NUREG-0737 Item 111.D.3.4, "Control Room Habitability Requirement,"

and the subsequent reanalysis included in PC/M 06-004, "Addition of Unit 5 to the Turkey Point Site," for new chemical release hazards demonstrate that the toxicity limits of Regulatory Guide 1.78 are NOT exceeded in the CRE following a hazardous chemical release. Thus, neither automatic nor manual actuation of CREVS is required for an analyzed hazardous chemical release. Analysis of a smoke challenge demonstrates that it will NOT result in the inability of the CRE occupants to control the reactors either from the Control Room or alternate shutdown panels.

In order for the CREVS to be considered OPERABLE, the CRE Boundary must be maintained such that the CRE occupant radiological dose does NOT exceed that calculated in the OBA Radiological Dose Consequence Analyses and CRE occupants are protected from hazardous chemicals and smoke. Since the CREVS and CRE are common to both units, the ACTION requirements are applicable to both units simultaneously, and must be applied according to each unit's operational MODE.

The LCO is modified by a Note that allows the CRE boundary to be opened intermittently under administrative controls. This Note applies only 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, controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the Control Room operators. The dedicated individual should have a m.ethod to rapidly close the opening and restore the integrity of the CRE boundary when a need for CRE isolation is indicated.

REVISION NO.:

PROCEDURE TITLE:

PAGE:

17 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 170 of 209 PROCEDURE NO.:

O-ADM-536 TURKEY POINT PLANT Upon determination ATTACHMENT 2 Tecbnjca! Specification Bases (Page 153 of 192) immediately suspend the movement of irradiated fuel, and If the u 1ltered in leakage of potential! contaminated air past the CRE Bounda and into the CRE can result i CRE occupant radiological dose greater tha that calculated in the dose a lyses or in inadequate protection o CRE occupants from hazardo chemicals or smoke, the CRE bounda is inoperable. Actions must taken to restore an OPERABLE C Boundary within 90 days WM~~~~~=.'i!l;~~,...

~~~~~~ that the CRE boundary is inoperable +A=

MOb>ES 1, 2, ~. @r 4, the operators are required t immediately initiate action to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a OBA, the mitigating actions will ensure that CRE occupant radiological exposures will NOT exceed the calculated dose in the radiological dose consequence analyses, and that CRE occupants are protected from hazardous chemicals and smoke Previous surveys of offsite and onsite chemicals identified that 0 hazardous chemicals present a hazard to Control Room habita ility.

Thus, the mitigating action for chemical hazards may verify tha the chemical hazards analyses are current and require NO toxic g protection for the CRE occupants. These mitigating actions (i.., actions that are taken to offset the consequences of the inoperable CR boundary) should be preplanned for implementation upon ent into the condition, regardless of whether entry is intentional or unintenti nal. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowable outage time (AOT) is reasonable based on t e low probability of a OBA occurring during this time period and the u e of mitigating actions. The 90 day AOT is reasonable based on th determination that the mitigating actions will ensure protection f CRE occupants within analyzed limits while limiting the probability th t CRE occupants will have to implement protective measures that ma adversely affect their ability to control the reactors and maintai them in a safe shutdown condition in the event of a OBA. The 90 day A is a reasonable time to diagnose, plan and possibly repair, and tes most problems with the CRE boundary and is consistent with the approach provided in the Westinghouse Standard Technical Specifications for one or more inoperable CREVS trains due to an inoperable CRE boundary.

following which irradiated fuel movement may resume.

REVISION NO.:

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171 of 209 action must be taken immediately to suspend all operations that could result in a release of radioactivity that might require isolation of the CRE, such as movement of irradiated fuel, and

.R=f!i~~~~~=@F='F.==i, "f the inoperable CREVS or the CRE Boundary e restored to OPERABLE status within the associated required AOT, he unit must be placed in a MODE that minimizes the accident the risk. To achieve this status, the unit must be placed in at least MODE 3 next NOBY) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 (COLD SHUTDOWN) 30 wit a6 hours.

lies to both units simultaneously, be in MODE 3 ithin 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and in MOD

~

hours. The AOTs are reaso able, based on operating experience, to reach the required unit co ditions from full power conditions in an orderly manner and without cha lenging unit systems.

This does NOT preclude the movement of fuel to a safe position.

IR MOQE! 8 er 0, witt-1 tt-10 GREV~ iRei;ioraelo fer aR iRei;ioraelo GR!!

~HHHfary er for ett'1er roaseRs, aetirn m1;1st eo tal(OR immo1iatoly te s1;1s130R1 all ei;ioratieRs tt'1at 5e1;1l1 ros1;1lt iR a release ef ra1ieaetivity tt'1at mi~Rt ro!1;1ire iselatieR ef tt-10 GRE, s1;15t.;i as me¥emoRt ef irra1iato1 f1;1el.

Tt'1is i;ilaeos tt'1e 1;1Rit iR a eeR1itieR tt'1at miRimizos tt'1e aeei1oRt risl(. Tt'1is lees NOT 13ro5l1;110 tt'1e mevemeRt ef f1;1el tea safe 13esitieR. Tt'1ose

/\\GTIO~J ro!1;1irem0Rts ai;ii;ily te eett-1 1;1Rits sim1;1ltaF1oe1;1sly.

Operations that, in the absence of a compensation adjustment, add positive reactivity are acceptable when, combined with other concurrent actions that add negative reactivity, the overall net reactivity addition is zero or negative. For example, a positive reactivity addition caused by temperature increases or decreases is acceptable if it is concurrent with a negative reactivity addition (i.e., boration and/or rod movement, if authorized) such that the overall, net reactivity addition is zero or negative.

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TECHNICAL SPECIFICATION BASES CONTROL PROGRAM TURKEY POINT PLANT ATTACHMENT 2 Technjca! Specjficatjon Bases (Page 155 of 192) 3/4.7.5 (Continued)

~

Surveillance Requirement (SR) 4.7.5.g verifies the OPERABILITY of the CRE Boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. It verifies that the unfiltered air in leakage into the CRE is NO greater than the flow rate assumed in the dose analyses. When unfiltered air in leakage is greater than the assumed flow rate, ACTION b must be entered WRBR a ~Rit is iR MOfJES 1 4 Ernl ACTION l m~st alse 8e ei;iterel wReR a ~Rit is iR MOfJE 8 er~). ACTION b allows time to restore the CRE boundary to OPERABLE status provided mitigating actions are taken WRile iR MOfJES 1 4, that ensures that the CRE remains within the licensing basis habitability limits for the occupants following an accident. The details of the testing are specified in the Control Room Envelope Habitability Program.

172 of 209

v t e Letter Sequence Request
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L-2016-246, Regarding License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS)

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SUMMARY

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3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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3.0 TECHNICAL EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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L-2016-246, Regarding License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS)

Text

SUMMARY

System Description

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

System Description

3.0 TECHNICAL EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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