View source for L-2010-022, Request to Amend License Proposed Changes to the Technical Specifications (TS) for the Removal of Two TS That Restrict Movements of Heavy Loads Over the Spent Fuel Pools

{{Adams
| number = ML100600441
| issue date = 02/16/2010
| title = Request to Amend License Proposed Changes to the Technical Specifications (TS) for the Removal of Two TS That Restrict Movements of Heavy Loads Over the Spent Fuel Pools
| 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 = DPR-031, DPR-041
| contact person = 
| case reference number = L-2010-022
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 65
}}

=Text=
{{#Wiki_filter:0 FPL.
POWERING TODAY.
EMPOWERING TOMORROW.
10 CFR 50.90 L-2010-022 February 16, 2010 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re:       Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request No. 202 Technical Specification Changes Regarding Heavy Loads over the Spent Fuel Pools In accordance with the provisions of Sections 50.90 and 50.91 (a)(1) of Title 10 of the Code of Federal Regulations (10 CFR), Florida Power and Light Company (FPL) hereby submits an application for amendment to the Renewed Facility Operating License DPR-31 for Turkey Point Unit 3 and DPR-41 for Turkey Point Unit 4. The application proposes changes to the Technical Specifications (TS) for the removal of two TS that restrict movements of heavy loads over the spent fuel pools.
The proposed changes to the TS are related to heavy load transport activities by crane travel over the spent fuel pools of Turkey Point Units 3 and 4. Specifically, it is proposed to delete TS 3/4.9.7 requirements, associated with load limitations over the spent fuel pool, and retain them in licensee controlled documents. The deletion of TS 3/4.9.7 requirements is based on the operational limits and safety margins that are in place for the control of heavy loads, consistent with the Turkey Point responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, in licensee controlled documents.
Additionally, it is proposed to delete TS 3/4.9.12 that limits the handling of the spent fuel cask under certain conditions. The deletion of TS 3/4.9.12 is justified based on the installation of a new single-failure-proof spent fuel cask handling crane meeting the requirements of NUREG-0554, "Single-Failure-Proof Cranes For Nuclear Power Plants," May 1979. provides the proposed changes and the supporting justification including the Determination of No Significant Hazards and Environmental Considerations. Attachment 2 contains marked copies of the proposed TS pages. Attachment 3 is a NUREG-0554 compliance matrix for the new single-failure-proof crane.
Acc,(
an FPL Group company

Turkey Point Units 3 and 4                                                              L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 2 of 2 The Plant Nuclear Safety Committee has reviewed the proposed amendment. In accordance with 10 CFR 50.91 (b)(1), copies of the proposed amendment are being forwarded to the State Designee for the State of Florida.
FPL requests approval of this application within 12 months of receipt by the NRC in order to prepare for the transfer of spent fuel to dry storage in 2011. Implementation by FPL will be within 60 days of license amendment issuance by the NRC.
Please contact Mr. Robert Tomonto at 305-246-7327 if there are any questions about this license amendment application.
I declare under penalty of perjury that the foregoing is true and correct.
Very truly yours, Executed on                                     Michael Kiley Vice President - Turkey Point Nuclear Plant Attachments: 1)         Evaluation of Proposed Technical Specification Changes
: 2)      Marked-up Technical Specification Pages
: 3)      NUREG-0554 Compliance Matrix cc:     Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Mr. W. A. Passetti, Florida Department of Health

Attachment 1 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Evaluation of Proposed Changes

Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                              Page 1 of 14

==1.0    INTRODUCTION==

In accordance with the provisions of Sections 50.90 and 50.91 (a)(1) of Title 10 of the Code of Federal Regulations (10 CFR), Florida Power and Light Company (FPL) hereby submits an application for amendment to the Renewed Facility Operating License DPR-31 for Turkey Point Unit 3 and DPR-41 for Turkey Point Unit 4. The application proposes changes to the Technical Specifications (TS) for the deletion of two TS that restrict movements of heavy loads over the spent fuel pools.

==2.0    DESCRIPTION==
OF PROPOSED LICENSE AMENDMENTS The proposed TS changes for Turkey Point Units 3 and 4 are as follows:
TS 3/4.9.7, "Crane Travel - Spent Fuel Storage Areas," would be deleted. TS 3/4.9.7 defines restrictions for heavy loads carried over irradiated fuel stored in the spent fuel pool. The load limitation defined in TS 3/4.9.7 is preserved and implemented in existing plant documents which have been established based on the operating limits and safety margins for the control of heavy loads consistent with FPL responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980 [Reference I].
TS 3/4.9.12, "Handling of Spent Fuel Cask," would be deleted. TS 3/4.9.12 specifies the requirements for the movement of a spent fuel cask. The deletion of TS 3/4.9.12 is based on the installation of a new single-failure-proof spent fuel cask handling crane meeting the requirements of NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979 [Reference 2].

==3.0    BACKGROUND==

Turkey Point Units 3 and 4 are owned and operated by FPL. The plant is located on the shore of Biscayne Bay in Miami-Dade County, Florida, about 25 miles south of Miami, Florida. The plant consists of two Westinghouse pressurized water reactor nuclear units.
Each unit utilizes a spent fuel pool for the storage of spent nuclear fuel assemblies to remove decay heat and provide radiation shielding.
The spent fuel handling crane, described in the Turkey Point Updated Final Safety Analysis Report (UFSAR), Section 9.5.4, "Fuel Handling System," and used for spent fuel handling, is a traveling bridge with a top-running trolley mounted on an overhead structure. Loads in excess of 2000 pounds are prohibited from travel over fuel assemblies by TS 3/4.9.7. The spent fuel handling crane has operational limits and safety

Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                Page 2 of 14 margins that are currently in place for the control of heavy loads consistent with NUREG-0612. The trolley is equipped with two hoists, one on each side of the bridge.
The hoists are provided with limit switches, overload sensors and other safety features to withstand two-blocking, load hang-ups and other overloading, mis-reeving, and single cable failures. The capacity of each hoist is two tons.
In addition, an in-line weight sensing system is provided for each hoist to limit the lifting load to preclude accidental fuel damage should binding occur. When lifting over spent fuel, the total load is limited to 2000 pounds by procedures, limit switches and load sensors.
The current spent fuel cask handling crane is a 105/15 ton main/auxiliary hook capacity cask crane of the overhead bridge type, and services both units for spent fuel cask handling operations. The crane is located outdoors, where it can access each unit's auxiliary building, as well as adjacent outside laydown areas and the plant road. The crane is not currently single-failure-proof and its original design included only static seismic factors. Access to the cask handling/storage area of each unit's spent fuel pool is through an opening in the Auxiliary Building's roof and east wall, which is normally closed, by an inverted "L" shaped door. The crane is prevented by electrical interlocks and the physical location of the sliding roof/door opening, from carrying a load over the fuel storage areas of the spent fuel pools.
Based on the current inventory and the anticipated future generation of spent fuel at Turkey Point, FPL has decided on the implementation of an Independent Spent Fuel Storage Installation (ISFSI) for future storage of spent fuel in a dry cask storage system. In a typical cask loading campaign, the casks are loaded with spent fuel assemblies inside the spent fuel pool area; then the cask is lifted out of the pool using the spent fuel cask handling crane and placed in a cask handling facility where it is prepared for transfer to the ISFSI storage facility. The cask assembly for this system is a multiple fuel assembly configuration, in contrast to a single fuel assembly configuration as currently specified by TS 3/4.9.12.
FPL is in the process of upgrading the spent fuel cask handling crane to a single-failure-proof crane design (design rated load of 130 tons for the main hoist and 25 tons for the auxiliary hoist), which includes the replacement of the main and auxiliary hoists, trolley, bridge and electronics. Upgrade of the crane support structure is also being implemented to meet the increased load handling capabilities of the spent fuel cask handling crane.

Turkey Point Units 3 and 4                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                              Page 3 of 14

==4.0    TECHNICAL ANALYSIS==

Description of Proposed Changes Marked-up pages of the proposed Unit 3 and Unit 4 TS changes are shown in Attachment 2 to this application. The description of the proposed changes is summarized below.
The following TS are to be deleted:
Section 3/4.9.7                Crane Travel - Spent Fuel Storage Areas Section 3/4.9.12               Handling of Spent Fuel Cask TS 3/4.9.7 Limiting Condition for Operation (LCO) prohibits loads in excess of 2000 pounds from travel over fuel assemblies in the spent fuel storage pools.
TS 3/4.9.12 LCO specifies the spent fuel cask configuration and fuel aging requirements that must be met before the spent fuel cask can be moved. The LCO is applicable during movement of the spent fuel cask in the spent fuel storage area.
Proposed Technical Specification Changes A. TS 3/4.9.7, Crane Travel - Spent Fuel Storage Areas (both units)
Summary of Specification and Its Bases The TS 3/4.9.7 LCO prohibits loads weighing in excess of the nominal weight of a fuel assembly, control rod assembly, and associated handling tool from travel over irradiated fuel assemblies in the spent fuel pool. This weight limit is 2000 pounds and is the same for both units. The Surveillance Requirements (SR) specify verification of the load being 2000 pounds or less prior to the operation of the spent fuel handling crane over fuel assemblies. The Bases for these load restrictions support analyses assumptions to: 1) limit the activity released on a load drop to no more than the contents of a single fuel assembly; and 2) prevent a load drop from distorting fuel in the storage racks that would result in a critical geometry.
Evaluation of Proposed Change TS 3/4.9.7 is being deleted because the spent fuel-related crane requirements are not of controlling importance to operational safety. This rationale is consistent with the Improved Standard Technical Specifications for Westinghouse Plants and the 1993

Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                               Page 4 of 14 NRC Policy Statement. The proposed deletion of TS 3/4.9.7 is based on the guidelines of the NRC Staff Review of NSSS Vendor Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications ("split report"), dated May 9, 1988. TS 3/4.9.7 is listed in Appendix B, Table 2 (Westinghouse Plants) of the "split report" as an LCO which may be "wholly or partially relocated" to licensee controlled documents. FPL proposes to delete TS 3/4.9.7 and relocate its requirements that are currently implemented in existing plant documents which include procedures and the Updated Final Safety Analysis Report. These documents have been established based on the operating limits and safety margins for the control of heavy loads consistent with FPL responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants,"
July 1980. Therefore, an administrative basis exists for removing the TS 3/4.9.7 load limiting requirements and associated Bases from the Turkey Point Units 3 and 4 TS.
B. TS 3/4.9.12, Handling of Spent Fuel Cask (both units)
Summary of Specification and its Bases The TS 3/4.9.12 LCO prohibits the handling of the spent fuel cask under certain conditions. These conditions include a limitation that the cask not be moved into the spent fuel pit (pool) until all the fuel in the spent fuel pit has decayed for a minimum of 1525 hours. Second, only a single element cask can be moved into the spent fuel pit. Finally, a fuel assembly shall not be removed from the pit in a shipping cask until it has decayed for a minimum of 120 days. Limiting spent fuel decay time from last time critical to a minimum of 1,525 hours prior to moving a spent fuel cask into the spent fuel pit ensures that potential offsite doses are a fraction of 10 CFR Part 100 limits should a dropped cask strike stored fuel assemblies. The SR require determination of the required decay times of the spent fuel assemblies prior to the movement of the spent fuel cask. In addition, the spent fuel cask handling crane interlock shall be demonstrated operable within 7 days of crane operation and at least once per 7 days when the crane is being used.
The restriction to allow only a single element cask to be moved into the spent fuel pit ensures the maintenance of water inventory in the unlikely event of an uncontrolled cask descent. Use of a single element cask, which nominally weighs about twenty-five tons, increases crane safety margins by about a factor of four.
Requiring that spent fuel decay time from last time critical be at least 120 days prior to moving fuel assemblies outside the fuel storage pit in a shipping cask ensures that potential offsite doses are a fraction of 10 CFR 100 limits should a dropped

Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                               Page 5 of 14 cask and ruptured fuel assembly release activity directly to the atmosphere.
Evaluation of Proposed Change The determination has been made that TS 3/4.9.12 can be deleted based on the upgrade of the new spent fuel cask handling crane to a single-failure-proof design, meeting applicable requirements of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, and NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979, ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)" [Reference 6] and CMAA 70-04, "Specifications for Top Running Bridge & Gantry Type Multiple Girder Electric Overhead Traveling Cranes" [Reference 7]. Operating experience and inspection information related to upgrading existing cranes to single-failure-proof for the movement of heavy loads, provided in NRC Regulatory Issue Summary 2005-25 [Reference 8] is also incorporated in the design considerations.
A Compliance Matrix is contained in Attachment 3 to this application demonstrating specific compliance with each section of NUREG-0554.
This implementation of the new single-failure-proof spent fuel cask handling crane eliminates the need for the cask drop accident analyses currently included in the UFSAR for each plant because the potential for a cask drop is considered to be extremely small.
The single-failure-proof spent fuel cask handling crane is designed, and will be fabricated, installed and tested to ensure that a single failure will not result in the loss of the capability of the system to safely retain the load. Dynamic analysis has been performed for the applicable seismic conditions defined in the UFSAR.
During a seismic event (Design Earthquake and Maximum Earthquake), the crane and main and auxiliary hoists are designed to retain control of and hold the maximum critical load (MCL). The analyzed design rated load (DRL) of the trolley and main hoist of the spent fuel cask handling crane is 130 tons. The DRL for the auxiliary hoist is 25 tons. The spent fuel cask handling crane system component parts subject to wear and exposure are designed for a minimum of 15 percent above the design rated load in accordance with Section 2.2 of NUREG-0554 for additional safety margin. Similarly, the bridge and trolley are designed to remain in place on their respective runways with their wheels prevented from leaving the tracks during a seismic event.
The operational limits, interlocks, procedural and administrative controls, that

Turkey Point Units 3 and 4                                                              L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                             Page 6 of 14 restrict the handling of heavy loads over fuel stored in the spent fuel pool will continue to be in place and will be applicable to the new spent fuel cask handling crane.
The deletion of TS 3/4.9.12 is based on the new single-failure-proof crane and the implementing procedures that will meet the applicable requirements of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," Section 5.1.6, "Single Failure Proof Handling Systems," July 1980, and NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979.

==5.0    REGULATORY ANALYSIS==

Applicable Regulatory Requirements/Criteria Section 182a of the Atomic Energy Act of 1954, as amended (the Act) requires applicants for nuclear power plant operating licenses to include the TSs as part of the license. The Commission's regulatory requirements related to the content of TSs are set forth in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR). The regulation requires that the TSs include items in specific categories, including: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls.
The regulation does not specify the particular requirements to be included in the TSs.
The four criteria defined by 10 CFR 50.36(c)(2)(ii) [Reference 3] determine whether particular items are required to be included in the TS LCOs. The design basis accidents and transient analyses discussed in Criteria 2 and 3 include any design basis event described in the UFSAR, not.just those events described in Chapters 6, "Engineered Safety Features," or Chapter 15, "Accident Analysis." The initial conditions captured under Criterion 2 should not be limited to only process variables assumed in the safety analyses, they should also include certain active design features and operating restrictions needed to preclude unanalyzed accidents. In this context, active design features include only those design features under the control of operations personnel (i.e., licensed operators and personnel who perform control functions at the direction of licensed operators).
Furthermore, should the TSs involve physical, designed-in features that prevent operations staff from immediately exceeding the assumptions in the bounding analysis in the course of operations, then the TSs would not meet Criterion 2 and could be relocated to the UFSAR or other similarly controlled document. The NRC staff documented its

Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                               Page 7 of 14 decisions on the relocation of TSs in the "NRC Staff Review of Nuclear Steam Supply System Vendor Groups' Application of the Commission's Interim Policy Criteria to Standard Technical Specifications," transmitted to the various nuclear industry owners groups on May 9, 1988. Existing TSs that fall within or satisfy any of the above criteria must be retained in the TSs; those that do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.
NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants," dated May 1979, identifies features of the design, fabrication, installation, inspection, testing, and operation of single-failure-proof overhead crane handling systems that are used for handling critical loads. The NUREG superseded Draft Regulatory Guide 1.104, Overhead Crane Handling Systems for Nuclear Power Plants, dated 1976.
In NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, the NRC staff provided regulatory guidelines for control of heavy load lifts to assure safe handling of heavy loads in areas where a load drop could impact on stored spent fuel, fuel in the reactor core, or equipment that may be required toachieve safe shutdown or permit continued decay heat removal. Section 5.1.1 of NUREG-0612 provides guidelines for reducing the likelihood of dropping heavy loads and provides criteria for establishing safe load paths; procedures for load-handling operations; training of crane operators; design, testing, inspection, and maintenance of cranes and lifting devices; and analyses of the impact of heavy load drops.
The guidelines in Sections 5.1.2 through 5.1.6 ofNUREG-0612 address alternatives to either further reduce the probability of a load handling accident or mitigate the consequences of heavy load drops. These alternatives include using a single-failure-proof crane to improve reliability through increased factors of safety and through redundancy or duality in certain active components. Criteria for design of single-failure-proof cranes are included in NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants."
In NRC Bulletin (NRCB) 96-02, Movement of Heavy Loads over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment, dated April 1996, the NRC staff addressed specific instances of heavy load handling concerns and requested licensees to provide specific information detailing their extent of compliance with the guidelines and their licensing basis.
6.0    NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION FPL has evaluated these TS changes to determine if a significant hazard is present. The

Turkey Point Units 3 and 4                                                             L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                            Page 8 of 14 No Significant Hazards Consideration evaluation required by 10 CFR 50.92 is provided below for each TS change.
TS 3/4.9.7, Crane Travel-Spent Fuel Storage Areas (reviewed for both units)
FPL has evaluated whether or not a significant hazards consideration is involved with removing the TS 3/4.9.7, "Crane Travel - Spent Fuel Storage Areas," from the Turkey Point Units 3 and 4 TS by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1)    Would operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The removal of TS 3/4.9.7 will not increase the probability of a fuel handling accident (FHA), as evaluated in Chapter 14.2.1 of the UFSAR, and is considered remote because of the administrative controls and physical limitations imposed on fuel handling operations. The load limit restriction, in conjunction with existing plant documents (for example, Turkey Point heavy load handling procedures) that restrict crane or other heavy load handling operations provide a defense-in-depth approach to handling heavy loads in the spent fuel pool vicinity. The load limitation defined in TS 3/4.9.7 is preserved and will be implemented based on the operation limits and safety margins for the control of heavy loads consistent with NUREG-0612. The TS change does notrepresent any physical change to the plant systems, structures, or components. Therefore, the systems credited with mitigating the dose consequences of a FHA remain in place. The dose consequences of a fuel handling accident as discussed in Turkey Point UFSAR Chapter 14.2.1 will not increase because of the administrative controls and physical limitations imposed on fuel handling operations which minimize the likelihood of a FHA.
Therefore, facility operation in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2)    Would operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Turkey Point Units 3 and 4                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                             Page 9 of 14 Response: No The removal of TS 3/4.9.7 does not represent any physical change to the plant systems, structures, or components. The same operational functions of moving new fuel, spent fuel, or other loads over the spent fuel pool are retained and therefore do not create or increase the possibility of a new or different kind of accident from any accident previously evaluated. Additionally, the load limit of 2000 pounds over the spent fuel pool defined in TS 3/4.9.7 is preserved and implemented in existing plant documents and are established based on the operational limits and safety margins for the control of heavy loads consistent with NUREG-0612. Other measures which preclude the creation of a new or different type of accident include interlocks and physical stops, operator training, and load handling procedures.
Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3)    Would operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?
Response: No The removal of TS 3/4.9.7 does not change the operational process of moving loads over the spent fuel pool. There are no changes to any physical plant systems, structures, or components. The spent fuel handling crane has weight sensors that are interlocked to limit the total load. In addition, an in-line weight sensing system is provided for each hoist to limit the lifting load to preclude accidental fuel damage should binding occur. When lifting over spent fuel, the total load is limited to 2000 pounds by current procedures, limit switches and load sensors. Because of these measures no margin of safety is reduced or compromised.
Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.
Based on the above, FPL concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),
and, accordingly, a finding of "no significant hazards consideration" is justified.

Turkey Point Units 3 and 4                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                           Page 10 of 14 TS 3/4.9.12, Handling of Spent Fuel Cask (reviewed for both units)
FPL has evaluated whether or not a significant hazards consideration is involved with the proposed amendment of removing TS 3/4.9.12, "Handling of Spent Fuel Cask," by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
I)    Would operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The removal of TS 3/4.9.12 will not involve a significant increase in the probability or consequences of an accident previously evaluated. The accident evaluated for the existing spent fuel cask handling crane is the drop of a single element cask as cited in UFSAR Section 14.2.1.3, "Cask Drop Accident." This cask drop accident was analyzed and the radiological dose consequence, as a result of the cask drop, is determined to be within the limits of 10 CFR 100. The current spent fuel cask handling crane at Turkey Point Units 3 and 4 has a single 105/15 ton main/auxiliary hook design capacity and is not designed as single-failure-proof. The new spent fuel cask handling crane will be single-failure-proof meeting all of the requirements of NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" and also NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems." The probability of a cask drop accident using a single-failure-proof crane designed and operated to these NUREG requirements is considered to be extremely small.
The design for the upgrade of the spent fuel cask handling crane is to increase the capacity to 130/25 tons (main/auxiliary hook). All crane components (hoist, bridge, girders, etc.) are designed and fabricated to retain control of and hold the maximum critical load (a planned 32 element spent fuel cask) in the unlikely event of the failure of a single component, coincident with a Design or Maximum earthquake.
The objectives cited in Section 5.1 of NUREG-0612, "Recommended Guidelines,"
for the control of heavy loads are satisfied. The probability of a cask drop accident using the new single-failure-proof spent fuel cask crane, as compared to the existing non-single-failure-proof crane, is therefore not increased. The increase of the consequences of an accident previously evaluated is also not increased because the potential for a cask drop by the new upgraded spent fuel cask handling crane is considered to be extremely small.

Turkey Point Units 3 and 4                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                            Page 11 of 14 Further, operational limits, interlocks, procedural and administrative controls, that restrict the handling of heavy loads over fuel stored in the spent fuel pool, provide additional defense-in depth to ensure that a load could not be dropped that would result in dose consequences greater than previously evaluated.
It is concluded that facility operation in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2)    Would operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No Operation of the spent fuel cask handling crane after the upgrade to a single-failure-proof design will remain the same as the operation of the existing spent fuel cask handling crane. The distinction is the load that will be lifted.
The new spent fuel cask is a multiple assembly cask, in contrast to a single assembly cask as currently specified for use. The current spent fuel cask handling crane is designed to lift a single element spent fuel cask. The upgraded capacity of the new spent fuel cask handling crane will allow for lifting a cask designed to hold a maximum of 32 spent fuel assemblies. Current operating and administrative procedures that restrict the movement of heavy loads over fuel stored in the spent fuel pool remain in place. The new spent fuel cask handling crane is designed, fabricated and tested to single-failure-proof requirements (NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" and NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems") and will be operated within the procedural and administrative framework as the currently installed spent fuel cask handling crane. Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created from the removal of TS 3/4.9.12.
Therefore, it can be concluded that the operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3)   Would operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

Turkey Point Units 3 and 4                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                             Page 12 of 14 Response: No The existing spent fuel cask handling crane is not designed as single-failure-proof in accordance with NUREG-0612. The new spent fuel cask handling crane is designed, and will be fabricated, installed and tested to the single-failure-proof requirements as outlined in NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems." The use of the defense-in-depth approach for the control and handling of heavy loads as cited in Section 5.1 of NUREG-0612, "Recommended Guidelines," provides assurance that there is a sufficient margin of safety in the handling of heavy loads. Thereby, the removal of TS 3/4.9.12 will not involve a significant reduction in the margin of safety.
Defense-in-depth measures include operational limits, interlocks, procedural and administrative controls, rigging, load paths, testing, training, maintenance and other related considerations. These measures provide assurance that the margin of safety is not reduced in the operation of the facility by meeting all the requirements of NUREG-0612 and NUREG-0554. The specific requirements and FPL compliance with them is documented in the NUREG-0554 Compliance Matrix [Attachment 3 to this application].
The design for the upgrade of the spent fuel cask handling crane is to increase the capacity to 130/25 tons (main/auxiliary hook). The spent fuel cask handling crane has a Main Hoist and Auxiliary Hoist Cable Safety Factor of a minimum 10:1 on nominal breaking strength at 130 tons and 25 tons respectively and is fully compliant with ASME NOG-1 Section 5425.1. The Main Hoist Hook and Auxiliary Hoist Hook Safety Factor have a 10:1 minimum on ultimate strength at 130 tons and 25 tons, respectively.
Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.
Based on the above, FPL concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
7.0    ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION 10 CFR 51.22(c)(9) provides criteria for identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facilityrequires no environmental

Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                             Page 13 of 14 assessment if operation of the facility in accordance with the proposed amendment would not:
(i)      involve a significant hazards consideration, (ii)     result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii)    result in a significant increase in individual or cumulative occupational radiation exposure.
FPL has reviewed the proposed amendment to remove two TS, which restrict movements of loads over the spent fuel pool, from the Turkey Point Nuclear Plant Unit 3 and 4 Operating Licenses. It has been concluded that the proposed amendment involves no significant increase in the amounts, with no significant change in the types, of any effluents that may be released offsite since existing effluent pathways are not impacted by the proposed change and new pathways are not created. There is no significant increase in individual or cumulative occupational radiation exposure since the activities supported by the load handling systems involved in the proposed amendment are not changed. The proposed amendment also involves no significant hazards consideration as discussed in Section 6.0 of this evaluation and meets the criteria for categorical exclusion set forth in 10 CFR 51.22(b). An environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.
8.0    PRECEDENT Licensing precedents for similar changes to remove spent fuel-related heavy load limitations include:
Oyster Creek received a license amendment on January 23, 2002 [Reference 4] which deleted Oyster Creek TS 5.3.1.B and 5.3.1 .C. These TS restricted the handling of heavy loads over irradiated fuel stored in the spent fuel pool. The basis for deleting these TS was the upgrade of the reactor building crane and associated handling systems to a single-failure-proof system. In comparison, from a spent fuel handling point of view, the Oyster Creek reactor building crane is equivalent to the Spent Fuel Cask Crane at Turkey Point Units 3 and 4.
St. Lucie Units 1 and 2 received license amendments on April 28, 2004 [Reference 5] for the relocation of Spent Fuel Crane TS requirements by applying the 10 CFR 50.36 criteria. The basis for the relocation of the TS was the certification that the replacement

Turkey Point Units 3 and 4                                                              L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                          Page 14 of 14 cask cranes were designed, installed, and load tested to the single-failure-proof criteria of NUREG-0554 under 10 CFR 50.59. Even though Turkey Point is not "relocating" the TS as described in the St. Lucie amendments, the load handling requirements and the associated activities, such as the replacement of the cask crane(s), are equivalent for comparison.

==9.0   REFERENCES==
: 1. NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980.
: 2. NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979.
: 3. 10 CFR 50.36(c)(2)(ii), Technical Specifications [screening criteria].
: 4. Letter from NRC to Mr. Oliver D. Kingsley, Exelon Nuclear, "Oyster Creek Nuclear Generating Station- Issuance of Amendment Re: Handling of Heavy Loads Over Irradiated Fuel Stored in the Spent Fuel Pool (TAC No. MB1747)," January 23, 2002.
: 5. Letter from NRC to Mr. J. A. Stall, Florida Power and Light, "St. Lucie Units 1 and 2- Issuance of Amendments Regarding the Relocation of Spent Fuel Pool Crane Technical Specification Requirements (TAC Nos. MB5667 and MB 5668)," April 28, 2004.
: 6. ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)," May 2005.
: 7. CMAA 70-04, "Specifications for Top Running Bridge & Gantry Type Multiple Girder Electric Overhead Traveling Cranes," January 2004
: 8. NRC Regulatory Issue Summary 2005-25: Clarification of NRC Guidelines for Control of Heavy Loads, October 31, 2005.

Attachment 2 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Marked-up Technical Specification Pages

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION                                                                                                                       PAGE 3/4.9 REFUELING OPERATIONS 3/4.9.1       BO RO N CO NCENTRATIO N.........................................................................                 3/4 9-1 3/4.9.2       INSTR UMENTAT IO N....................................................................................           3/4 9-2 3/4 .9.3      D E C AY T IME ................................................................................................ 3/4 9-3 3/4.9.4       CONTAINMENT BUILDING PENETRATIONS ..............................................                                 3/4 9-4 3/4.9.5       C O MMUNIC A T IO NS .....................................................................................       3/4 9-5 3/4.9.6       MA NIPULATO R C RA NE ...............................................................................            3/4 9-6
              /-DELETED 3/4.9.7         RANETRAVE - SPENT F                         L STORAGE AREAS                              .................. 3/4 9-7 3/4.9.8       RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION High W ater Level .......................................................................................... 3/4 9-8 Low W ater Level ........................................................................................... 3/4 9-9 TURKEY POINT - UNITS 3 & 4                                      xii                             AMENDMENT NOS.A-1"ANDA-8n

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION                                                                                                                                    PAGE 3/4.9.9      CONTAINMENT VENTILATION ISOLATION SYSTEM ...............................................                                      3/4 9-10 3/4.9.10     REFUELING CAVITY W ATER LEVEL .........................................................................                       3/4 9-11 3/4.9.11     WATER LEVEL - STORAGE POOL .............................................................................
g-DELETED)                                                                                                                    3/4 9-12 3/4.9.12     1, AN E,*"N* eF SPEN, TF.U.EL GA K ............................................................................               3/4 9-13 3/4.9.13     RA D IATIO N M O N ITO R ING ........................................................................................         3/4 9-14 3/4.9.14     S PE NT FU EL STO RA G E ..............................................................................................       3/4 9-15 3/4.10       SPECIAL TEST EXCEPTIONS 3/4.10.1     S H U T D O W N M A R G IN .................................................................................................. 3/4 10-1 3/4.10.2     GROUP HEIGHT, INSERTION, AND POWER DISTRIBUTION LIMITS ......................                                                 3/4 10-2 3/4.10.3     P H Y S IC S T E S T S    ................................................................................................... 3/4 10-3 3/4.10.4     (This specification num ber is not used) .........................................................................            3/4 10-4 3/4.10.5     POSITION INDICATION SYSTEM - SHUTDOWN .......................................................                                 3/4 10-5 TURKEY POINT - UNITS 3 &4                                           xiii                            AMENDMENT NOS.3,*9"AND,?.,<

REFUELING OPERATIONS 3/4.9.7 J .. NE TRAVEL - SPENT FUEL. STORACE AREAS
         '-DE LETED "LMITING    CONDITION FOR OPERATION 3.9.       od   'exes       of 2000 pounds shall be prohibited from travel over fuel assemblies ntstrg           ool. A APPLICABILITY:        Witl       asemblies in the storage pool.
ACTION:
: a.       With the requirements oe      above specification not s    ied, place the crane load in a safe condition.
: b.       The provisions of Specification 3.0.      n applicable.
SUREL                  sai                                                                                        "ET 4.9.. nor to crane operation over fuel assemblies in the spent fuel storage pool, verify that each load is 20 nds or less.
TURKEY POINT - UNITS 3 & 4                              3/4 9-7                    AMENDMENT NOS.,2,4AND,249

REFUELING OPERATIONS 3/4.9.12 j       -D LeF SPEN'T TAED~LIqe FULEL CGASK "I&IMITING CONDITION FOR OPERATION 3.91        eadling of spent fuel cask shall be limited to the following conditions:
: 1)      "he    spent fuel cask shall not be moved into the spent fuel pit until all the spen ffel in the pit has ayed for a minimum of one thousand five hundred twenty-five (1,525) h         rs.
: 2)        Only a     gle element cask may be moved into the spent fuel pit.
: 3)        A fuel assem      shall not be removed from the spent fuel pit in     hipping cask until it has' decayed for a mmum of one hundred twenty (120) days.
APPLICABILITY:       During movement o"pent fuel cask in the spent fu        torage area.
ACTION:
With the requirement of the above specification no     atisfie , suspend all movement of the spent fuel cask within the spent fuel storage area.
4.9.12.1 The following required decay time of the spent fuel a         mblies shall be determined prior to the movement of a spent fuel cask by verific i n of date and time the s nt fuel assemblies were placed into the spent fuel pit:
: a.        1525 hours of d ay of all spent fuel assemblies in the spen uel pit for movement of a spent fuel cask into the ent fuel pit.
: b.        120 da of decay of the spent fuel assembly in the spent fuel cask pi r to removal of the spent fuel sk from the spent fuel pit.
4.9.12.2 Prior t any operations involving spent fuel cask movement into the spent fuel pit, veri        only a single element ca will be moved into the spent fuel pit.
4.9.1    The spent fuel cask crane interlock shall be demonstrated OPERABLE within 7 days of crane o ration an t least once per 7 days (7 days is maximum time between tests; specification 4.0.2 does not apply he en the crane is being used to maneuver the spent fuel cask.
TURKEY POINT - UNITS 3 & 4                             3/4 9-13                     AMENDMENT NOS. ,144AND;1$4"

Attachment 3 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools NUREG-0544 Compliance Matrix

Turkey Point Units 3 and 4                                                             L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                           Page 1 of 42 Table of Contents NUREG-0554 Compliance Matrix                                                        Pages 2-42 NOTES:
: 1. NUREG-0612 incorporates NUREG-0554 as the referenced document for single-failure-proof cranes. Compliance with NUREG-0554 stated herein also ensures compliance with NUREG-0612.
: 2. The crane including main and auxiliary hoists, trolley and bridge are designed, manufactured and tested in accordance with the specific requirements of ASME NOG-I -
2004 for a Type I Crane (i.e. single-failure-proof crane). The ASME committee has prepared a matrix comparing the requirements of ASME NOG-1 Type I vs. NUREG-0554.
This matrix indicates that a design compliant with ASME NOG-l for a Type 1 Crane meets or exceeds the intent of NUREG-0554. The intent for the body of this document is to address specific requirements of NUREG-0554, unless otherwise indicated.
: 3. NRC REGULATORY ISSUE 

==SUMMARY==
2005-25, SUPPLEMENT I CLARIFICATION OF NRC GUIDELINES FOR CONTROL OF HEAVY LOADS, states "ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes." In Revision 1 to Section 9.1.5 of the Standard Review Plan (NUREG-0800), the NRC staff also enhanced the RIS 2005-25, Supplement I guidelines for the design of single-failure-proof cranes. The NRC staff has concluded that the application of the criteria for Type I cranes from ASME NOG-1-2004, "Rules for Construction of Overhead and Gantry Cranes," to the design of new overhead heavy load handling systems is an acceptable method for satisfying the guidelines of NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants." These guidelines provide licensees and applicants with guidance that the NRC considers acceptable for the use in designing new single-failure-proof cranes. The NRC staff has participated in the ASME Cranes for Nuclear Facilities Committee as it has developed a comparison of ASME NOG-I design criteria to the criteria of NUREG-0554. The NRC staff understands that the committee will provide the comparison as an appendix to a future revision of ASME NOG-1."
: 4. This document applies to the new components supplied as part of FPL'S vendor's scope for the new crane including the new bridge, trolley, main hoist, auxiliary hoist and electrical controls.

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                Page 2 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS 2.1.                                                       The replacement crane system including trolley and bridge was not utilized in the construction of the plant Construction   Design criteria for construction phase           nor for any construction lifts. The usage of the             No exceptions And        operation.                                       replacement crane system is limited to operational load      noted.
Operating                                                      handling. The replacement crane system did not have a Periods                                                      separate construction specification.
The existing crane system is being replaced with a new crane system; hence the new crane design is in Allowable design stress limits of Table          accordance with the latest revision of CMAA 3.3.3.1.3-1 of CMAA Specification #70-           Specification #70. The replacement crane system meets 1975.                                            the applicable allowable stress limits for plant operation as indicated in section 3.4 of CMAA Specification #70-2004.
The replacement crane system including main hoist, nreflects the appropriate duty cycle in auxiliary hoist, trolley and bridge is being designed and Design rmanufactured                                            in accordance with CMAA #70-2004 for CMAA Specification #70.                          Class C service, minimum. This service class is consistent with the anticipated crane usage.

Turkey Point Units 3 and 4                                                                                                   L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                  Page 3 of 42 SEC #                 NUREG-0554 GUIDANCE                            TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS Structural analysis for various load combinations is used to maintain allowable design margins.
Sum total of simultaneously applied loads           The replacement crane system including main hoist, (static and dynamic) should not result in stress    auxiliary hoist, trolley and bridge is designed for the levels causing permanent deformation, other         applicable loading combinations from ASME NOG-1, than localized strain concentration, in any part    CMAA Specification #70-2004 and NUREG-0554 of the handling system.                             design basis accident conditions (broken rope, two-blocking and load hang-up) and OBE (Operating Basis Earthquake) and SSE (Safe Shutdown Earthquake) 4.
combinations.
The main and auxiliary hoist motions employ flux vector variable frequency drives while the trolley and bridge Effects of cyclic loading induced by jogging motions employ scalar frequency drives to provide or plugging .... included in the design smooth slow speed positioning and gradual acceleration specifications.
and deceleration, eliminating the effects of cyclic loadings induced by jogging and plugging.

Turkey Point Units 3 and 4                                                                                            L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                           Page 4 of 42 SEC #                 NUREG-0554 GUIDANCE                      TURKEY POINT CRANE COMPLIANCE                               FPL I   _EXCEPTIONS The main hoist, trolley and bridge is designed for the specified maximum critical load (MCL) of 130 tons.
Single-failure-proof crane should be designed The auxiliary hoist is designed for the specified MCL of to handle the maximum critical load (MCL)     25 tons.
Wearing components in the main and auxiliary hoists Increase of approximately 15% of the design   including hooks, brakes, reducers and bearings are load (MCL) for component parts subjected to   designed with at least a 15% increase above their 2.2 degradation due to wear and exposure.         respective MCL ratings to account for degradation due to wear and exposure.                                      No exceptions Maximum The MCL and DRL (Design Rated Load) ratings of 130         noted.
Critical The MCL rating should be clearly marked on    tons and 25 tons will be clearly marked on the trolley, Load the crane.                                    crane bridge and on both sides of the main and auxiliary hoist lower blocks.
The DRL is the same as the MCL at 130 tons for the Certain single-failure-proof cranes may be    main hoist.
required to handle non-critical loads of      The DRL is the same as the MCL at 25 tons for the magnitude greater than the MCL during plant   auxiliary hoist. Therefore, this requirement is not maintenance period.                           applicable to the new crane.
The MCL and DRL ratings of 130 tons and 25 tons will The DRL rating marked on the crane be clearly marked on the trolley, crane bridge and on separately from the MCL marking.
both sides of the blocks.

Turkey Point Units 3 and 4                                                                                           L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                         Page 5 of 42 SEC #                NUREG-0554 GUIDANCE                       TURKEY POINT CRANE COMPLIANCE                               FPL EXCEPTIONS 28OF to 11 0&deg;F, 100% maximum relative humidity, atmosphere pressure, and no emergency corrosive or hazardous conditions are specified as design criteria.
Operating environment ... specified for the  The main and auxiliary hoist lower blocks are of an open crane and lifting fixtures.                  design to permit drainage and supplied with lubricants compatible with the spent fuel pool chemistry. FPL 2.3                                                    does not intend to submerse the lower blocks in the spent fuel pool.                                           No exceptions Operating                                                  The crane is located outdoors and outside of               noted.
Environment    Closed boxed sections of the crane structure containment. The crane is not subject to pressurization vented to avoid collapse during containment  from tests or plant operational loads; therefore box pressurization.                              sections are closed and not vented. The crane is not exposed to containment spray.
Drainage should be provided to avoid         The design of the crane includes design features to standing water in the crane structure.       prevent accumulation of water on the trolley or crane structure.

Turkey Point Units 3 and 4                                                                                                  L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                 Page 6 of 42 SEC #                NUREG-0554 GUIDANCE                           TURKEY POINT CRANE COMPLIANCE                                    FPL EXCEPTIONS Already fabricated crane structural              All structural members essential to structural integrity of 2.4 components should be tested by subjecting the    the new replacement crane will be subjected to impact No exceptions crane to a test lift at the lowest anticipated   testing utilizing the Charpy V-notch testing method per Material                                                                                                                      noted.
operating temperature (i.e. cold proof load      ASTM A-370. As such, the alternative of a cold proof Properties test).                                           load test was not utilized and not required.                 .9 I
Impact testing is not required for material with Structural members (exceeding /2 inch)                                                                           nominal All structural members essential to structural integrity of essential to structural integrity tested in                                                                      thickness of 5/8 the new replacement crane will be subjected to impact accordance with the following impact test                                                                        inch or less per testing utilizing the Charpy V-notch testing method per requirements. Either drop weight test per                                                                        ASME NOG-1 ASTM A-370.
ASTM E-208 or Charpy test per ASTM A-                                                                            and ASME 370 may be used for impact testing.                                                                              Section III, NC-2300 and ND-2300, as applicable.

Turkey Point Units 3 and 4                                                                                                       L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                     Page 7 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                       FPL EXCEPTIONS The replacement trolley and bridge structure are Toughness recommendations were developed         fabricated from plates and structural shapes rolled from Toughnessarecommendationtinswere deveped     carbon steel with thicknesses ranging from 1/4/4       in. to 1 1/2/2 typical material section thickness for crane in. For the structural members essential to the structural girders ... (2 in.). Later information indicates integrity of the replacement trolley and bridge structure,         No exceptions that material thickness of (4 in.) or more ... the required energy values of Table NOG-4212-1 are                 noted.
The rules of ASME Code Class 3 Charpy            satisfied. The required energy values from Table NOG-testing do not make adjustments for thickness    42a12-1 are extracted from Table ND-23 1-(a)-I of greater than (2 1/2 in)...                       Section III, Division 1 of the ASME Boiler and Pressure Vessel Code.
All structural members essential to structural integrity of the new replacement crane are subjected to impact testing utilizing the Charpy V-notch testing method per ASTM A-370.
2.4       As an alternative, cold proof testing            The minimum operating temperature for the replacement Material     consisting of a single dummy test load equal     crane is specified at 28'F. Charpy impact testing is               No exceptions Properties    to 1.25 times the MCL shall be used to           crform       ed at      28&deg;F. Chare      impactFtestin is          noted.
(continued)   establish the minimum operating temperature. performed    at a test tem specified minimum           tempuretemperature operating    of 30iF lessinthan  the accordance with ASME NOG-1.
As such, the alternative of a cold proof load test is not utilized and not required.

Turkey Point Units 3 and 4                                                                                                     L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                    Page 8 of 42 SEC #                 NUREG-0554 GUIDANCE                              TURKEY POINT CRANE COMPLIANCE                                   FPL EXCEPTIONS The alternative of a cold proof load test is not utilized The cold proof test should be followed by a          and not required. Welds on the replacement trolley and non-destructive examination of welds whose           bridge structure whose failure could result in the drop of failure could result in the drop of the critical     the critical load, will be nondestructively tested during load. The nondestructive examination of              initial fabrication. As such, nondestructive testing critical areas should be repeated at 4 year          subsequent to site load testing of the replacement crane intervals or less.                                   and thereafter is not required.
The main hoist lower block side plates are the only components of the new replacement trolley or bridge           Exception to cold Cranes and lifting fixtures made of low-alloy        structure fabricated from ASTM A514 steel. Charpy             proof testing of steel such as ASTM A514 should be                    impact testing is performed in accordance with ASTM           A514, but A370 at a test temperature of 30 degrees less than the        justified by subjected to the cold-proof test in any case.        specified minimum operating temperature in accordance         performing with ASME NOG-1. This approach is satisfactory to             impact testing.
I preclude brittle fracture of materials.                     I Cast iron should not be used for load-bearing components such as rope drums. Cast iron             Cast iron is not used for any load bearing components on may be used for electric motor frames and            the replacement trolley or bridge structure.
brake drums.                                                                                                       No exceptions
                                                                -U                                                                noted.
Alternative methods of fracture analysis that achieve an equivalent margin of safety against Not applicable for supplied equipment.
fracture ...

Turkey Point Units 3 and 4                                                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                               Page 9 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                FPL EXCEPTIONS 2.5 The crane is designed to retain control of the 130 ton MCL (Main Hoist) and 25 ton MCL (Auxiliary Hoist)
Crane designed to retain control of and hold                                                                 No exceptions Seismic for all load combinations including broken rope, two-the load.                                                                                                    noted.
Design                                                       blocking, load hang-up, and OBE and SSE seismic events.
The seismic and structural analysis of the crane determined that there is no appreciable trolley or bridge Bridge and trolley designed to remain in place uplift for all applied loading combinations. The during a seismic event with their wheels replacement trolley and bridge structure will be provided prevented from leaving the tracks.
with seismic restraints to ensure the bridge and trolley remain on the respective rails.
Analysis determined that the bridge would remain on the Bridge remains on the runway with brakes runway and the trolley will remain on the bridge with applied, and the trolley remains on the crane brakes applied during an OBE or SSE event. All crane girders with brakes applied during a SSE brakes will be set when the crane is not being operated event.
or power is removed.
4 The crane's design satisfies regulatory position 2 of Crane designed and constructed in accordance Regulatory Guide 1.29. The crane is designed to remain with regulatory position 2 of Regulatory in place and hold the load during and after an OBE or Guide 1.29.
SSE event.

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 10 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS The MCL plus operational and seismically        The crane mathematical model appropriately considers induced pendulum and swinging load effects       seismically induced pendulum and swinging load
               ... considered in the trolley design and they    effects. The pendulum effect due to horizontal seismic should be added to the trolley weight for the    input and swinging load effects is evaluated and bridge design.                                   determined to be insignificant.
Lamellar tearing is predominant in highly restrained joints such as connections utilizing thick plates and full penetration welds. The structural components of the replacement trolley and bridge structures are fabricated primarily from thin plate sections and welded together 2.6       Examine the (weld) joints by radiography or      via primary structural fillet welds eliminating the ultrasonic inspection ... to ensure the absence  concern of lamellar tearing.                                 No.exceptions Lamellar     of lamellar tearing in the base metal and        Additionally, non-destructive examinations of critical       noted.
Tearing     soundness in the weld metal.                     welds on the replacement trolley and bridge structure are performed in accordance with ASME NOG-1.
Hoist drum shell and hub full penetration butt weld integrity are verified by radiography or ultrasonic inspection.

Turkey Point Units 3 and 4                                                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                             Page 11 of 42 SEC #                 NUREG-0554 GUIDANCE                       TURKEY POINT CRANE COMPLIANCE                                  FPL EXCEPTIONS Non-destructive examinations of critical welds on the replacement trolley and bridge structure are performed Weld joints whose failure could result in the  in accordance with ASME NOG- 1.
drop of a critical load should be              Lamellar tearing is predominant in highly restrained nondestructively examined. If these weld      joints such as connections utilizing thick plates and full lamellar tearing, the base metal at the joint penetration welds. The structural components of the slamellardtearing b    e aost eymetaltine,        replacement trolley and bridge structures are fabricated should be nondestructively examined.          primarily from thin plate sections and welded together via primary structural fillet welds eliminating the concern of lamellar tearing.

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                             Page 12 of 42 SEC #                 NUREG-0554 GUIDANCE                         TURKEY POINT CRANE COMPLIANCE                                  FPL EXCEPTIONS Historical data, as well as projected crane usage indicates far less than 20,000 cycles will be applied to Fatigue analysis should be considered for the   the replacement trolley and bridge structure. Therefore, critical load-bearing structures and            additional fatigue analysis is not needed for any components of the crane handling system         components on the trolley or bridge structure, as CMAA Specification #70 used 20,000 cycles, minimum, as its 2.7                                                       design basis.
The structural fatigue usage factors from CMAA                No exceptions Structural                                                    Specification #70-2004, Table 3.4.7-1 are used in the         noted.
Fatigue                                                     design of the replacement trolley and bridge structure.
Cumulative fatigue usage factors should         The design of the mechanical components of the reflect effects of the cyclic loading from both replacement trolley and bridge considered the allowable stresses from CMAA Specification #70-2004 for the construction and operating periods.             appropriate service class (Class C). The replacement trolley and bridge structure are not used for construction.
The cumulative usage factor appropriately reflects the operating period for the crane.
Preheat temperatures for all weldments          All welding procedures for the replacement trolley and bridge structure specify preheat temperatures where 2.8       specified in the weld procedures.               required by AWS D .1.
Post weld heat treatment for all weldments                                                                    No exceptions Welding      specified in the weld procedures. To include    All welding procedures for the replacement trolley and        noted.
Procedures    Section 2.6 welds, which shall be post-weld     bridge structure specify post-weld heat treatment where heat treated in accordance with Sub Article     required by AWS D1. 1, 2006. This is in accordance 3.9 ofAWS DI-1.                                 with Sub Article 3.9 of AWS DI.1, 1976.

Turkey Point Units 3 and 4                                                                                             L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                          Page 13 of 42 SEC #                 NUREG-0554 GUIDANCE                      TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS Primary or principal load-bearing 3.1       components, equipment, and subsystems such   The quality inspections and checks for the primary or as driving equipment, drum, rope reeving     principle load bearing components of the replacement         No exceptions General      system, hooks, blocks, control systems, and  trolley and bridge structure are consistent with Table       noted.
braking system should receive special        7200-1 of ASME NOG-1.
attention.
Auxiliary hoisting systems of the main crane The new single-failure-proof trolley includes a 25 ton 3.2       handling system ... single-failure-proof. single-failure-proof auxiliary hoist.
No exceptions Auxiliary     Auxiliary systems or dual components for the Dual systems are provided on the main and auxiliary          noted.
Systems      main hoisting mechanism ... immobile safe    hoists ensuring the load will be retained upon a position.                                    component or subsystem failure.
Special features are provided in the design to sense over travel (control and power), overweight, overspeed, mis-spooling and unbalanced reeving. The electrical design 3.3       Automatic controls and limiting devices      addresses the effects of phase reversal or phase loss in designed ... disorders due to inadvertent    the hoist power supply (USNRC letter GL 83-042 dated No exceptions Electric     operator action, component malfunction ... Aug. 26, 1983) as well as undervoltage, overvoltage, and noted.
Control     will not prevent the handling system from    overcurrent protection. Detection of any of the above Systems      stopping and holding the load.               faults removes power from the hoists, placing them in a safe condition. Bridge and trolley motions are limited by travel limit switches, which de-energize the motor at ends of travel.

Turkey Point Units 3 and 4                                                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                            Page 14 of 42 SEC #                 NUREG-0554 GUIDANCE                         TURKEY POINT CRANE COMPLIANCE                                FPL EXCEPTIONS Emergency stop buttons, are provided on the radio Emergency stop button added to the control      transmitter and back-up pendant station. These buttons station to stop all motion.                     will remove power from all crane motors and set all brakes when actuated.
A crane that has been immobilized because of    The main and auxiliary hoists are provided with malfunction or failure of controls or           redundant brakes to allow portions of the hoist drive components while holding a critical load        train to be repaired while retaining the load. The should be able to hold the load or set the load hydraulic drum brakes on the main and auxiliary hoists down while repairs or adjustments are made. can be manually modulated to lower a load in the event of hoisting equipment failure.
The hydraulic drum brakes on the main and auxiliary hoists can be manually modulated to lower a load in the 3.4       Manual operation of the hoisting system and     event of hoisting equipment failure. A hand pump is the bridge and trolley transfer mechanisms to   provided to allow for manual operation of the hydraulic     No exceptions Emergency     a safe laydown area.                            system without electric power. The bridge and trolley       noted.
Repairs                                                     are provided with attachment points for manual operation.
Crane design and operating area include provisions ... cause release of radioactivity   Provisions (i.e. attachment points) are made to allow the during corrective repairs, replacements or adjustments are being made to place the crane   trolley and bridge to be moved to a safe area for handling system back into service after         component repair or replacement with a suspended load.
component failure(s).

Turkey Point Units 3 and 4                                                                                                    L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                Page 15 of 42 SEC #                  NUREG-0554 GUIDANCE                             TURKEY POINT CRANE COMPLIANCE                                FPL EXCEPTIONS 4.1                                                           The Operating and Maintenance Manual provided, Protection against excessive wire rope wear includes instructions for scheduled inspection and           No exceptions
                ... through scheduled inspection and Reeving                                                          maintenance of the wire ropes consistent with OSHA           noted.
maintenance.
System                                                          1910.179.
Design of the rope reeving systems(s) should       The design of the main and auxiliary hoist reeving be dual with each system providing separately      systems are dual with each system providing the load balance ... configuration of ropes and    independent load balance on the head and load blocks rope equalizer(s).                                 through configuration of ropes and rope equalizers.
Selection of the hoisting rope or running rope     The selection of the wire ropes for the main and
                    .to maintain efficient working of the          auxiliary hoist reeving system is consistent with the wire individual wire strands ... during the hoisting    rope manufacturer's application recommendations for operation.                                         their wire rope.
Impact and dynamic loadings, including acceleration, The effects of impact loadings, acceleration       emergency stops, broken rope, two-blocking, load hang-and emergency stops should be included in          up and seismic are considered in sizing the main and selecting rope reeving systems.                    auxiliary hoist wire ropes and reeving system
_ components.
Maximum load, including static and inertia         The maximum load, including the static and inertia forces, on each individual wire rope in the        forces on each individual wire rope in the dual reeving dual reeving system with the MCL attached          system with the design MCL attached, does not exceed should not exceed 10% of the manufacturer's         10% of the wire rope manufacturer's published breaking 4.
published breakinz strength.
                                    -      -                    A strength for both the main and auxiliary hoists.
                                                                         -

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 16 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS The wire rope selection criteria used is based upon the Consider the wire rope yield strength, as well   ultimate strength of the rope. The transferred load under as ultimate strength, when specifying wire       a broken rope scenario is limited to 40% of the ultimate aseutimatenstrength, whensprecaing wirope        strength of the rope in accordance with the requirements rope to ensure the desired margin on rope        of ASME NOG-1 to ensure satisfactory safety margins strength.                                        are maintained, thereby minimizing rope yield strength concerns.
Maximum fleet angle from drum to lead sheave in the load block or between              The hoist systems are designed such that the maximum individual sheaves should not exceed 3 1/20 at   fleet angle in each hoist system does not exceed 3 1/2'.
any one point during hoisting except that for the last three (3) feet of maximum lift elevation the fleet angle may increase slightly.
4.1       Reverse bends for running wire ropes should      The use of reverse bends is limited by the design. The be limited, and the use of larger sheaves        design utilizes larger sheaves with running sheave to Reeving System      considered in wire ropewhere fatiguea disproportional reduction life would be expectedi   wire rope diameters of at least 20:1 for the main and        No  exceptions noexptions irerop n ftige lfewoud b epeced Sysem                                         auxiliary hoists, thereby minimizing the stochastic          noted.
(continued)   from the use of standard sheave diameters for    affects of fatigue.
reverse bends.
Equalizer for stretch and load on the rope       The design of the main hoist equalizer is a combination reeving ... beam or sheave type or               of sheave and rocker beam. The design of the auxiliary combinations thereof.                            hoist equalizer is of the rocker beam type.

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 17 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                FPL EXCEPTIONS Dual rope reeving system with individual attaching points and means for balancing or The main hoist design employs an equalizer rocker beam distributing the load between the two and hydraulic shock absorbers to balance and distribute operating rope reeving systems will permit the forces associated with load transfer. The auxiliary either rope system to hold the critical load and hoist utilizes an equalizer rocker beam to balance and transfer the critical load without excessive distribute forces associated with the load transfer.
shock in case of failure of the other rope system.
Pitch diameter of running sheaves and drums      The pitch diameter of the drums and running sheaves is
               ... in accordance with recommendations of        greater than 20 times the wire rope diameter as required CMAA Spec. #70.                                  by Tables 4.5.2-1 and 4.6.4-1, respectively, of CMAA Specification. #70-2004 for class C service and 6 x 37 class rope.
Dual reeving system may be a single rope         The main hoist design uses two drums with two ropes, from each end of a drum terminating at one of    with a balanced dual reeving system with each rope the blocks or equalizer with provisions ..       terminating on the drum it originated on. The auxiliary designed for total load. Alternatively, a 2-rope hoist uses one drum with two ropes with a balanced dual system may be used from each drum or             reeving system with each rope terminating at the separate drums using a sheave equalizer or       equalizer assembly. Each rope of the main and auxiliary beam equalizer or any other combination that     hoist is capable of carrying the respective rated load with provides two separate and complete reeving       a factor of safety of 5:1 against the manufacturer's systems.                                         published breaking strength.

Turkey Point Units 3 and 4                                                                                                    L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                 Page 18 of 42 SEC #                NUREG-0554 GUIDANCE                            TURKEY POINT CRANE COMPLIANCE                                   FPL EXCEPTIONS 4.2       Load hoisting drum ... structural and             The drum retaining devices are steel structures, which mechanical safety devices to limit the drop of    ensure that a shaft or bearing failure will not allow the      No exceptions Drum        the drum ... from disengaging from its            main or auxiliary hoist drums to disengage from the            noted.
Supports     holding brake system.                             brakes.
Head and load blocks should be designed to        The main and auxiliary hoist head and load blocks are 4.3                                                         designed to use a dual reeving design to maintain a maintain a vertical load balance about the                                                                       No exceptions center of lift ... reeving system of dual         vertical load balanced about the center of the lift. The       noted.
Head and     den         .                                     balanced dual reeving system eliminates tilt of the load Load Blocks    design.                                           block.
Load-block assembly should be provided with       The designa provides providing             an path single load equivalent  marginpoint)
(attachment    of safety with by a     Design consistent two load-attaching points, ... each ... able to                                                                  with NUREG-support a load of three times the load (static    10:1 factor of safety on ultimate strength consistent with     0612 Appendix C supportamic) lod othutie          thel    (att      NUREG-0612 Appendix C and ASME NOG-1. The                      and ASME and dynamic) ... without permanent                main hoist hook MCL is 130 tons and the auxiliary hoist         Nd 1.
hook MCL is 25 tons.                                           NOG-1.
Individual component parts of the hoist systems are designed to support a static load of 200% of the MCL of Individual component parts of the vertical        130 tons for the main hoist and 25 tons for the auxiliary      Design consistent hoisting system ... head block, rope reeving      hoist. The single failure point components of the main         with NUREG-system, load block ... dual-load attaching        and auxiliary hoist load and head blocks are designed to       0612 Appendix C device ... designed to support a static load of   support static loads equivalent to their respective MCLs       and ASME 200% of the MCL.                                  based upon a 10:1 factor of safety on the average              NOG- 1.
ultimate strength of the material consistent with I NUREG-0612 Appendix C and ASME NOG-1.

Turkey Point Units 3 and 4                                                                                                       L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                    Page 19 of 42 SEC #                NUREG-0554 GUIDANCE                             TURKEY POINT CRANE COMPLIANCE                                     FPL
____
___   ___
____ ___ ___
___ ___    ___    ___    ____     ___   ___    ___    ___    ___      EXCEPTIONS the main hoist sister hook All load attaching points of are statically load tested at a minimum of 260 tons (i.e. 2 200% static load test performed for hook.          times the MCL of 130 tons). The auxiliary hoist hook is statically load tested at a minimum of 50 tons (i.e. 2           No exceptions times the MCL of 25 tons).                                       noted.
Measurements of the geometric configuration        All main and auxiliary hoist hook critical dimensions are of the hooks ... before and after the load test. measured before and after the load test.
Hook volumetric nondestructive exam, to            As required by Table 7200-1 of ASME NOG- 1, an verify soundness and integrity, before and         ultrasonic examination is performed on the main and after load test. Hook surface examination, to      auxiliary hoist hooks before the proof load test and a 4.3       verify soundness and integrity, before and         magnetic particle test is performed on the hooks after the after load test.                                   proof load test.                                                 No exceptions Head and     Load block should be non-destructively             The main and auxiliary hoist load block hook, hook nut           noted.
Load Blocks    examined by surface and volumetric                 and crosshead components are non-destructively (continued)   techniques.                                        examined by surface and volumetric inspections.
Results of examinations documented and             All test reports are provided to FPL in a quality control recorded.                                          document package.

Turkey Point Units 3 and 4                                                                                                  L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                               Page 20 of 42 SEC #                   NUREG-0554 GUIDANCE                         TURKEY POINT CRANE COMPLIANCE                                   FPL EXCEPTIONS The maximum main hoist speed for critical load handling is 5 FPM, as given in CMAA Spec. #70-1975, Fig. 70.6 for slow speed and Table 533 1.1-1 of ASME Maximum hoisting speed for the critical load    NOG-1-2004.
4.4       ... limited to "slow" column of CMAA Spec.
               #70.                                            The maximum auxiliary hoist speed for critical load            No exceptions Hoisting                                                     handling is 15 FPM, as given in CMAA Spec. #70-1975,           noted.
Speed                                                        Fig. 70.6 for slow speed and Table 5331.1-1 of ASME NOG- 1-2004.
Conservative industry practice limits the rope   By design, the maximum line speed of the main hoist line speed to 50 FPM at the drum.                wire ropes is less than 50 FPM at the drums.
The design of the main and auxiliary hoists employ The reeving system designed to prevent the      redundant limit switches to prevent two-blocking and for cutting or crushing of the wire rope if a two-   defense in depth purposes, the reeving system is blocking incident were to occur.                 designed to not cut or crush the wire ropes during a two-4.5                                                       blocking event.
The mechanical and structural components of      The mechanical and structural components of the main Design      the complete hoisting system .... required       and auxiliary hoisting systems are designed to withstand      No exceptions Against     strength to resist failure ... for two-blocking  a two-block and load hang-up event without permanent          noted.
Two-       and load hang-up.                                deformation or damage and hence failure.
Blocking     Means provided within the reeving system         A mechanical slip clutch is provided in the main and located on the head or on the load-block         Amcaia               lpcuc spoie        ntemi        n combinations to absorb or control the kinetic    auxiliary hoist drive trains to absorb the kinetic energy cnergyombin   tations tomab      o erb uriontthekof       the rotating machinery during a two-blocking or load energy of rotating machinery during the          hang-up event.
_____ _____ incident of two-blocking.                       ________________________                                        _______

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 21 of 42 SEC #                NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                  FPL EXCEPTIONS As an alternative, the protective control       The design uses the alternative method, as well as the 4.5 system to prevent the hoisting from two-        capability to withstand a two-block event for both the blocking should include, as a minimum, two      main and auxiliary hoist. Primary rotary limit switch on Design independent travel-limit devices of different   the drum shaft senses both the upper and lower positions      No exceptions Against                                                                                                                   noted.
designs, and activated by separate mechanical   of load block travel and stops the motion by de-Two-means. These devices de-energize the hoist      energizing the hoist controls. The secondary lever-Blocking (continued) drive motor and the main power supply to        operated power limit switch is tripped by the lower prevent the hoist from two-blocking.            block and directly breaks power to the hoist motor.
The hoist frequency drive is programmed to only provide a margin of torque above what is required to lift the load, thereby limiting input energy into the system.
Torque demand above this value faults the drive and sets The protective control system for load hang-    the brake. Additionally, overload switches are installed up should consist of load cell systems in the   in the main and auxiliary hoist reeving systems. The drive train or motor current sensing devices or overload switches sense overloads that result from two-mechanical load-limiting devices.               blocking or load hang-up and de-energize the hoist control in the up motion. The above systems are in addition to a mechanical slip clutch installed in the hoist drive trains to absorb the energy associated with two-blocking and load hang-up.
Location of the mechanical holding brakes       The main and auxiliary hoists use two shoe-type holding and their controls should provide positive,     brakes on the high speed shafting to hold the load during reliable and capable means to stop and hold     normal operation. The hydraulic drum caliper brakes the hoisting drum.                              provide single-failure-proof braking for the design.

Turkey Point Units 3 and 4                                                                                             L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                          Page 22 of 42 SEC #                 NUREG-0554 GUIDANCE                       TURKEY POINT CRANE COMPLIANCE                                FPL EXCEPTIONS This should include capability to withstand   The maximum torque of the driving motor is limited by the maximum torque of the driving motor if a  the flux vector frequency drive. The main and auxiliary malfunction occurs and power to the driving   hoist drive trains are designed to absorb this motor cannot be shutoff.                      corresponding maximum motor torque. The hoist holding brakes are designed to stop and hold the load under all specified loading conditions.
The auxiliary hoist, if supplied, should be   The auxiliary hoist design uses the alternative method of equipped with two independent travel-limit    providing two independent travel-limit switches to switches to prevent two-blocking,             prevent two-blocking, as well as the capability to withstand a two-block event.
Lifting devices attached to the load block 4.6       such as ... designed with a dual or auxiliary Lifting devices and interfacing lift points used for device or combinations thereof. Each          handling heavy loads will meet the associated guidance      No exceptions Lifting     designed or selected to support a load of 3Xs in NUREG-0612, Section 5.1.6 and the requirements of        noted.
Devices      the load (static and dynamic) being handled   the FPL site heavy loads program.
without permanent deformation.
The main and auxiliary hoists are equipped with unbalanced load limits. When the unbalanced load 4.7       If side loads cannot be avoided, the reeving  limits are reached it will trip and the hoisting motion system should be equipped with a guard that   will be stopped. The main and auxiliary hoists are also     No exceptions Wire Rope     would keep the wire rope properly located in  equipped with drum wire rope level wind limit switches      noted.
Protection    the grooves on the drum.                      that would trip when the limits are reached and stop the hoisting motion if the wire rope did not spool properly into the drum grooves.

Turkey Point Units 3 and 4                                                                                                          L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                       Page 23 of 42 SEC #                 NUREG-0554 GUIDANCE                                  TURKEY POINT CRANE COMPLIANCE                                  FPL
______________________________EXCEPTIONS The proper functioning of the hoisting                    Component parts and the welds or bolting are designed machinery during load handling ensured by                 in accordance with CMAA Spec. #70-2004 and ASME providing adequate support strength of the                NOG-1-2004. Deflection calculations are performed 4.8       individual component parts and the welds or               under load to confirm frame deflection does not affect bolting that bind them together.                          machinery alignment.                                         No exceptions Machinery                                                               The main and auxiliary hoist designs employ gear trains      noted.
Alignment     Where gear trains are interposed between the              between the holding brakes and hoisting drums, but holdn brakes anould    the hoistinge-    drumee- f a      additionally employ hydraulic drum brakes to provide gear trains should be single-failure-proof and            single-failure-proof operation. The gear trains are dual should be of dual design.                                 and single-failure-proof.
Each holding brake of the main and auxiliary hoist is 4.9                                                                 provided with adequate capacity to stop and hold the Each holding brake should have more than                  respective full load, but not excessive to cause damage full load stopping capacity but should not                to hoisting machinery. Main and auxiliary hoisting           No exceptions Braking     have excessive capacity that could cause                  machinery is evaluated for applied brake torques for all     noted.
System      damage to the hoisting machinery,                         specified loading scenarios including normal operation, load hang-up, broken rope, two-blocking and seismic conditions.
Each holding brake of the main and auxiliary hoist is Each holding brake should have a torque                   designed with a minimum capacity of 125% of the rating not less than 125% of the full-load                deindwtamnmucpctyo12%fth torque developed during the hoisting operation at the hoisting torque at the point of application.              point of brake application.
Minimum hoisting braking system should                    The main and auxiliary hoist control systems are include one power control braking system                  provided with dynamic braking through the flux vector (not mechanical or drag brake type)...                    drive.

Turkey Point Units 3 and 4                                                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                            Page 24 of 42 SEC #                 NUREG-0554 GUIDANCE                     TURKEY POINT CRANE COMPLIANCE                                     FPL EXCEPTIONS Minimum hoisting braking system should       Two (2) shoe or disc type high speed holding brakes are include                                      provided on the high speed shafting for each of the main
               ... two holding brakes.                      and auxiliary hoist.
The holding brakes in the main and auxiliary hoisting The holding brakes should be applied when systems are applied when power is off or when a drum power is off and should be automatically overspeed occurs. The braking systems are fail-safe, i.e.
applied on overspeed to the full holding automatically activated when electrical power is position if a malfunction occurs.
removed.
No exceptions noted. A clarification is provided as Minimum number of braking systems that                                                                      follows:
should be operable for emergency lowering    The main and auxiliary hoist emergency hydraulic drum          Only the after a single brake failure should be two   brake systems are provided to allow emergency lowering          Emergency holding brakes for stopping and controlling  of a main and auxiliary hoist critical load, respectively. Drum Brake drum rotation.                                                                                               system is required to safely lower the load for the main and auxiliary hoists.

Turkey Point Units 3 and 4                                                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                            Page 25 of 42 SEC #                 NUREG-0554 GUIDANCE                         TURKEY POINT CRANE COMPLIANCE                                FPL EXCEPTIONS 4.9                                                       The main and auxiliary hoist designs employ gear trains Holding brake system should be single-between the holding brakes and hoisting drums, but failure-proof; any component or gear train                                                                  No exceptions Hoist                                                      additionally employ hydraulic drum brakes to provide should be dual if interposed between the                                                                    noted.
Braking                                                     single-failure-proof operation. The gear trains are dual holding brakes and hoist drum.
System 4
and single-failure-proof.
                                                                      -~          -
(continued)                                                   Component parts, welds, and bolting are designed in accordance with CMAA Spec. #70-2004 and ASME-Dynamic and static alignment of all hoisting NOG-1-2004, including seismic design in accordance machinery components ... range of lifted RG 1.92 and 1.61 to assure machinery alignment during loads ... positioned and anchored on the dynamic and static conditions. Deflection calculations trolley platform.
are performed under load to confirm frame deflection does not affect machinery alignment.
Provisions for manual operation of the          The main and auxiliary hoist drum emergency hydraulic hoisting brakes during an emergency             brakes can each be manually modulated for emergency condition.                                      lowering.
Adequate heat dissipation from the brakes to    The main and auxiliary hoist hydraulic brake systems preclude damage from excessive lowering         are capable of continuous lowering of the rated load at velocity.                                       minimum speed without exceeding the brake velocity,_                                  _   temperature limits.
The main and auxiliary hoist drums are supplied with remotely powered speed indicators to ensure lowering Portable instruments to indicate the lowering speeds are not excessive. The speed indicators are speed during emergency operations.
located in an area visible from where manual lowering will be performed.

Turkey Point Units 3 and 4                                                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                             Page 26 of 42 SEC #                 NUREG-0554 GUIDANCE                         TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS Only the main and auxiliary hoist emergency hydraulic Malfunction of a holding brake during           drum brakes are required to safely control the main and emergency lowering of the load ... restore      auxiliary hoist loads, respectively during emergency brake to working condition before any           lowering operations. Should a malfunction of the lowering is started.                            braking system occur, it could be restored to operation before lowering is started.
Bridge and trolley drives provided with         The bridge and trolley scalar frequency drives provide control and holding braking systems ...         controlled braking. Holding brakes located on each applied when power off.                         motor are automatically applied when power is off Bridge and trolley drives provided with         The bridge and trolley motor brakes will automatically control and holding braking systems ...         set when an overload condition is detected by the applied on overload,                            frequency drive.
Bridge and trolley drives provided with         The bridge and trolley motor brakes will automatically 5.1       control and holding braking systems ...         set in the event of a drive failure.
applied on failure in the drive system.                                                                      No exceptions Braking      Maximum torque capability of the driving        The maximum torque capacity of the driving motor and         noted.
Capacity     motor and gear reducer ... not exceed the       gear reducer for bridge and trolley motions is selected to capability of the gear train and brakes to stop not exceed the capacity of the gear train and brakes to the trolley and bridge from the maximum         stop the motion from the maximum speed with the speed with DRL attached.                        design rated load attached.
Incremental or fractional inch movements should be provided by such items as variable    Subject provision is provided for bridge and trolley via speed controls or inching motor drives,         use of scalar frequency drive controls.

Turkey Point Units 3 and 4                                                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                             Page 27 of 42 SEC #                NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                  FPL EXCEPTIONS 5.1                                                       The bridge and trolley control and holding brakes are Control and holding brakes rated at 100% of                                                                   No exceptions capable of applying a counter torque that is 100% of maximum torque that can be developed at the                                                                   noted.
Braking                                                     maximum drive torque that can be developed at the point point of application.
Capacity                                                     of application.
(continued)                                                   The trolley is provided with the A-4 drive arrangement per CMAA Spec. #70-2004. One mechanical brake is If two mechanical brakes, one for control and   provided for each drive (i.e. 2 total).
one for holding ... adjusted with one brake leading ...                                     The bridge is provided with the A-4 drive arrangement per CMAA Spec. #70-2004. One mechanical brake is provided for each drive (i.e. 2 total).
The bridge and trolley motors are provided with spring Brakes mechanically tripped to the on or        set, electrically released holding brakes that are holding position in the event of power supply   automatically applied when power is interrupted. For an malfunction or an overspeed condition.          overspeed situation, the frequency drives would sense an over voltage condition and the traverse brakes would set and prevent further travel.
Provisions made for manual emergency            The bridge and trolley brakes include a manual release operation of the brakes.                        lever to permit manual emergency operation.
Holding brake should be designed so that it     Design of the bridge and trolley holding brakes is such cannot be used as a foot-operated slowdown      that they cannot be used as a foot-operated slowdown brake.                                          brake.
Drag brakes should not be used.                 Drag brakes are not used for the bridge or trolley drives.
L                                               I                                                             -

Turkey Point Units 3 and 4                                                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                             Page 28 of 42 SEC #                 NUREG-0554 GUIDANCE                         TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS The opposite drive wheels of the bridge and trolley are Oposmatched and identical diameterso            inspected and found to be within the tolerance of +/- 0.010 inch.
The bridge and trolley speeds are in compliance with the Trolley and bridge slow speed limits of         slow operating speeds given in CMAA Specification
                                                               #70-1975 and Tables 5332.1-1The   and 5333.1-1 of ASME NOG-1 for 130 ton capacity.          bridge speed is 50 FPM and the trolley speed is 40 FPM.
Mechanical limiting devices provided to         Positive mechanical end stops will be installed on the control or prevent over travel and overspeed    runway for limiting bridge travel and on the bridge of the trolley and bridge.                      girders for limiting trolley travel.
Travel limit switches are provided for the bridge and Electrical limiting devices provided to control trolley to prevent over travel. For an overspeed or prevent over travel and overspeed of the     situation, the frequency drives would sense an over trolley and bridge.                             voltage condition and the traverse brakes would set and 5.2                                                       prevent further travel.                                      No exceptions Buffers for bridge and trolley travel should be Compression bumpers, attached to the trolley and             noted.
Safety Stops                the and olle rails,                bridge, are included for buffering contact with end of included at the end of the rails.               travel stops.
Safety devices such as limit-type switches provided for malfunction ... should be in       Trolley and bridge limit switches are provided as safety addition to and separate from the limiting      devices, in addition to the end stops and bumpers. The means or control devices provided for           switches are not intended for control of the trolley and operation.                                      bridge during normal crane operations.

Turkey Point Units 3 and 4                                                                                              L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                           Page 29 of 42 SEC #                 NUREG-0554 GUIDANCE                         TURKEY POINT CRANE COMPLIANCE                               FPL EXCEPTIONS The design of the individual components of the main and auxiliary hoisting systems are based on the maximum Horsepower rating of the hoist driving motor    torque capability (when hoisting the respective MCL at Horsmatched with the calculated ... design load maximum acceleration and rated speed) of the hoist and acceleration to the design hoisting speed. motor. The main and auxiliary hoist acceleration rates are controlled via the flux vector drive. Control of 6.1                                                       acceleration limits strain on the machinery and load-carrying devices.                                          No exceptions Driver      To preclude excessive motor torque, the         The maximum motor torque is limited by the flux vector     noted.
Selection    maximum torque capability of the electric       frequency drive, preventing excessive motor torque motor drive for hoisting should not exceed the build-up. This rated motor torque is less than the torque rating or capability of the individual          capacity of the individual hoist components under all components of the hoisting system required to normal operating conditions, ensuring the motor does hoist the MCL at the maximum design hoist       not overpower the hoist components. The main and speed. Over power and overspeed conditions      auxiliary hoists have an overspeed switch, which causes should be considered an operating hazard.       all brakes to set when tripped.

Turkey Point Units 3 and 4                                                                                                   L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                Page 30 of 42 SEC #                NUREG-0554 GUIDANCE                             TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS The hoisting motion for the main and auxiliary hoist can each be stopped within 3 inches with the respective maximum critical load at maximum design hoist speed 6.1                                                          with all brakes operating.
Controls capable of stopping the hoisting                                                                       No exceptions Driver      movement ... maximum hoisting movement             Additionally, the defense-in-depth design of the main noted.
Selection    of 3 inches an acceptable stopping distance.       and auxiliary hoist braking systems provides the (continued)                                                      capability of stopping the maximum critical load at maximum design hoist speed within 5 inches, with each of the three (3) individual brakes, being the two (2) holding brakes and one (1) emergency brake system.
The main and auxiliary hoists are designed to stop and Prudent to include safety devices in the           safely hold the load following any of the following fault control system ... to ensure the controls will     conditions: overload, overspeed, over travel, wire rope return to or maintain a safe holding position in mis-spooling, and unbalanced load. Electrical design case of malfunction. Electrical circuit design includes provisions for the effects of overvoltage, undervoltage, phase reversal, or phase loss in the hoist I power supply.
Emergency stop buttons that will remove power from all For elaborate control systems, radio control motors and set all brakes are provided on the radio
               ... an "emergency stop button" placed at transmitter and on the back-up pendant station.
ground level to remove power from the crane Additionally, a floor mounted conductor bar disconnect independent of the crane controls.
switch is provided to remove all crane power.
a.

Turkey Point Units 3 and 4                                                                                                      L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                  Page 31 of 42 SEC #                 NUREG-0554 GUIDANCE                            TURKEY POINT CRANE COMPLIANCE                                    FPL
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___ ___ ____   ___
_ ___ ___
___   ___  __    ___   ___    ___    ___    ___   ___    ___   ___     __    EXCEPTIONS For cranes with a DRL rating much higher          The DRL and MCL for the main hoist are the same at than the MCL rating ... electrical or             130 tons. The DRL and MCL for the auxiliary hoist are mechanical resetting of the overload sensing      the same at 25 tons. The trip points or set points for the device, away from the operator cab and            main and auxiliary hoist overload sensing devices are included in an administrative program.            based on 130 tons and 25 tons, respectively.
Control system provided should include            Hoisting (raising and lowering) of all loads, including consideration of the hoisting (raising and        the rated load, is considered in the design of the control lowering) of all loads, including the rated       systems for the single-failure-proof crane.
load.
Control system(s) provided should include         The effects of the inertia of the rotating hoisting 6.2       consideration of... the effects of the inertia of machinery such as motor armature, shafting and the rotating hoisting machinery, ... and drum. coupling, gear reducer, and drum are considered in the No exceptions Driver     therotatnghoistngmachinry,_..._nddrum.design of the main and auxiliary hoist control systems.
The crane will not be used to move individual spent fuel         noted.
Control Systems     Control system adaptable to include interlocks elements. The main hoist will be used predominately to lift spent fuel casks and cask components. The design that will prevent  trolley and  bridge movements while spent fuel elements are           auxiliary ahoist includes    provision  to prevent operation  duringbridge, trolley main hoist     and operation.
a reactor vessel or storage axlayhitoeaindrn                     anhitoeain rack. lifted free of being                                             An operator controlled selector switch is provided on the remote radio transmitter and cab to allow the subject feature.

Turkey Point Units 3 and 4                                                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                            Page 32 of 42 SEC #                    NUREG-0554 GUIDANCE                    TURKEY POINT CRANE COMPLIANCE                                  FPL EXCEPTIONS The main and auxiliary hoist designs employ sensors in Means provided in the motor control circuits  the motor control circuits to detect and respond to to sense and respond to such items as         excessive electrical current, excessive motor temperature excessive electric current, excessive motor   via thermostats embedded in the motor windings, over temperature, overspeed, overload, and over    travel via the hoisting limit switches, overspeed via the 6.3       travel.                                       drum overspeed limit, and overload via the weight sensing switch.                                               No exceptions Malfunction                                                  The main and auxiliary hoist dynamic braking systems          noted.
Protection    Controls should be provided to absorb the     are designed to absorb the kinetic energy of the rotating kinetic energy of the rotating machinery and  machinery and stop the hoisting motion should one rope kintop...ic energy eorone of the rotat macfail.
ing                These forces are also designed to be absorbed via systems should fail.                          the mechanical holding brake systems. The kinetic energy released during rope failure will be absorbed in the equalizer system.
The main hoist speed is variable from 0.25 FPM to 5 6.4                                                     FPM for handling a critical load via the flux vector Increment drives for hoisting may be provided frequency drive.                                              No exceptions Slow   Speed Drives      by step less controls or inching motor drive. The  auxiliary hoist speed is vable Teaxlayhitsedi                 aibefo  from 0.25  FPM to
                                                                                                           .5FMt           noted.
15 FPM for handling a critical load via the flux vector frequency drive.
If jogging or plugging is to be used, the     The frequency drives provided for crane motions control control circuit should include features to    the acceleration and deceleration of the motor and prevent abrupt change in motion.              eliminate abrupt motion changes.

Turkey Point Units 3 and 4                                                                                                    L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                 Page 33 of 42 SEC #                NUREG-0554 GUIDANCE                              TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS Drift point in the electric power system for        Drift points are not provided in the electrical power bridge or trolley movement should be                system for bridge or trolley motion.
provided only for the lowest speeds.
Bridge and trolley travel limit switches, both slow-down Safety devices such as limit-tde switches           and end of travel, are provided as safety devices, in 6.5       provided for malfunction, inadvertent               addition to the end stops and bumpers. The switches are      No exception operty atordtion o , r fpaiue shoud be   liing           not intended for control of the bridge and trolley during Safety     addition to and separate from the limiting          normal crane operations. Main and auxiliary hoist limit      noted.
Devices      means or control devices    provided  fornomlcaeprtis.Mnadaulayhitlmt switches are provided as safety devices and are not to be operation.                                          tripped during normal hoisting operations.
6.6       The complete operating control system and           A complete control system is provided with the remote provisions for emergency controls for the           radio transmitter. A back-up cab station located on theexceptions Control     overhead crane handling system should                                                                            noted.
Stations    preferably be located in a cab on the bridge.       bridge is utilized for emergency controls.
When additional operator stations are               The back-up cab station is provided with controls similar considered, they should have control systems        to those on the remote radio transmitter.
similar to the main station.
Manual controls for hoisting and trolley            The manual lowering controls for the main and auxiliary movement provided on the trolley, and for the       hoist are located on the trolley.
bridge provided on the bridge.
Remote control for any of these motions             The main hoist, auxiliary hoist, trolley and bridge should be identical to those on the bridge cab      motions are variable (analog) control from the remote control panel.                                    Iradio transmitter and the back-up cab station.

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 34 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS control station Cranes that use more than one should be provided with electrical interlocks    An electrical interlock is provided between the remote that permit only one control station to be       radio transmitter and cab control stations.
operable at any one time Main and auxiliary hoist manual control is available on the trolley. Manual movement of the bridge and trolley In the design of control systems, provision for  is possible from the runway and bridge endties, and locations of devices for control during      respectively. Emergency stop buttons are available on emergency conditions should be provided,         the remote radio transmitter and back-up cab station. A floor mounted conductor bar disconnect switch is provided to remove all crane power.
Installation instructions are provided by the crane Installation instructions should be provided by vendor, will be included in the site installation work the manufacturer.                                order package and utilized by the vendor for the 7.1                                                        installation of the new crane system.
Include  a full explanation of the crane Gncdlingsystem, a                its colntrlniiations ofThe                    operation and maintenance manual provided               No exceptions includes a full description of the crane control system. noted.
for the system.
Instructions should cover ... Requirements for   The factory and site test procedures cover all testing installation, testing, and preparations for      requirements while the operation and maintenance operation.                                       manual provided contains crane operating instructions.

Turkey Point Units 3 and 4                                                                                                    L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                 Page 35 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                    FPL EXCEPTIONS When the permanent plant crane is used for      The replacement crane system including trolley and construction and the requirements for           bridge will not be utilized in the construction of the plant construction are more severe than those for     nor for any construction lifts. The usage of the permanent plant service, the construction       replacement crane system is limited to operational load 7.2       requirements should be defined separately.      handling. The replacement crane system does not have a At the end of the construction period, the       separate construction specification.
Construction   crane shall be modified as needed for                                                                            No exceptions and       permanent plant service.                                                                                         noted.
Operating     During and after installation of the crane, the  After functional testing of the crane system and load Periods     proper assembly of electrical and structural     testing of the trolley and hoists at the factory, the crane components should be verified. The integrity     is shipped to the Turkey Point. After installation, the new of all control, operating and safety systems     crane system is inspected and tested to verify the integrity should be verified as to satisfaction of         of all control, operating and safety systems.
installation and design requirement.            _         _III

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 36 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                  FPL EXCEPTIONS In order to verify the crane's mechanical and electrical systems are properly installed, the requirements of NOG 7500 "Qualification for Permanent Plant Service," as they apply to the new crane, are used. These A complete check ... Crane's mechanical and      requirements include Section 7520 "Inspection Prior to electrical systems to verify the proper          Performance Testing," NOG 7521.2 "Mechanical installation and to prepare the crane for        Inspection," NOG 7521.3 "Electrical Inspection (Visual) testing.                                         While Crane is Immobile," and NOG 7530 which invokes the requirements of NOG 7420 "Pre-operational Testing and Inspection" and NOG 7421 "No Load Test".
These requirements exceed those required in ASME 8.1                                                        B30.2.                                                        No exceptions noted.
General Information concerning proof testing on components and subsystems ... performed at A complete functional and load test report is supplied the manufacturer's plant ... available for the after testing is complete.
checking and testing performed at the place of installation.
             &                                                I                                                             A

Turkey Point Units 3 and 4                                                                                                  L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                               Page 37 of 42 SEC #                 NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                  FPL EXCEPTIONS Exception - Site Load Testing at 125% of MCL including the transport The replacement trolley, main hoist and auxiliary hoist positions of are load tested to 125% of their respective MCL/DRL at trolley and bridge the factory to verify proper operation.
producing maximum strain 8.2       The crane system should be static load tested    Load testing of the fully assembled crane is completed in the bridge and at 125% of MCL, ... including all positions      on site to verify proper operation and structural integrity trolley structures Static and    generating maximum strain in the bridge and      of replacement bridge and runway support structure, are performed to Dynamic      trolley structures and positions recommended     respectively. Site load testing is performed at 125% of the extent Load Tests    by the designer and manufacturer                 the crane MCL/DRL. The hoist, trolley and bridge are practical based positioned during the 125% site load test to the extent on the operating possible based on the physical arrangement of the constraints of the buildings including roof openings and qualification of plant. This is in supporting floors and structures.
accordance with the practicality clauses of ASME NOG-1 and NUREG-0612.
A                                               .1

Turkey Point Units 3 and 4                                                                                                      L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                   Page 38 of 42 SEC #                NUREG-0554 GUIDANCE                               TURKEY POINT CRANE COMPLIANCE                                  FPL
___________________________________                                                                EXCEPTIONS and load tests Complete 100% and 125% performance are performed at the manufacturer's facility for the After making required adjustments resulting          replacement trolley, main hoist and auxiliary hoist. The from 125% static load test, 100% MCL                 100% and 125% performance and load tests of the fully         No exceptions performance test for all speeds and motions          assembled crane are also performed on site to the extent      noted.
for which designed. All safety and limiting          practical based on the physical arrangement of the control devices will be verified,                    building including roof openings and qualification of supporting floors and structures. All limits possible are verified during site testing.
Emergency lowering of the MCL for the main hoist and Emergency manual lowering of the load and            auxiliary hoist is demonstrated during factory load           No exceptions manual movement of the bridge and trolley            testing. Manual release of trolley and bridge brakes is       noted.
should be tested with the MCL attached.              demonstrated during factory functional testing and site functional testing.
When equipped with an energy-controlling device between load and head blocks the complete hoisting machinery is allowed to two-block (load block limit and safety devices       A two-block test of the main hoist and auxiliary hoist bypassed). Test, at slow speed and no load, to       was performed during factory functional testing at slow       No exceptions Two-Block      provide assurance of design, controls and            speed without load on the respective hooks to verify          noted.
Test       overload protective devices. Demonstrate that        proper operation of the energy controlling device and the maximum torque developed by the driving          controls.
system, including inertia of the rotating parts at the over torque condition, will be absorbed or controlled.

Turkey Point Units 3 and 4                                                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                             Page 39 of 42 SEC #                  NUREG-0554 GUIDANCE                        TURKEY POINT CRANE COMPLIANCE                                 FPL EXCEPTIONS The complete hoisting machinery tested for ability to sustain a load hang-up condition ...
load block attaching points are secure to a     The overweight limits on the main hoist and auxiliary fixed anchor or an excessive load. Crane        hoist are set and tested during factory load testing.
manufacturer ... ensure proper functioning of protective overload devices.
The crane systems are operated to verify the proper Operational tests of crane systems performed    functionality of all limit switches and other safety to verify the proper functioning of limit       devices in accordance with the requirements of NOG sw4abiitce and otherf safey devines. a7421              "No Load Test," as well as the additional 8.4       ability to perform as designed,                 requirements contained in NOG 7421.1.                        No exceptions Operational    Special arrangements may have to be made to     The main and auxiliary hoist overload sensors are tested     noted.
Test       test overload and overspeed sensing devices,    during the 125% load tests. The overspeed sensing devices are tested by reprogramming the frequency drive to cause the motor to overspeed. Actuation of the overspeed detection circuit is verified to occur at 130%
of the critical load rated speed.

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 40 of 42 SEC #                 NUREG-0554 GUIDANCE                            TURKEY POINT CRANE COMPLIANCE                               FPL EXCEPTIONS The manufacturer includes inspection and maintenance procedures in the operation and maintenance manual.
The inspections encompass the requirements necessary With good maintenance practice, degradation to assure degradation of the critical wearing components is not expected to exceed 15% of the design does not affect the crane's MCL rating.
load rating, and periodic inspection coupled with a maintenance program should ensure FPL's design change process assures that applicable that the crane is restored to the design procedures and documents including inspection and condition if such degradation is found.
maintenance procedures comply with the implemented design change and manufacturer specified inspections and maintenance.
8.5                                                        4 No exceptions noted.
Maintenance    The MCL rating of the crane should be              Wearing components in the main and auxiliary hoists established as the rated load capacity, and the    including hooks, brakes, reducers and bearings are design rating for the degradable portion of the    designed with at least a 15% increase above their handling system should be identified to obtain     respective MCL ratings to account for degradation due the margin available.                              to wear and exposure.
                                                               -4 The MCL should be plainly marked on each           The MCL rating will be marked on the bridge and each side of the crane for each hoisting unit.          side of the main and auxiliary hoist lower blocks.

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 41 of 42 SEC #                NUREG-0554 GUIDANCE                          TURKEY POINT CRANE COMPLIANCE                                   FPL EXCEPTIONS The manufacturer provides a manual of information to use for checking, testing, and operating the crane.
Crane designer and manufacturer should           Information obtained during testing is also provided in provide a manual of information and              the manual. The manual also describes a preventive procedures for use in checking, testing and      maintenance program based upon the requirements of operating the crane. Manual to describe a        OSHA 1910.179, ASME B30.2 and ASME NOG-l.
preventive maintenance program based on the      The preventive maintenance program provides the approved test results and information obtained   information required to service, repair, and replace all during testing. Include such items as ...        major trolley and hoist components. Additionally, 9        Operating requirements for all travel            where applicable, visual examinations, equipment movements ... Clearly defined...                 diagnostics, and nondestructive examinations are              No exceptions Operating                                                      described in the manual. The manual also describes            noted.
Manual                                                       operating features and limitations.
The allowed rope degradation margin is in accordance with ASME B30.2.
The designer should establish the MCL rating     The allowed hook degradation margin is in accordance and the margin for degradation of wear           with ASME B30.10.
susceptible component parts.
The allowed brake degradation is in accordance with the brake manufacturer's recommendations, included with the maintenance manual.
a                                                L                                                             I

Turkey Point Units 3 and 4                                                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                              Page 42 of 42 SEC #                  NUREG-0554 GUIDANCE                       TURKEY POINT CRANE COMPLIANCE                                   FPL EXCEPTIONS A quality assurance program should be          FPL approved the crane manufacturer's quality plan which established to include the recommendations of  establishes the requirements and responsibilities for this report for the design, fabrication,       control of the design, fabrication, installation and testing installation, testing and operation of crane   of the replacement crane. FPL's 10 CFR 50, Appendix B handling systems for safe handling of critical program addresses these requirements as well as testing load.                                          and operation at the site.
Applicable procurement documents should require the crane manufacturer to provide a    The crane manufacturer's quality program was accepted 10        quality assurance program consistent with the  by FPL and met the applicable requirements of 10 CFR pertinent provisions of Regulatory Guide       50, Appendix B. The applicable requirements are                No exceptions Quality      1.28, to the extent necessary. Program to     invoked in the procurement documents.                          noted.
Assurance     address NUREG-0554.
Program should address all recommendations     The quality assurance plan addresses all areas of concern in this report.                                including the critical components of the crane system.
General qualification requirements for crane operators, including the requirements of ASME B30.2, are Include qualification requirements for crane   included in the operation and maintenance manual to operators.                                     assist FPL in developing operator standards.
Additionally, operator and maintenance training Is provided by the crane manufacturer on-site.}}