ML20055F060

Documentation of the Completion of Required Actions Taken in Response to the Lessons Learned from the Fukushima Dai-Ichi Accident

ML20055F060
Person / Time
Site:	Turkey Point
Issue date:	03/24/2020
From:	Robert Bernardo NRC/NRR/DORL/LPMB
To:	Moul D Florida Power & Light Co
Bernardo R
References
Download: ML20055F060 (29)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 24, 2020 Mr. Don Moul Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: NT3/JW 15430 Endeavor Drive Jupiter, FL 33478

SUBJECT:

TURKEY POINT UNITS 3 AND 4 - DOCUMENTATION OF THE COMPLETION OF REQUIRED ACTIONS TAKEN IN RESPONSE TO THE LESSONS LEARNED FROM THE FUKUSHIMA DAI-ICHI ACCIDENT

Dear Mr. Moul:

The purpose of this letter is to acknowledge and document that the actions required by the U.S. Nuclear Regulatory Commission (NRC) in orders issued following the accident at the Fukushima Dai-ichi Nuclear Power Station have been completed for Turkey Point, Units 3 and 4 (Turkey Point). In addition, this letter acknowledges and documents that Florida Power and Light Company (FPL, the licensee) has provided the information requested in the NRCs March 12, 2012, request for information under Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f), related to the lessons learned from that accident. Completing these actions and providing the requested information, in conjunction with the regulatory activities associated with the Mitigation of Beyond-Design-Basis Events (MBDBE) rulemaking, implements the safety enhancements mandated by the NRC based on the lessons learned from the accident. Relevant NRC, industry, and licensee documents are listed in the reference tables provided in the enclosure to this letter. The NRC will provide oversight of these safety enhancements through the Reactor Oversight Process (ROP).

BACKGROUND In response to the events in Japan resulting from the Great Thoku Earthquake and subsequent tsunami on March 11, 2011, the NRC took immediate action to confirm the safety of U.S.

nuclear power plants:

On March 18, 2011, the NRC issued Information Notice 2011-05, Thoku-Taiheiyou-Oki Earthquake Effects on Japanese Nuclear Power Plants (Reference 1.1). The information notice was issued to inform U.S. operating power reactor licensees and applicants of the effects from the earthquake and tsunami. Recipients were expected to review the information for applicability to their facilities and consider actions, as appropriate.

Suggestions contained in an information notice are not NRC requirements; therefore, no specific action or written response was required.

On March 23, 2011, the NRC issued Temporary Instruction (TI) 2515/183, Followup to the Fukushima Daiichi Fuel Damage Event. The purpose of TI 2515/183 was to provide NRC

inspectors with guidance on confirming the reliability of licensees strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following events that may exceed the design basis for a plant. The results of the inspection for each licensee were documented in an inspection report (Reference 1.2).

On March 23, 2011, the Commission provided staff requirements memorandum (SRM)

COMGBJ-11-0002, NRC Actions Following the Events in Japan. The tasking memorandum directed the Executive Director for Operations to establish a senior level agency task force, referred to as the Near-Term Task Force (NTTF), to conduct a methodical and systematic review of the NRC processes and regulations to determine whether the agency should make additional improvements to the regulatory system and make recommendations to the Commission within 90 days for its policy direction (Reference 1.3).

On April 29, 2011, the NRC issued TI 2515/184, Availability and Readiness Inspection of Severe Accident Management Guidelines (SAMGs). The purpose of TI 2515/184 was to inspect the readiness of nuclear power plant operators to implement SAMGs. The results of the inspection were summarized and provided to the NTTF, as well as documented in a 2011 quarterly integrated inspection report for each licensee (Reference 1.4).

On May 11, 2011, the NRC issued Bulletin (BL) 2011-01, Mitigating Strategies.

BL 2011-01 required licensees to provide a comprehensive verification of their compliance with the regulatory requirements of 10 CFR 50.54(hh)(2), as well as provide information associated with the licensees mitigation strategies under that section. In 10 CFR 50.54(hh)(2), it states, in part: Each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire. BL 2011-01 required a written response from each licensee (Reference 1.5). Note that the final MBDBE rule (Reference 1.15) moved the requirements formerly in 10 CFR 50.54(hh)(2) to 10 CFR 50.155(b)(2).

On July 21, 2011, the NRC staff provided the NTTF report, Recommendations for Enhancing Reactor Safety in the 21st Century: The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident to the Commission in SECY-11-0093, Near-Term Report and Recommendations for Agency Actions Following the Events in Japan (Reference 1.6).

On October 3, 2011, the staff prioritized the NTTF recommendations into three tiers in SECY-11-0137, Prioritization of Recommended Actions to Be Taken in Response to Fukushima Lessons Learned. The Commission approved the staffs prioritization, with comment, in the SRM to SECY-11-0137 (Reference 1.7).

A complete discussion of the prioritization of the recommendations from the NTTF report, additional issues that were addressed subsequent to the NTTF report, and the disposition of the issues that were prioritized as Tier 2 or Tier 3 is provided in SECY-17-0016, Status of Implementation of Lessons Learned from Japans March 11, 2011, Great Thoku Earthquake and Subsequent Tsunami (Reference 12.10). A listing of the previous Commission status reports, which were provided semiannually, can be found in Table 12 in the enclosure to this letter.

The NRC undertook the following regulatory activities to address the majority of the Tier 1 recommendations:

On March 12, 2012, the NRC issued Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, EA-12-050, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents, and EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, and a request for information under 10 CFR 50.54(f) (hereafter referred to as the 50.54(f) letter) to licensees (References 1.8, 1.9, 1.10, and 1.11, respectively).

On June 6, 2013, the NRC issued Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Reference 1.12), which superseded Order EA-12-050, replacing its requirements with modified requirements.

In addition to the three orders and the 50.54(f) letter, the NRC completed rulemaking, 10 CFR 50.155, Mitigation of Beyond-Design-Basis Events, that made generically applicable the requirements of Orders EA-12-049 and EA-12-051. The draft final rule and supporting documentation were provided to the Commission for approval in SECY-16-0142, Draft Final Rule - Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49) (Reference 1.13). The MBDBE rulemaking effort consolidated several of the recommendations from the NTTF report.

On January 24, 2019, the Commission, via SRM-M190124A (Reference 1.14), approved the final MBDBE rule, with edits. The final rule approved by the Commission contains provisions that make generically applicable the requirements imposed by Orders EA-12-049 and EA-12-051 and supporting requirements. The Commissions direction in the SRM makes it clear that the NRC will continue to follow a site-specific approach to resolve the interaction between the hazard reevaluation and mitigation strategies using information gathered in the 50.54(f) letter process. The NRC staff made conforming changes to the final rule package (Reference 1.15) as directed by the Commission, which included changes to two regulatory guides (References 1.16 and 1.17). The final rule was published in the Federal Register on August 9, 2019 (84 FR 39684), with an effective implementation date of September 9, 2019.

Subsequent to Commission approval of the final MBDBE rule, the staff engaged with stakeholders to pursue the expeditious closure of the remaining post-Fukushima 50.54(f) letter responses on a timeframe commensurate with each items safety significance.

In a draft discussion paper (Reference 1.18) used to support a Category 3 public meeting held on February 28, 2019 (Reference 1.19), the NRC staff outlined the process to be used to review the reevaluated hazard and mitigation strategies assessment (MSA) information provided by licensees considering the differences between the draft final MBDBE rule and the approved final MBDBE rule. Subsequently, the NRC staff provided a screening letter (also called a binning letter) for both seismic and flooding hazard reevaluations (References 5.22 and 6.26), which categorized sites based on available information and the status of any commitments made in prior reports and assessments. The process is discussed in greater detail in the Hazard Reevaluation and Mitigation Strategies Assessment sections of the discussion which follows.

This letter acknowledges and documents that the actions required by the NRC in response to the orders, as well as the information provided in response to the March 12, 2012, 50.54(f) letter, have been completed for Turkey Point. However, the staff is not determining whether the licensee complies with the final MBDBE rule. Oversight of compliance with the final MBDBE rule at Turkey Point will be conducted through the ROP.

DISCUSSION Mitigation Strategies Order Order EA-12-049, which applies to Turkey Point, requires licensees to implement a three-phase approach for mitigation of beyond-design-basis external events (BDBEEs). It requires licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a BDBEE that results in a simultaneous loss of all alternating current (ac) power and loss of normal access to the ultimate heat sink (LUHS). Phases 1 and 2 of the order use onsite equipment, while Phase 3 requires obtaining sufficient offsite resources to sustain those functions indefinitely.

In August 2012, the Nuclear Energy Institute (NEI) issued Revision 0 of industry guidance document NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, as guidance to comply with the order. The NRC endorsed the guidance in Revision 0 of Japan Lessons-Learned Project Directorate (JLD) interim staff guidance (ISG) document JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

Subsequently, in December 2015, NEI issued Revision 2 of NEI 12-06 and the NRC endorsed that guidance in Revision 1 of JLD-ISG-2012-01 (Reference 2.1). Licensees were required to provide an overall integrated plan (OIP) to describe how they would comply with the order, along with status reports every 6 months until compliance was achieved (Reference 2.2). The NRC staff provided an interim staff evaluation (ISE) related to the OIP (Reference 2.3). The NRC concluded in the ISE that the licensee provided sufficient information to determine that there is reasonable assurance that the plan, when properly implemented, including satisfactory resolution of the open and confirmatory items, would meet the requirements of Order EA-12-049 at Turkey Point. The NRC staff also conducted a regulatory audit of the licensees strategies and issued a report which documented the results of the audit activities (Reference 2.4). Upon reaching compliance with the order requirements, the licensee submitted a compliance letter and a final integrated plan (FIP) to the NRC (Reference 2.5). The FIP describes how the licensee is complying with the order at Turkey Point.

The NRC staff completed a safety evaluation (SE) of the licensees FIP (Reference 2.6). The SE informed the licensee that its integrated plan, if implemented as described, provided a reasonable path for compliance with Order EA-12-049 at Turkey Point. The staff then evaluated the implementation of the plans through inspection, using TI 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communications/Staffing/Multi-Unit Dose Assessment Plans. An inspection report was issued to document the results of the TI 2515/191 inspection (Reference 2.7). The NRC will oversee implementation of the mitigation strategies requirements under the final MBDBE rule requirements through the ROP.

Phase 3 of Order EA-12-049 required licensees to obtain sufficient offsite resources to sustain the required functions indefinitely. There are two redundant National Strategic Alliance for

FLEX Emergency Response (SAFER) Response Centers (NSRCs), one located in Memphis, Tennessee, and the other in Phoenix, Arizona, which have the procedures and plans in place to maintain and deliver the equipment needed for Phase 3 from either NSRC to any participating U.S. nuclear power plant when requested (Reference 2.8). The NRC staff evaluated and inspected the NSRCs and the SAFER program, plans, and procedures (References 2.9 and 2.10). Subsequently, SAFER provided two addenda to document the treatment of equipment withdrawn from the NSRCs (Reference 2.11). The NRC reviewed the addenda and documented its conclusion in an updated staff assessment (Reference 2.12). The NRC concluded that licensees may reference the SAFER program and implement their SAFER response plans to meet the Phase 3 requirements of the order. The licensees FIP (Reference 2.5) includes the plans for utilizing the NSRC equipment at Turkey Point. In its SE (Reference 2.6), the NRC staff concluded that the licensee has developed guidance that, if implemented appropriately, should allow utilization of offsite resources following a BDBEE consistent with NEI 12-06 guidance and should adequately address the requirements of the order.

Spent Fuel Pool Instrumentation Order Order EA-12-051, which applies to Turkey Point, required licensees to install reliable SFP level instrumentation with a primary channel and a backup channel, independent of each other, and with the capability to be powered independent of the plants power distribution systems. The NEI issued NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, as guidance to be used by licensees to comply with the order. The NRC endorsed this guidance in JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (Reference 3.1). Licensees were required to provide an OIP to describe how they would comply with the order, along with status reports every 6 months until compliance was achieved (Reference 3.2). The NRC issued an ISE, providing feedback on the OIP (Reference 3.3). The NRC staff conducted a regulatory audit of the licensees strategies and issued a report that documented the results of the audit activities (Reference 3.4). Upon reaching compliance with the order requirements, the licensee submitted a compliance letter to the NRC (Reference 3.5), describing how the licensee complied with the order at Turkey Point.

The NRC staff completed an SE of the actions taken by the licensee in response to the order (Reference 3.6). The SE informed the licensee that its integrated plan, if implemented as described, provided a reasonable path for compliance with Order EA-12-051 at Turkey Point.

The staff then evaluated the implementation of the plan through inspection, using TI 2515/191.

An inspection report was issued to document the results of the TI 2515/191 inspection (Reference 3.7). The NRC will oversee implementation of the SFP instrumentation requirements under the final MBDBE rule requirements through the ROP.

Reliable Hardened Containment Vent Order Order EA-13-109 (Reference 1.12) is only applicable to operating boiling-water reactors (BWRs) with Mark I and Mark II containments. Because the reactors at Turkey Point are pressurized water reactors with large, dry, ambient-pressure containments, this order is not applicable to Turkey Point.

Request for Information Under 10 CFR 50.54(f)

The 50.54(f) letter requested operating power reactor licensees to:

reevaluate the seismic and flooding hazard at their sites using present-day NRC requirements and guidance, and identify actions that are planned to address plant-specific vulnerabilities associated with the reevaluated seismic and flooding hazard; perform seismic and flooding walkdowns to verify compliance with the current licensing basis; verify the adequacy of current strategies and maintenance plans; and identify degraded, nonconforming, or unanalyzed conditions related to seismic and flooding protection; and provide an assessment of their current emergency communications and staffing capabilities to determine if any enhancements are needed to respond to a large-scale natural emergency event that results in an extended loss of ac power to all reactors at the site, and/or impeded access to the site.

In COMSECY-14-0037, Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluat[i]on of Flooding Hazards (Reference 6.13), the NRC staff described issues related to the implementation of Order EA-12-049 and the related MBDBE rulemaking, and the completion of flooding reevaluations and assessments. In the SRM to COMSECY-14-0037 (Reference 6.14), the Commission directed the NRC staff to provide a plan for achieving closure of the flooding hazard assessments to the Commission for review and approval. The NRC staff provided this plan in COMSECY-15-0019, Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants (Reference 6.16), which the Commission approved in the SRM to COMSECY-15-0019 (Reference 6.17).

Hazard Reevaluations (Enclosures 1 and 2 of the 50.54(f) letter)

Each licensee followed a similar two-phase process to respond to the hazard reevaluations requested by the 50.54(f) letter. In Phase 1, licensees submitted hazard reevaluation reports using NRC-endorsed, industry-developed guidance. The guidance specified that a licensee should determine if interim protection measures were needed while a longer-term evaluation of the impacts of the hazard was completed. The NRC staff reviewed the reevaluated hazard information. Using the reevaluated hazard information and a graded approach, the NRC identified the need for, and prioritization and scope of, plant-specific assessments. For those plants that were required to perform a flooding integrated assessment or a seismic probabilistic risk assessment (SPRA), Phase 2 decisionmaking (as described in a letter dated September 21, 2016 (Reference 5.17)), would determine whether additional plant-specific regulatory actions were necessary. In addition, as discussed in COMSECY-15-0019, most licensees performed an MSA to demonstrate that the licensee had adequately addressed the reevaluated hazards within their mitigation strategies developed for BDBEEs.

In a draft discussion paper (Reference 1.18) used to support a Category 3 public meeting held on February 28, 2019 (Reference 1.19), the NRC staff outlined the process to be used to review the reevaluated hazard and MSA information provided by licensees considering the differences between the draft final MBDBE rule and the approved final MBDBE rule. The purpose of these reviews is to ensure that the conclusions in the various staff assessments continue to support a determination that no further regulatory actions are needed.

As stated in the discussion paper, the NRC subsequently issued a seismic screening letter (Reference 5.22) and a flooding screening letter (Reference 6.25), also called binning letters, to all operating power reactor licensees. The purpose of the binning letters is to categorize sites based on available information and the status of any commitments made in prior reports and assessments. Turkey Point was binned as a Category 1 site for both seismic and flooding.

Category 1 includes sites where no additional information or regulatory action is required. This category includes sites, such as Turkey Point, where the licensee has demonstrated that existing seismic capacity or effective flood protection will address the unbounded reevaluated hazards.

Seismic Hazard Reevaluation (Enclosure 1 of the 50.54(f) letter) of the 50.54(f) letter requested each operating power reactor licensee to complete a reevaluation of the seismic hazard that could affect their sites using updated seismic hazard information and present-day regulatory guidance and methodologies to develop a ground motion response spectrum (GMRS). The licensee was asked to compare their results to the safe-shutdown earthquake (SSE) ground motion and then report to the NRC in a seismic hazard screening report. To provide a uniform and acceptable industry response, the Electric Power Research Institute (EPRI) developed a technical report, EPRI 1025287, Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic, and the NRC endorsed the guidance in a letter dated February 15, 2013 (Reference 5.1). From November 2012 to May 2014, the NRC and the industry provided guidance for the performance of the reevaluated hazard reviews (References 5.2-5.7). The licensee provided a seismic hazard screening report for Turkey Point (Reference 5.8).

If the new GMRS was not bound by the current design basis (CDB) SSE, Enclosure 1 of the 50.54(f) letter requested more detailed evaluations of the impact from the hazard. Also, the licensee was asked to evaluate whether interim protection measures were needed while the more detailed evaluation was completed. By letter dated May 7, 2013, the NRC endorsed industry-developed guidance, a proposed path forward, and schedules, which were provided in a letter from NEI dated April 9, 2013. Attachment 1 of the NEI letter contains EPRI report 300200704, Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic, to provide the guidance needed to perform an evaluation of any needed interim protective measures (Reference 5.3). This expedited seismic evaluation process (ESEP) is a screening, evaluation, and equipment modification process performed by licensees to provide additional seismic margin and expedite plant safety enhancements for certain core cooling and containment components while the more detailed and comprehensive plant seismic risk evaluations are being performed. Turkey Point was not required to perform an ESEP since the SSE bounds the reevaluated GMRS in the 1 to 100 Hertz (Hz) region as noted in References 5.10 and 5.11.

By letter dated May 9, 2014 (Reference 5.10), the NRC informed licensees of the initial screening and prioritization results based on a review of the licensees seismic hazard screening reports. The NRC updated the screening and prioritization in a letter dated October 3, 2014 (Reference 5.11). The NRC provided the final determination of required seismic evaluations in a letter dated October 27, 2015 (Reference 5.18). These evaluations could consist of an SPRA (Reference 5.1, SPID, Section 6.1.1), limited scope evaluations (High Frequency (Reference 5.14) and/or SFP evaluations (Reference 5.15)), or a relay chatter evaluation (Reference 5.4). If an SPRA was required, then additional Phase 2 regulatory decisionmaking was required (References 5.16 and 5.17).

The NRC staff completed and documented its review of the licensees reevaluated seismic hazard in a staff assessment (Reference 5.9). Turkey Point was screened out from the need for any further assessments because the SSE bounds the reevaluated GMRS in the 1 to 100 Hz region.

Because the staffs reviews were completed prior to when the final MBDBE rule was approved, the NRC staff, using the process discussed in the seismic binning letter (Reference 5.22),

re-visited these conclusions considering the final approved MBDBE rule. The staff confirmed that the conclusions in the various staff assessments continue to support a determination that no further regulatory actions are required for Turkey Point.

The NRC staff reviewed the information provided and, as documented in the staff assessment (Reference 5.9), concluded that the licensee provided sufficient information in response to of the 50.54(f) letter. The staff acknowledges that all seismic hazard reevaluation activities requested by Enclosure 1 of the 50.54(f) letter have been completed for Turkey Point.

No further information related to the reevaluated seismic hazard is required.

Flooding Hazard Reevaluation (Enclosure 2 of the 50.54(f) letter) of the 50.54(f) letter requested each operating power reactor licensee to complete a reevaluation of applicable flood-causing mechanisms at their site using updated flooding hazard information and present-day regulatory guidance and methodologies. Licensees were asked to compare their results to the CDB for protection and mitigation from external flood events. The NRC developed guidance to conduct the reevaluations (References 6.1 through 6.6). The licensee submitted a flood hazard reevaluation report (FHRR) for Turkey Point (Reference 6.7) to the NRC as requested by the 50.54(f) letter. Interim actions needed to protect against the reevaluated flood hazard were specified in the FHRR. The NRC inspected the interim actions using TI 2515/190, Inspection of Licensee's Proposed Interim Actions as a Result of the Near-Term Task Force Recommendation 2.1 Flooding Evaluation and documented the results in a quarterly integrated inspection report (Reference 6.9). A regulatory audit to support the review of the FHRR was not required. The NRC staff documented the technical bases for its conclusions from the review of the FHRR by issuing a staff assessment (Reference 6.11).

In COMSECY-14-0037 (Reference 6.13), the NRC staff requested Commission direction to more clearly define the relationship between Order EA-12-049, the related MBDBE rulemaking, and the flood hazard reevaluations and assessments. Because the NRC was reevaluating its approach to the flooding evaluations, the NRC provided an extension of the due dates for any integrated assessments in a letter dated November 21, 2014 (Reference 6.12). In the SRM to COMSECY-14-0037 (Reference 6.14), the Commission directed the NRC staff to provide a plan for achieving closure of the flooding portion of NTTF Recommendation 2.1 to the Commission for its review and approval. On May 26, 2015, the NRC deferred, until further notice, the date for submitting the integrated assessment reports (Reference 6.15). On June 30, 2015, the NRC staff provided a plan to the Commission in COMSECY-15-0019 (Reference 6.16). On July 28, 2015, the Commission approved the plan in the SRM to COMSECY-15-0019 (Reference 6.17). On September 29, 2015, the NRC issued a letter to licensees to describe the graded approach to the flood hazard reevaluations approved by the Commission (Reference 6.18).

The COMSECY-15-0019 action plan required the NRC staff to develop a graded approach to identify the need for, and prioritization and scope of, plant-specific integrated assessments and evaluation of plant-specific regulatory actions. The NRC staffs graded approach enabled a site

with hazard exceedance above its CDB to demonstrate the sites ability to cope with the reevaluated hazard through appropriate protection or mitigation measures which are timely, effective, and reasonable. Integrated assessments were focused on sites with the greatest potential for additional safety enhancements. New guidance for performing the integrated assessments and focused evaluations was developed for this graded approach. The guidance also provided schedule information for submission of any required integrated assessment. On July 18, 2016, the staff issued JLD-ISG-2016-01, Guidance for Activities Related to Near-Term Task Force Recommendation 2.1, Flooding Hazard Reevaluation, Focused Evaluation and Integrated Assessment (Reference 6.19). The ISG provided the guidance for Phase 1 flooding assessments, as described in COMSECY-15-0019, and endorsed industry guidance provided in NEI 16-05, External Flooding Integrated Assessment Guidelines (Reference 6.19). If an integrated assessment was necessary, then Phase 2 regulatory decisionmaking was required (References 6.23 and 6.24).

The NRC staff reviewed the FHRR considering the above direction from the Commission and provided a supplement to the FHRR staff assessment (Reference 6.10). The supplement updates the original staff assessment to address changes in the NRC's approach to the steps following the review of the flood hazard reevaluations as directed by the Commission. The letter also addresses the next steps associated with the mitigation strategies assessment with respect to the reevaluated flood hazards. The information in the staff assessment supplement was used by the licensee to complete the flood hazard MSA and other flood hazard evaluations.

As noted in the staff assessment supplement letter (Reference 6.10), the local intense precipitation (LIP), seiche, tsunami, storm surge, and combined events flood-causing mechanisms at Turkey Point were not bound by the CDB. Therefore, additional assessments of these flood-causing mechanisms were required. The NRC staff used a graded approach to determine if this site would need to perform an integrated assessment for the reevaluated flooding hazard, or if a focused evaluation would suffice. Based on the graded approach, Turkey Point completed a focused evaluation (Reference 6.20) to ensure appropriate actions were identified and taken to protect the plant from the reevaluated flood hazard. The NRC staff conducted a regulatory audit (Reference 6.22), completed its review of the focused evaluation (Reference 6.20), and concluded in the staff assessment (Reference 6.21) that the licensee provided sufficient information in response to the 50.54(f) letter. Audit results were summarized in the staff assessment. No further regulatory actions are required related to the flood hazard reevaluations.

Because the staffs reviews were completed prior to when the final MBDBE rule was approved, the NRC staff, using the process discussed in the flooding binning letter (Reference 6.25),

re-visited these conclusions considering the final approved MBDBE rule. The staff confirmed that the conclusions in the various staff assessments continue to support a determination that no further regulatory requirements are required for Turkey Point.

The NRC staff reviewed the information provided by the licensee and has concluded that sufficient information was provided to be responsive to Enclosure 2 of the 50.54(f) letter. The staff acknowledges that all flooding hazard reevaluation activities requested by Enclosure 2 of the 50.54(f) letter have been completed for Turkey Point. No further information related to the reevaluated flood hazard is required.

Mitigating Strategies Assessment In addition to the closure plan for NTTF Recommendation 2.1, the action plan approved by the Commission in the SRM to COMSECY-15-0019 (Reference 7.4) identified the staff efforts to ensure licensees would address the reevaluated hazard information in their mitigation strategies. Proposed requirements related to the MSA were included in the draft final MBDBE rule but were removed as a requirement from the final approved rule language. The Commissions direction in SRM-M190124A (Reference 1.14) makes clear that the NRC will continue to follow a site-specific approach to resolve the interactions between the hazard reevaluation and mitigation strategies using information gathered in the 50.54(f) letter process.

In a draft discussion paper (Reference 1.18) used to support a Category 3 public meeting held on February 28, 2019 (Reference 1.19), the NRC staff outlined the process to be used to review the reevaluated hazard and MSA information provided by licensees considering the differences between the draft final MBDBE rule and the approved final MBDBE rule. Subsequently, the NRC staff provided a screening letter (also called a binning letter) for both seismic and flooding information (References 5.22 and 6.25), which categorized sites based on available information and the status of any commitments made in prior reports and assessments. The majority of MSAs had been submitted and evaluated by the staff prior to the issuance of the binning letters. For the MSA reviews that had not yet been completed, or MSAs that had not yet been submitted, the staff would evaluate the hazard impacts on the mitigation strategies, as appropriate, as part of its review of SPRA reports, flooding FEs, and/or flooding integrated assessments.

The objective of the MSA is to determine whether the mitigation strategies developed for Order EA-12-049 can still be implemented given the reevaluated hazard levels. If it was determined that the mitigation strategies could not be implemented for the reevaluated hazard levels, the MSA could provide other options such as performing additional evaluations, modifying existing mitigating strategies, or developing alternate mitigating strategies or targeted hazard mitigating strategies to address the reevaluated hazard levels. In Revision 1 to JLD-ISG-2012-01, the NRC endorsed industry-developed guidance contained in Appendices G and H of Revision 2 to NEI 12-06 (Reference 7.5) for completing the MSAs. In Revision 2 to JLD-ISG-2012-01, the NRC endorsed the industry-developed guidance of NEI 12-06, Revision 4 (Reference 7.5).

The licensee completed both a flood hazard MSA (Reference 7.6) and a seismic hazard MSA (Reference 7.8) for Turkey Point. A regulatory audit was not required for either MSA. The NRC staff reviewed the MSA submittals and issued staff assessments (References 7.7 and 7.9) documenting its review. The NRC staff concluded that the licensee has demonstrated that the mitigation strategies appropriately address the reevaluated hazard conditions. As discussed in the seismic and flooding binning letters (References 5.22 and 6.26), the staff re-visited this conclusion considering the final approved MBDBE rule. The staff confirmed that the conclusions in the MSA staff assessments continue to support a determination that no further regulatory actions are required.

Walkdowns (Enclosures 3 and 4 of the 50.54(f) letter)

Enclosures 3 and 4 of the 50.54(f) letter requested that licensees perform plant walkdowns to verify compliance with the current licensing basis as it pertains to seismic and flood protection.

By letter dated May 31, 2012 (Reference 8.2), the NRC endorsed industry-developed guidance contained in Technical Report EPRI 1025286, Seismic Walkdown Guidance (Reference 8.1),

for the performance of the seismic walkdowns. By letter dated May 31, 2012 (Reference 9.2),

the NRC endorsed industry-developed guidance contained in NEI 12-07, Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features (Reference 9.1), for performance of the flooding walkdowns. The licensee provided a report for both the seismic and flooding walkdowns at Turkey Point (References 8.3 and 9.3). The NRC performed onsite inspections per TI 2515/188, Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns, and TI 2515/187, Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns, and documented the inspection results in a quarterly integrated inspection report (References 8.4 and 9.4). The NRC staff issued staff assessments for both the seismic and flooding walkdowns (References 8.6 and 9.5). Because there were inaccessible items identified during the initial licensee seismic walkdowns, the licensee submitted a subsequent seismic walkdown report after accessing the areas (Reference 8.5). The NRC documented its review of the subsequent walkdown reports in the staff assessment (Reference 8.6).

The NRC staff reviewed the information provided by the licensee and determined that sufficient information was provided to be responsive to Enclosures 3 and 4 of the 50.54(f) letter. The staff acknowledges that all seismic and flooding walkdown activities requested by the 50.54(f) letter have been completed for Turkey Point.

Communications and Staffing (Enclosure 5 of the 50.54(f) letter) of the 50.54(f) letter requested licensees to assess their means to power equipment needed to communicate onsite and offsite during a prolonged station blackout event and to identify and implement enhancements to ensure that communications can be maintained during such an event. Also, licensees were requested to assess the staffing required to fill all necessary positions to respond to a multiunit event with impeded access to the site, or to an extended loss of all ac power for single unit sites. Licensees were requested to submit a written response to the information requests within 90 days, or provide a response within 60 days and describe an alternative course of action and estimated completion dates. The licensee proposed an alternative course of action and schedule for Turkey Point (Reference 10.2), which included a 90-day partial response (Reference 10.3). The NRC acknowledged the schedule changes in a letter dated July 26, 2012 (Reference 10.4).

By letter dated May 15, 2012, the NRC endorsed industry-developed guidance contained in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities (Reference 10.1), for the performance of the communications and staffing assessments. The licensee provided the communications assessment and implementation schedule for Turkey Point (Reference 10.5), and the NRC completed a staff assessment of the licensees communications assessment (Reference 10.6).

Licensees responded to the staffing portion of the 50.54(f) letter in two phases to account for the implementation of mitigation strategies. Phase 1 staffing assessments were based on the existing station blackout coping strategies with an assumption of all reactors at the site being affected concurrently. The Phase 1 staffing assessment is required for multiunit sites and was completed for Turkey Point (Reference 10.7). In Phase 2, all licensees assessed the staffing necessary to carry out the mitigation strategies (Reference 10.9). The NRC staff issued staffing assessment response letters (References 10.8 and 10.10) for each submittal. The NRC performed an onsite inspection using TI 2515/191 to verify that the emergency communications and staffing plans at Turkey Point have been implemented as described by the licensee (Reference 10.11).

Proposed Regulatory Guide 1.228 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16218A236) was expected to endorse, with clarifications, NEI 12-01, NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond-Design-Basis Events and Severe Accidents (Reference 11.16), and NEI 14-01, Emergency Response Procedures and Guidelines for Beyond-Design-Basis Events and Severe Accidents (Reference 11.7). However, the final MBDBE rules language was revised to remove these requirements from the rule. The NRC staff canceled proposed Regulatory Guide 1.228 to reflect the approved changes in the final rule. The NRC will oversee the licensees implementation of communications and staffing plans which support the mitigation strategies requirements through the ROP.

The NRC staff reviewed the information provided by the licensee and determined that sufficient information was provided to be responsive to Enclosure 5 of the 50.54(f) letter. The staff acknowledges that all emergency preparedness communications and staffing activities requested by Enclosure 5 of the 50.54(f) letter have been completed for Turkey Point. No further information related to the communications and staffing assessments is required.

Additional Industry Commitments Update and Maintain Severe Accident Management Guidelines The NRC staff provided the proposed MBDBE rule to the Commission on April 30, 2015, in SECY-15-0065, Proposed Rulemaking: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49) (Reference 11.1) and the Commission issued the SRM to SECY-15-0065 on August 27, 2015 (Reference 11.2). The Commission approved publication of the proposed rule subject to removal of the proposed requirements pertaining to the SAMGs. The Commission also directed the staff to update the ROP to explicitly provide periodic oversight of industrys implementation of the SAMGs. By letter dated October 26, 2015 (Reference 11.3), NEI described the industry initiative, approved by the Nuclear Strategic Issues Advisory Committee as mandatory for all NEI members, to update and maintain the SAMGs. Specifically, each licensee will perform timely updates of their site-specific SAMGs based on revisions to generic severe accident technical guidelines. Licensees will also ensure that SAMGs are considered within plant configuration management processes. As noted in the NEI letter, the licensee provided a letter (Reference 11.4) to establish a site-specific regulatory commitment for Turkey Point.

In a letter to NEI dated February 23, 2016 (Reference 11.5), the staff outlined its approach for making changes to the ROP in accordance with the Commission direction. The staff engaged NEI and other stakeholders to identify the near-term and long-term changes to the ROP, consistent with the Commission direction and the licensees near-term and long-term SAMG commitments. In November 2016, the staff revised Inspection Procedure 71111.18, Plant Modifications (Reference 11.6, effective January 1, 2017), to provide oversight of the initial inclusion of SAMGs within the plant configuration management processes to ensure that the SAMGs reflect changes to the facility over time. In November 2018, the staff published a revision to IP 71111.18 (Reference 11.6, effective January 1, 2019), to provide oversight of the site-specific incorporation of generic owners groups SAMG guidance revisions.

Multiunit/Multisource Dose Assessments In COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (Reference 11.13), the NRC staff requested

Commission approval to implement the NTTF recommendation concerning multiunit/multisource dose assessments by having licensees document their commitment to obtain multiunit/multisource dose assessment capability by the end of 2014, rather than by issuing an order. Multiunit dose assessment capabilities would be made generically applicable through subsequent rulemaking. The Commission approved the staffs requests in the SRM to COMSECY-13-0010, dated April 30, 2013 (Reference 11.14). The licensee commitments are documented in References 11.8 through 11.11.

The NRC staff included the multiunit/multisource dose assessment requirement in the proposed MBDBE rulemaking (Reference 11.1). However, in response to a public comment concerning the 10 CFR 50.109 backfitting justification for the proposed multiple source term dose assessment requirements, the NRC staff determined that this requirement did not meet the criteria for imposition under 10 CFR 50.109(a)(4)(ii). The NRC staff also concluded that this could not be justified as a compliance backfit or as a substantial safety improvement whose costs, both direct and indirect, would be justified considering the potential safety gain.

Therefore, these requirements were removed from the draft final rule (Reference 1.13).

The licensee provided the requested information and stated that Turkey Point will have multiunit/multisource dose assessment capabilities (Reference 11.11) by December 31, 2014.

The NRC acknowledged the licensees submittal (Reference 11.12), verified the implementation of these dose assessment capabilities through inspection per TI 2515/191, and issued an inspection report (Reference 11.15).

CONCLUSION The NRC staff concludes that Florida Power and Light Company, the licensee, has implemented the NRC-mandated safety enhancements resulting from the lessons learned from the Fukushima Dai-ichi accident through its implementation of Orders EA-12-049 and EA-12-051 at Turkey Point. The staff further concludes that the licensee has completed its response to the 50.54(f) letter for Turkey Point. No further regulatory decisionmaking is required for Turkey Point related to the Fukushima lessons-learned.

A listing of the applicable correspondence related to the Fukushima lessons-learned activities for Turkey Point is included as an enclosure to this letter.

If you have any questions, please contact me at 301-415-2621 or by e-mail at Robert.Bernardo@nrc.gov.

Sincerely,

/RA/

Robert J. Bernardo, Project Manager Integrated Program Management and BDB Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosure:

Documents Related to Required

Response

cc w/encl: Distribution via Listserv

Turkey Point Units 3 and 4 Enclosure Reference Documents Related to Required Response to the Lessons Learned from the Fukushima Dai-ichi Accident TABLE 1 Initial Actions in Response to the Events in Japan Caused by the Great Thoku Earthquake and Subsequent Tsunami Ref Document Date ADAMS1 Accession No.

1.1 NRC Information Notice 2011-05 March 18, 2011 ML110760432 1.2 NRC Follow-up to the Fukushima Dai-ichi Fuel Damage Event Temporary Instruction (TI) 2515/183 March 23, 2011 ML11077A007 NRC TI 2515/183 Inspection Report 2011-010 May 13, 2011 ML111330163 Summary of Observations - TI-183 November 28, 2011 ML11325A020 1.3 NRC Tasking Memorandum, Staff Requirements Memorandum (SRM) to COMGBJ-11-0002 March 23, 2011 ML110820875 1.4 NRC Availability and Readiness Inspection of SAMG NRC Availability and Readiness Inspection of SAMG - TI 2515/184 April 29, 2011 ML11115A053 NRC Integrated Inspection Report 2011-003 (TI 2515/184 inspection results)

July 27, 2011 ML112082835 NRC TI 2515/184 Inspection Results, Region 2 Summary June 2, 2011 ML111530328 NRC Summary of TI 2515/184 Results June 6, 2011 ML11154A109 1.5 NRC Bulletin 2011-01, Mitigating Strategies NRC Bulletin 2011-01 May 11, 2011 ML111250360 Licensee 30 day response to BL 2011-01 June 10, 2011 ML11172A191 Licensee 60 day response to BL 2011-01 July 8, 2011 ML11203A015 NRC Request for Additional Information (RAI) regarding Licensee 60 day response to BL 2011-01 December 5, 2011 ML11334A001 Licensee response to RAI January 4, 2012 ML12018A240 NRC Closeout of BL 2011-01 for Turkey Point Units 3 and 4 July 12, 2012 ML12188A576 1.6 NRC NTTF Report (SECY-11-0093)

July 12, 2011 ML11186A950 1.7 NRC SECY-11-0137, Prioritization of Recommended Actions to Be Taken in Response to Fukushima Lessons Learned NRC SECY-11-0137 October 3, 2011 ML11272A111 SRM-SECY-11-0137 December 15, 2011 ML113490055 1.8 NRC Order EA-12-049 March 12, 2012 ML12054A735 1.9 NRC Order EA-12-050 March 12, 2012 ML12054A694 1.10 NRC Order EA-12-051 March 12, 2012 ML12054A679 1.11 NRC Request for Information Under 10 CFR 50.54(f) (the 50.54(f) letter)

March 12, 2012 ML12053A340 1 Agencywide Documents Access and Management System (ADAMS)

Turkey Point Units 3 and 4 TABLE 1 Initial Actions in Response to the Events in Japan Caused by the Great Thoku Earthquake and Subsequent Tsunami Ref Document Date ADAMS1 Accession No.

1.12 NRC Order EA-13-109 June 6, 2013 ML13143A321 1.13 NRC SECY-16-0142, Draft Final Rule:

Mitigation of Beyond-Design-Basis Events December 15, 2016 ML16301A005 1.14 SRM-M190124A: Affirmation Session-SECY-16-0142: Final Rule: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49) -

Package January 24, 2019 ML19023A038 1.15 Final Rule: Mitigation of Beyond-Design-Basis Events (Package)

August 9, 2019 ML19058A006 1.16 Regulatory Guide 1.226, Revision 0, Flexible Mitigation Strategies for Beyond-Design-Basis Events June 30, 2019 ML19058A012 1.17 Regulatory Guide 1.227, Revision 0, Wide Range Spent Fuel Pool Level Instrumentation June 30, 2019 ML19058A013 1.18 NRC Staff Preliminary Process for Treatment of Reevaluated Seismic and Flooding Hazard Information in Backfit Determinations February 14, 2019 ML19037A443 1.19 Category 3 Public Meeting to Discuss Staff's Preliminary Process for Treatment of Reevaluated Seismic and Flooding Hazard Information in Backfit Determinations February 14, 2019 ML19052A511

Turkey Point Units 3 and 4 TABLE 2 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events - EA-12-049 Ref Document Date ADAMS Accession No.

2.1 Guidance for Compliance with EA-12-049 -

Diverse and Flexible Coping Strategies (FLEX)

Industry Guidance on Diverse and Flexible Coping Strategies (FLEX) NEI 12-06, Revision 0 August 21, 2012 ML12242A378 NRC endorsement of NEI 12-06, Revision 0 - JLD-ISG-2012-01, Revision 0 August 29, 2012 ML12229A174 Industry Guidance on Diverse and Flexible Coping Strategies (FLEX) NEI 12-06, Revision 2 December 2015 ML16005A625 NRC endorsement of NEI 12-06, Revision 2 - JLD-ISG-2012-01, Revision 1 January 22, 2016 ML15357A163 2.2 Licensee Overall Integrated Plan (OIP)

Licensee OIP submittal February 26, 2013 ML13072A038 OIP 1st six month status report August 21, 2013 ML13248A311 OIP 2nd six month status report February 26, 2014 ML14073A454 OIP 3rd six month status report August 27, 2014 ML14253A162 OIP 4th six month status report February 26, 2015 ML15076A195 OIP 5th six month status report August 11, 2015 ML15233A417 OIP 6th six month status report February 23, 2016 ML16109A160 2.3 NRC Interim Staff Evaluation of OIP February 6, 2014 ML14002A160 2.4 NRC audit of EA-12-049 OIP NRC Notification of Audit of EA-12-049 August 28, 2013 ML13234A503 NRC Site Specific Audit Plan July 8, 2015 ML15188A507 NRC Audit Report November 12, 2015 ML15307A314 2.5 Licensee Compliance Letter for EA-12-049 and Final Integrated Plan (FIP)

June 20, 2016 ML16181A189 2.6 NRC Safety Evaluation of Implementation of EA-12-049 October 28, 2016 ML16279A455 2.7 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Emergency Preparedness Information NRC TI 2515/191 December 23, 2015 ML15257A188 NRC TI 2515/191 Inspection Report 2018-011 March 30, 2018 ML18089A127 2.8 Industry White Paper - National SAFER Response Centers (NSRC)

September 11, 2014 ML14259A221 2.9 NRC Staff Assessment of NSRCs September 26, 2014 ML14265A107

Turkey Point Units 3 and 4 TABLE 2 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events - EA-12-049 Ref Document Date ADAMS Accession No.

2.10 NRC Inspection of Implementation of EA-12-049 Regarding the use of NSRC NRC Inspection Procedure (IP) 43006 September 30, 2016 ML16273A318 NRC Vendor Inspection of the Phoenix NSRC Report No. 99901013/2016-201 January 12, 2017 ML17012A186 NRC Vendor Inspection of the Memphis NSRC Report No. 99901013/2017-201 May 5, 2017 ML17117A576 2.11 Addenda I and II to industry NSRC white paper May 24, 2018 ML18150A658 2.12 NRC Updated Staff Assessment of NSRCs September 20, 2018 ML18157A014 NA NRC approval of relaxation request of the schedule requirements for Unit 3 concerning Order EA-12-049 March 13, 2015 ML15013A498

Turkey Point Units 3 and 4 TABLE 3 Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation -

EA-12-051 Ref Document Date ADAMS Accession No.

3.1 Guidance for Compliance with EA-12-051 -

Spent Fuel Pool Instrumentation (SFPI)

Industry Guidance for Compliance with EA-12-051 - NEI 12-02, Revision 1 August 2012 ML12240A307 NRC endorsement of NEI 12-02, Revision 1 - JLD-ISG-2012-03, Revision 0 August 29, 2012 ML12221A339 3.2 Licensee Overall Integrated Plan (OIP)

Licensee OIP February 26, 2013 ML130720690 OIP 1st six month status report August 21, 2013 ML13248A313 OIP 2nd six month status report February 26, 2014 ML14073A066 OIP 3rd six month status report August 15, 2014 ML14245A057 OIP 4th six month status report February 13, 2015 ML15075A023 OIP 5th six month status report August 11, 2015 ML15233A418 3.3 NRC Interim Staff Evaluation of OIP November 19, 2013 ML13280A177 3.4 NRC Audit of EA-12-051 NRC Notification of Audit of EA-12-051 March 26, 2014 ML14083A620 NRC Audit Report of Westinghouse SFPI design specifications August 18, 2014 ML14211A346 NRC Site Specific Audit Plan July 8, 2015 ML15188A507 NRC Audit Report November 12, 2015 ML15307A314 3.5 Licensee Compliance Letter for EA-12-051 January 6, 2016 ML16028A143 3.6 NRC Safety Evaluation of Implementation of EA-12-051 October 28, 2016 ML16279A455 3.7 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Emergency Preparedness Information NRC TI 2515/191 December 23, 2015 ML15257A188 NRC TI 2515/191 Inspection Report 2018-011 March 30, 2018 ML18089A127 Note: Table 4 relates to the Hardened Containment Vent System and is not applicable to Turkey Point.

Turkey Point Units 3 and 4 TABLE 5 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 1: Recommendation 2.1 Seismic Hazard Reevaluation Ref Document Date ADAMS Accession No.

Guidance Documents 5.1 Screening, Prioritization and Implementation Details (SPID)

Industry Guidance (SPID) -

EPRI 1025287 November 2012 ML12333A170 NRC letter endorsing SPID February 15, 2013 ML12319A074 5.2 NRC guidance for performing a Seismic Margin Assessment (SMA) -

JLD-ISG-2012-04 November 16, 2012 ML12286A029 5.3 Expedited Seismic Evaluation Process (ESEP)

Industry Letter - Proposed path forward for NTTF Recommendation 2.1: Seismic April 9, 2013 ML13101A345 Industry Guidance - Expedited Seismic Evaluation Process (ESEP) - EPRI 3002000704 April 2013 ML13102A142 NRC letter endorsing the ESEP approach.

Extension of ESEP due date to 3/31/14 for Central and Eastern U.S. (CEUS) sites May 7, 2013 ML13106A331 5.4 Industry letter on relay chatter review October 3, 2013 ML13281A308 5.5 NRC letter with guidance on the content of seismic reevaluation submittals (includes operability and reportability discussions)

February 20, 2014 ML14030A046 5.6 Industry letter on seismic risk evaluations for CEUS plants March 12, 2014 ML14083A596 5.7 NRC background paper - Probabilistic seismic hazard analysis May 20, 2014 ML14140A648 Seismic Hazard Screening Report 5.8 Licensee Seismic Hazard Screening Report March 27, 2014 ML14106A032 5.9 NRC Staff Assessment of Reevaluated Seismic Hazard Information January 22, 2016 ML16013A472 Screening and Prioritization Results 5.10 NRC Letter - Seismic screening and prioritization results for CEUS plants May 9, 2014 ML14111A147 5.11 NRC Letter - Updated seismic screening and prioritization results October 3, 2014 ML14258A043 5.12 NRC letter regarding development of Seismic Risk Evaluations - suitability of updated seismic hazard information for further assessments December 10, 2014 ML14307B707 5.13 ESEP Submittal and Evaluation Licensee ESEP Submittal Not Required Not Required NRC Response Letter for the ESEP Submittal Not Required Not Required

Turkey Point Units 3 and 4 TABLE 5 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 1: Recommendation 2.1 Seismic Hazard Reevaluation Ref Document Date ADAMS Accession No.

Additional Guidance Documents 5.14 High Frequency Program Application Guidance Industry High Frequency Application Guidance - EPRI 3002004396 July 30, 2015 ML15223A095 NRC letter endorsing High Frequency Application Guidance September 17, 2015 ML15218A569 5.15 Spent Fuel Pool Evaluation Guidance Industry SFP evaluation guidance -

EPRI 3002007148 February 23, 2016 ML16055A017 NRC letter endorsing SFP evaluation guidance March 17, 2016 ML15350A158 5.16 NRC Letter - Treatment of Seismic and Flooding Hazard Reevaluations in the Design and Licensing Basis September 29, 2015 ML15127A401 5.17 NRC Guidance for Regulatory Decisionmaking of reevaluated flooding and seismic hazards September 21, 2016 ML16237A103 Final Determinations of Required Seismic Evaluations 5.18 NRC Final Determination of Required Seismic Evaluations October 27, 2015 ML15194A015 5.19 Licensee Required Seismic Evaluation Submittals Not Required Not Required 5.20 Audit plan of seismic evaluations submittals July 6, 2017 ML17177A446 5.21 NRC Staff Assessment of Seismic Evaluations Not Required Not Required 5.22 NRC Treatment of Reevaluated Seismic Hazard Information (seismic binning letter)

July 3, 2019 ML19140A307

Turkey Point Units 3 and 4 TABLE 6 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 2: Recommendation 2.1 Flooding Hazard Reevaluation Ref Document Date ADAMS Accession No.

Initial Guidance Documents 6.1 NRC prioritization of plants for completing flood hazard reevaluations May 11, 2012 ML12097A509 6.2 NRC-issued guidance for performing an integrated assessment for external flooding (JLD-ISG-2012-05)

November 30, 2012 ML12311A214 6.3 NRC letter to industry describing when an integrated assessment is expected December 3, 2012 ML12326A912 6.4 NRC-issued guidance for performing a tsunami, surge, or seiche hazard assessment (JLD-ISG-2012-06)

January 4, 2013 ML12314A412 6.5 NRC letter to industry with guidance on the content of flooding reevaluation submittals March 1, 2013 ML13044A561 6.6 NRC-issued guidance for assessing flooding hazards due to dam failure (JLD-ISG-2013-01)

July 29, 2013 ML13151A153 Flood Hazard Reevaluation Report 6.7 Licensee FHRR and supplements FHRR March 11, 2013 ML130950216 FHRR supplemental information January 31, 2014 ML14055A365 FHRR supplemental information February 26, 2014 ML14073A065 FHRR supplemental information April 25, 2014 ML14149A479 FHRR supplemental information August 7, 2014 ML14234A085 6.8 FHRR Regulatory Audit No audit No audit 6.9 NRC Inspection of licensee interim actions (if applicable)

NRC TI 2515/190, Revision 0, Inspection of proposed interim actions as a result of FHRR August 30, 2013 ML13217A436 NRC TI 2515/190 inspection report 2013-005 January 31, 2014 ML14031A306 6.10 NRC Interim Staff Response to Reevaluated Flood Hazards (supplement to FHRR SA)

November 4, 2015 ML15301A200 6.11 NRC Staff Assessment of FHRR December 4, 2014 ML14324A816 Modified Approach to Flood Hazard Reevaluations 6.12 NRC extension of due dates for Integrated Assessment reports November 21, 2014 ML14303A465 6.13 NRC COMSECY-14-0037, Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluation of Flooding Hazards November 21, 2014 ML14309A256 6.14 NRC SRM for COMSECY-14-0037 March 30, 2015 ML15089A236 6.15 NRC letter on second extension of due date for flooding integrated assessment reports May 26, 2015 ML15112A051 6.16 NRC COMSECY-15-0019 Closure Plan for the Reevaluation of Flooding Hazards June 30, 2015 ML15153A104

Turkey Point Units 3 and 4 TABLE 6 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 2: Recommendation 2.1 Flooding Hazard Reevaluation Ref Document Date ADAMS Accession No.

6.17 NRC SRM-COMSECY-15-0019 July 28, 2015 ML15209A682 6.18 NRC letter describing the graded approach to flood hazard reevaluation directed by SRM-COMSECY-14-0037 September 1, 2015 ML15174A257 6.19 Flooding Assessment Guidance NEI 16-05, External Flooding Assessment Guidelines June 2016 ML16165A178 NRC endorsement of NEI 16 JLD-ISG-2016-01 July 11, 2016 ML16162A301 6.20 Licensee Focused Evaluation June 29, 2017 ML17212B180 6.21 NRC Staff Assessment of Focused Evaluation July 3, 2018 ML18158A548 6.22 NRC Generic FE and IA Regulatory Audit Plan July 18, 2017 ML17192A452 6.23 NRC Letter - Treatment of Seismic and Flooding Hazard Reevaluations in the Design and Licensing Basis September 29, 2015 ML15127A401 6.24 NRC Guidance for Regulatory Decisionmaking of reevaluated flooding and seismic hazards September 21, 2016 ML16237A103 6.25 NRC Treatment of Reevaluated Flooding Hazard Information (flooding binning letter)

August 20, 2019 ML19067A247

Turkey Point Units 3 and 4 TABLE 7 Mitigating Strategies Assessments (MSA)

Ref Document Date ADAMS Accession No.

7.1 NRC COMSECY-14-0037, Integration of Mitigating Strategies with Hazard Reevaluations November 21, 2014 ML14309A256 7.2 NRC SRM-COMSECY-14-0037 March 30, 2015 ML15089A236 7.3 NRC COMSECY-15-0019, Closure Plan for Flooding Hazard Reevaluations June 30, 2015 ML15153A104 7.4 NRC SRM-COMSECY-15-0019 July 28, 2015 ML15209A682 7.5 Process for Mitigating Strategies Assessments (MSA)

Industry Guidance for performing MSAs -

NEI 12-06, Revision 2, including Appendices E, G, & H December 2015 ML16005A625 NRC endorsement of NEI 12-06, Revision 2 - JLD-ISG-2012-01, Revision 1 January 22, 2016 ML15357A163 Industry Guidance on Diverse and Flexible Coping Strategies (FLEX) NEI 12-06, Revision 4 December 12, 2016 ML16354B416 NRC endorsement of NEI 12-06, Revision 4 - JLD-ISG-2012-01, Revision 2 February 8, 2017 ML17005A182 7.6 Licensees MSA submittal - Flooding December 20, 2016 ML17012A065 7.7 NRC Staff Assessment of MSA - Flooding June 27, 2017 ML17143A034 7.8 Licensees MSA submittal - Seismic May 24, 2016 ML16162A660 7.9 NRC Staff Assessment of MSA - Seismic June 16, 2016 ML16166A321 7.10 NRC MSA Audit Plan December 5, 2016 ML16259A189

Turkey Point Units 3 and 4 TABLE 8 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 3: Recommendation 2.3 Seismic Walkdown Ref Document Date ADAMS Accession No.

8.1 Industry Seismic Walkdown Guidance with NRC endorsement letter - EPRI 1025286 May 31, 2012 ML12188A031 8.2 NRC letter endorsing EPRI 1025286 May 31, 2012 ML12145A529 8.3 Licensee Seismic Hazard Walkdown Report November 27, 2012 ML12349A162 8.4 NRC Inspection of Seismic Walkdowns NRC TI 2515/188 July 6, 2012 ML12156A052 NRC Integrated Inspection Report 2012-005 (TI 2515/188 inspection results)

January 30, 2013 ML13030A208 8.5 Licensee inaccessible items seismic walkdown report package July 13, 2013 ML13213A193 8.6 NRC Staff Assessment of Seismic Walkdown Report (includes inaccessible walkdown items walkdown report)

April 21, 2014 ML14071A560 TABLE 9 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 4: Recommendation 2.3 Flooding Walkdown Ref Document Date ADAMS Accession No.

9.1 Industry Flooding Walkdown Guidance - NEI 12-07 May 31, 2012 ML12173A215 9.2 NRC letter endorsing NEI 12-07 May 31, 2012 ML12144A142 9.3 Licensee Flooding Hazard Walkdown Report Flooding Hazard Walkdown Report package November 20, 2012 ML123400473 Update to Flooding Hazard Walkdown Report - APM Assessment January 29, 2014 ML14057A795 9.4 NRC Inspection of Flooding Walkdowns NRC TI 2515/187 June 27, 2012 ML12129A108 NRC Integrated Inspection Report 2013-002 (TI 2515/187 inspection results)

April 24, 2013 ML13115A425 9.5 NRC Staff Assessment of Flooding Walkdown Report June 11, 2014 ML14156A286

Turkey Point Units 3 and 4 TABLE 10 Request for Information under Title 10 of the Code of Federal Regulations, Section 50.54(f), Enclosure 5: Recommendation 9.3 Emergency Preparedness Communications and Staffing Ref Document Date ADAMS Accession No.

10.1 Guidance Documents Industry Guidance for Emergency Preparedness staffing and communications - NEI 12-01 May 2012 ML12125A412 NRC letter endorsing NEI 12-01 May 15, 2012 ML12131A043 10.2 Florida Power & Light 60 day response and proposed alternative course of action May 10, 2012 ML12144A158 10.3 Florida Power & Light 90 day response to communications and staffing information requests June 11, 2012 ML12174A198 10.4 NRC letter - status of 90-day response July 26, 2012 ML12200A106 10.5 Licensee communications assessment Communications assessment October 25, 2012 ML12300A425 Supplement to communications assessment February 15, 2013 ML13064A359 10.6 NRC staff assessment of licensees communications assessment June 6, 2013 ML13149A382 10.7 Licensee Phase 1 staffing assessment (Non-public)

April 26, 2013 ML13128A079 10.8 NRC response to licensees Phase 1 staffing assessment October 23, 2013 ML13233A183 10.9 Licensee Phase 2 staffing assessment response Licensee Phase 2 staffing assessment for functions related to mitigation strategies September 28, 2015 ML15301A838 Licensee response to RAI January 20, 2016 ML16028A105 10.10 NRC Phase 2 staff assessment response March 3, 2016 ML16054A708 10.11 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Emergency Preparedness Information NRC TI 2515/191 December 23, 2015 ML15257A188 NRC TI 2515/191 Inspection Report 2018-011 March 30, 2018 ML18089A127

Turkey Point Units 3 and 4 TABLE 11 Additional Licensee Commitments - SAMGs and Multisource Dose Assessments Ref Document Date ADAMS Accession No.

Update and Maintain SAMGs 11.1 SECY-15-0065: Proposed Rulemaking:

Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49)

April 30, 2015 ML15049A201 11.2 SRM-SECY-15-0065 August 27, 2015 ML15239A767 11.3 NEI Letter describing industry initiative to update and maintain SAMGs October 26, 2015 ML15335A442 11.4 Site Commitment to Maintain SAMGs December 17, 2015 ML15356A209 11.5 NRC letter to NEI describing approach to SAMG oversight February 23, 2016 ML16032A029 11.6 NRC Inspection Procedure 71111.18, Plant Modifications November 17, 2016 ML16306A185 11.7 NEI 14-01, Emergency Response Procedures and Guidelines for Extreme Events and Severe Accidents, Rev. 1 February 2016 ML16224A619 Multisource Dose Assessments 11.8 NEI Letter: Industry survey and plan for multiunit dose assessments January 28, 2013 ML13028A200 11.9 NRC Letter to request additional information on multiunit dose assessment capability February 27, 2013 ML13029A632 11.10 NEI Letter: Implementation of Multiunit Dose Assessment Capability March 14, 2013 ML13073A522 11.11 Licensee Response Regarding Multisource Offsite Dose Assessment Capability to perform multisource dose assessment (non-public)

June 14, 2013 ML13183A073 Supplement - Commitment for automated system October 4, 2013 ML13295A223 11.12 NRC Acknowledgement of Licensee Dose Assessment Submittals April 2, 2014 ML14080A358 11.13 COMSECY-13-0010 March 27, 2013 ML12339A262 11.14 SRM-COMSECY-13-0010 April 30, 2013 ML13120A339 11.15 NRC Inspection of Licensee Responses to EA-12-049, EA-12-051, and Emergency Preparedness Information NRC TI 2515/191 December 23, 2015 ML15257A188 NRC TI 2515/191 Inspection Report 2018-011 March 30, 2018 ML18089A127 11.16 NEI 13-06, Enhancements to Emergency Reponses Capabilities for Beyond Design Basis Accidents and Events, Rev. 1 February 2016 ML16224A618

Turkey Point Units 3 and 4 TABLE 12 NRC Semi-Annual Status Reports to the Commission Ref Document Date ADAMS Accession No.

12.1 SECY-12-0025, Enclosure 8, Proposed Orders and Requests for Information in Response to Lessons Learned from Japans March 11, 2011, Great Thoku Earthquake and Tsunami February 17, 2012 ML12039A103 12.2 SECY-12-0095 - Enclosure 1: Six-Month Status Update On Charter Activities -

February 2012 - July 2012 July 13, 2012 ML12165A092 12.3 SECY-13-0020 - Third 6-Month Status Update On Response To Lessons Learned From Japan's March 11, 2011, Great Tohoku Earthquake And Subsequent Tsunami February 14, 2013 ML13031A512 12.4 SECY-13-0095 - Fourth 6-Month Status Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami September 6, 2013 ML13213A304 12.5 SECY-14-0046 - Fifth 6-Month Status Update on Response to Lessons Learned From Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami April 17, 2014 ML14064A520 12.6 SECY-14-0114 - Sixth 6-Month Status Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami October 21, 2014 ML14234A498 12.7 SECY-15-0059 - Seventh 6-Month Status Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami April 9, 2015 ML15069A444 12.8 SECY-15-0128: Eighth 6-Month Status Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami October 14, 2015 ML15245A473 12.9 SECY-16-0043: Ninth 6 Month Status Update on Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami April 5, 2016 ML16054A255 12.10 SECY-17-0016: Status of Implementation of Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Subsequent Tsunami January 30, 2017 ML16356A084

ML20055F060 *Via e-mail OFFICE NRR/DORL/LPMB/PM NRR/DANU/UARL/LA NRR/DORL/LPMB/BC NRR/DORL/LPMB/PM NAME RBernardo SLent DWrona*

RBernardo DATE 02/21/2020 02/25/2020 03/24/2020 03/24/2020