View source for L-2014-303, Response to Request for Additional Information Re License Amendment Request No. 216 - Transition to 10CFR50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for LWR Electric Generating Plants

{{Adams
| number = ML14336A634
| issue date = 11/05/2014
| title = Response to Request for Additional Information Re License Amendment Request No. 216 - Transition to 10CFR50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for LWR Electric Generating Plants
| author name = Kiley M
| author affiliation = Florida Power &amp; Light Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000250, 05000251
| license number = 
| contact person = 
| case reference number = L-2014-303
| package number = ML14336A638
| document type = Letter type:L
| page count = 7
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035 0 November 5, 2014 FPL. L-2014-303 10 CFR 2.390 10 CFR 50.90 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Generating Station Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)

==References:==
: 1. Florida Power & Light Company letter L-2012-092, "Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," June 28, 2012.2. Florida Power & Light Company letter L-2013-086, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," March 18, 2013.3. Florida Power & Light Company letter L-2014-003, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," January 4, 2014.4. Florida Power & Light Company letter L-2014-071, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)", April 4, 2014.5. Florida Power & Light Company letter L-2014-197, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," July 18, 2014.6. Florida Power & Light Company letter L-2014-256, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," September 12, 2014.By Florida Power & Light Company (FPL) letter L-2012-092 dated June 28, 2012, (Reference 1)in accordance with the provisions of 10 CFR 50.90, "Application of License or Construction Permit," FPL requested an amendment to the Renewed Facility Operating License (RFOL) for Turkey Point Nuclear Generating Station Units 3 and 4. The License Amendment Request (LAR) will enable FPL to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide (RG) 1.205.Security-Related Information 
-Withhold From Public Disclosure Under 10 CFR 2.390.Enclosure 1 to this letter contains security-related information.
Upon removal of Enclosure 1 this letter is uncontrolled.
L-2014-303 Page 2 of 3 The final risk estimates provided to the NRC by FPL letter L-2014-256 (Reference
: 6) were based on the methodology summarized in the RAI responses documented by FPL letters L-2014-071 (Reference 4), L-2014-197 (Reference 5), and L-2014-256 (Reference 6).The final quantification resulted in deletion, revision and addition of plant modifications previously submitted to the NRC per Reference
: 1. Enclosure 1 provides a revision to LAR Attachment S, Table S-2, Plant Modifications Committed, replacing it in its entirety.
The revised Table S-2 updates the Problem Statement for items 11, 12, 13 and 14 incorporating clarifying notes previously submitted to the NRC per Reference
: 2. The revised Table S-2 also reflects the following revisions previously submitted to the NRC per Reference 4: (1) plant modifications deleted (items 3, 4 and 24); and (2) one new plant modification (item 33).This submittal revises Table S-2 to reflect the following:
(1) plant modifications status; (2)addition of clarifying notes to items 16, 22, 29 and 32 to identify unit applicability for modification implementation for those items listed as applicable to both Units 3 and 4; (3) revision of item 20 to document it is a calculation, not a physical plant modification; (4) revision of item 25 to add panels 3C1 I and 4C1 1 to the modification; (5) revision of item 27 to reflect it is a Unit 3 modification; and (6) deletion of item 26 as a result of the revision to item 25.Enclosure 1 also provides a revision to LAR Attachment S, Table S-3, Implementation Items, originally submitted to the NRC by Reference
: 1. The enclosed Table S-3 replaces the original Table S-3 in its entirety.
Table S-3 has been updated to reflect revisions previously submitted to the NRC by FPL letters L-2013-086 (Reference 2), L-2014-003 (Reference 3), L-2014-071 (Reference 4), and L-2014-197 (Reference 5), and to add clarifying information.
The following revisions to Table S-3 reflect changes previously submitted to the NRC: (1) the description of item 18 was revised to reflect changes submitted per References 2 and 4; (2)item 19 was revised to delete reference to Table S-2, items 3 and 4 since the modifications were deleted by Reference 4; (3) item 20 was added by Reference 3; (4) items 21 and 23 were added by Reference 4; (5) item 22 was added by Reference 4 and revised by Reference 5; and (6) item 24 was added by Reference 2.The clarifying information incorporated in Table S-3 includes:
(1) the note above Table S-3 was revised to add item 12 as one of the items that will be completed in accordance with the modification process; and to clarify that item 22 will be completed within 6 months of the NRC approval of the Flowserve RCP Seal Topical Report; and (2) Item 12 added reference to Table S-2 item 22 to clarify linkage between the Table S-2 and S-3 items.Enclosure 1 to this letter contains sensitive security-related information; therefore, FPL requests that it be withheld from public disclosure in accordance with 10 CFR 2.390.Enclosure 2 to this letter provides a proposed revision to LAR Attachment M, License Condition, originally submitted to the NRC by Reference
: 1. The proposed License Condition revises two Sections:
: 1) Other Changes that May Be Made Without Prior NRC Approval, to add a statement specifying that this License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805; and 2) Transition License Conditions, items 2 and 3. Item 2 was revised to specify that plant modifications will be completed by the end of the second refueling outage (for each unit) following issuance of the license amendment.
Item 3 was revised to specify that: (1) implementation items 12, 18 and 19 are associated with plant modifications which will be completed in accordance with the plant modifications schedule; and (2)Security-Related Information -Withhold From Public Disclosure Under 10 CFR 2.390.Enclosure 1 to this letter contains security-related information.
Upon removal of Enclosure 1 this letter is uncontrolled.
L-2014-303 Page 3 of 3 implementation item 22 will be completed within 6 months of the NRC approval of the Flowserve RCP Seal Topical Report.The additional information provided in this letter does not impact the 10 CFR 50.92 evaluation of"No Significant Hazards Consideration" previously provided in FPL letter L-2012-092.
If you should have any questions regarding this application, please contact Robert Tomonto, Licensing Manager, at 305-246-7327.
I declare under penalty of perjury that the foregoing is true and correct.Executed on November t, 2014.Michael Kiley Vice President Turkey Point Nuclear Generating Station Enclosures cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point USNRC Project Manager for Turkey Point Ms. Cindy Becker, Florida Department of Health Security-Related Information -Withhold From Public Disclosure Under 10 CFR 2.390.Enclosure 1 to this letter contains security-related information.
Upon removal of Enclosure 1 this letter is uncontrolled.
Enclosure 2 to L-2014-303 Response to Request for Additional Information License Amendment Request No. 216 Florida Power and Light Company Turkey Point Nuclear Generating Station Units 3 and 4 Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Updated LAR Attachment M, License Condition Changes L-2014-303 Enclosure 2 Florida Power & Light Attachment M -License Condition Changes Replace the current FPL Turkey Point Nuclear Plant Unit 3 and Unit 4 fire protection License Conditions 3ID with the standard license condition based upon Regulatory Position 3.1 of RG 1.205.Fire Protection Program Florida Power and Light shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated 6/28/12, (and supplements dated 9/19/12, 3/18/13, 4/16/13, 5/15/13, 1/7/14, 4/4/14, 6/6/14, 7/18/14, 09/12/14 and 11/05/14) and as approved in the safety evaluation dated XX/XX/XX.Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10-7/year (yr) for CDF and less than 1 X 10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Revision I Page M-2 L-2014-303 Enclosure 2 Florida Power & Light Attachment M -License Condition Changes Other Changes that May Be Made Without Prior NRC Approval 1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement.
A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is"adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
The four specific sections of NFPA 805, Chapter 3, are as follows:* "Fire Alarm and Detection Systems" (Section 3.8);* "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);* "Gaseous Fire Suppression Systems" (Section 3.10); and* "Passive Fire Protection Features" (Section 3.11).This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated XX/XX/XX to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fire Revision 1 Page M-3 L-2014-303 Enclosure 2 Florida Power & Light Attachment M -License Condition Changes protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.Transition License Conditions
: 1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. and 3.below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2.above.2. The licensee shall implement the modifications to its facility, as described in Enclosure 1, Attachment S, Table S-2, "Plant Modifications Committed," of FPL letter L-2014-303, dated 11/05/2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the end of the second refueling outage (for each unit)following issuance of the license amendment.
The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3. The licensee shall implement the items listed in Enclosure 1, Attachment S, Table S-3, "Implementation Items," of FPL letter L-2014-303, dated 11/05/2014, with the exception of items 12, 18 and 19, no later than 180 days after NRC approval unless that falls within a scheduled outage window. Then this will occur 60 days after startup from that scheduled outage. Items 12, 18 and 19 are associated with modifications in Table S-2 and will be completed in accordance with Transition License Condition 2 above. Item 22 will be completed within 6 months of the NRC approval of the Flowserve RCP Seal Topical Report.Revision 1 Page M-4}}