View source for L-2025-019, License Amendment Request 280, Extend Implementation Date for Amendment No. 291 Regarding Revised Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project

{{Adams
| number = ML25036A099
| issue date = 02/04/2025
| title = License Amendment Request 280, Extend Implementation Date for Amendment No. 291 Regarding Revised Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project
| author name = Mack K
| author affiliation = Florida Power &amp; Light Co
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000251
| license number = DPR-041
| contact person = 
| case reference number = L-2025-019
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 1
| project = 
| stage = Request
}}

=Text=
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l=PL.
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 RE:
Turkey Point Nuclear Generating Station, Unit 4 Docket No. 50-251 Renewed Facility Operating License DPR-41 February 4, 2025 L-2025-019 10 CFR 50.90 License Amendment Request 280, Extend Implementation Date for Amendment No. 291 Regarding Revised Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project 

==References:==
: 1.
USN RC letter to Florida Power & Light Company, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Issuance of Amendment Nos. 298 and 291 Regarding Revising the Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project (EPID: L-2022-LLA-0128), January 22, 2024 (ADAMS Accession No. ML23320A306)
: 2.
USN RC letter to Florida Power & Light Company, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Correction of Safety Evaluation for Issuance of Amendment Nos. 298 and 291 Regarding Revising the Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project (EPID L-2022-LLA-0128), June 26, 2024 (ADAMS Accession No. ML24159A265)
Florida Power & Light Company (FPL) hereby requests an extension of the implementation date specified in Amendment 291 to Subsequent Renewed Facility Operating License (SRFOL) DPR-41 from refueling outage (RFO) 4R35 (spring 2025) to RFO 4R36 (spring 2027) for Turkey Point Nuclear Generating Station (Turkey Point), Unit 4. In Reference 1, as supplemented by Reference 2, Amendment Nos. 298 and 291 to SRFOLs DPR-31 and DPR-41 were issued to Turkey Point, Units 3 and 4, respectively. The amendments revise the Turkey Point Fire Protection Program (FPP) in support of a new reactor coolant pump (RCP) seal design. FPL requested the amendments in accordance with Turkey Point Operating License Condition 3.D, "Fire Protection" regarding FPP changes that do not require prior NRG approval.
FPL now proposes Amendment 291 implementation during Turkey Point Unit 4 RFO 4R36 (spring 2027) in lieu of RFO 4R35 (spring 2025) as currently specified. No change is proposed to the Turkey Point Unit 3 scheduled implementation of Amendment 298 during RFO 3R35 (spring 2026).
The enclosure to this letter provides FPL's evaluation of the proposed change. No changes are proposed to the Turkey Point Technical Specifications (TS) or the TS Bases.
FPL has determined that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and there are no significant environmental impacts associated with the proposed change. The Turkey Point Onsite Review Group has reviewed the proposed license amendments.
In accordance with 10 CFR 50.91 (b)(1 ), a copy of the proposed license amendments is being forwarded to the State designee for the State of Florida.
FPL requests the proposed change is processed on an expedited basis with approval before completion of Turkey Point Unit 4 RFO 4R35, which is scheduled to begin March 2025. Once approved, the amendment shall be implemented during Turkey Point Unit 4 RFO 4R36, currently scheduled in spring 2027.
Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035 

Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 This letter contains no new or revised regulatory commitments.
L-2025-019 Page 2 of 2 Should you have any questions regarding this submission, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 4th day of February 2025. 
. Mack Direct, Licensing and Regulatory Compliance Florida Power & Light Company cc:
USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Mr. Clark Eldredge, Florida Department of Health 

==Enclosure:==
Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 Turkey Point Nuclear Plant Unit 4 License Amendment Request 280 Extend Implementation Date for Amendment No. 291 Regarding L-2025-019 Enclosure Page 1 of 6 Revised Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project 1.0 

==SUMMARY==
DESCRIPTION............................................................................................................. 2 2.0 DETAILED DESCRIPTION.............................................................................................................. 2 2.1 Background......................................................................................................................... 2 2.2 Current Requirements/ Description of the Proposed Change............................................ 2 2.3 Reason for the Proposed Change....................................................................................... 3 

==3.0 TECHNICAL EVALUATION==
............................................................................................................ 3 

==4.0 REGULATORY EVALUATION==
........................................................................................................ 3 4.1 Applicable Regulatory Requirements/Criteria..................................................................... 3 4.2 Precedent............................................................................................................................ 4 4.3 No Significant Hazards Consideration................................................................................4 4.4 Conclusion........................................................................................................................... 5 

==5.0 ENVIRONMENTAL CONSIDERATION==
........................................................................................... 5 

==6.0 REFERENCES==
................................................................................................................................. 5 

Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 1.0 

==SUMMARY==
DESCRIPTION L-2025-019 Enclosure Page 2 of 6 Florida Power & Light Company (FPL) requests an extension of the implementation date specified in Amendment 291 to Subsequent Renewed Facility Operating License (SRFOL) DPR-41 from refueling outage (RFO) 4R35 (spring 2025) to RFO 4R36 (spring 2027) for Turkey Point Nuclear Generating Station (Turkey Point), Unit 4. In Reference 6.1, as supplemented by Reference 6.2, Amendment Nos. 298 and 291 to SRFOLs DPR-31 and DPR-41 were issued to Turkey Point, Units 3 and 4, respectively. The amendments revise the Turkey Point Fire Protection Program (FPP) in support of a new reactor coolant pump (RCP) seal design. FPL requested the amendments in accordance with Turkey Point Operating License Condition 3.D, "Fire Protection" regarding FPP changes that do not require prior NRC approval.
2.0 DETAILED DESCRIPTION 

===2.1 Background===
Turkey Point Units 3 and 4 are each equipped with three Westinghouse Model 93 RCPs with Flowserve NX design RCP seals. The seal design consists of three identical hydrodynamic mechanical stages in series and an abeyance (aka shutdown) seal designed to stop leakage from the upper, third stage seal for an indefinite period. Each seal is designed to withstand full RCS pressure. The seals were first installed during the Unit 3 fall 2015 and Unit 4 spring 2016 refueling outages. The NX seals replaced the previous seal design as was necessary to cope with a beyond design basis event with an extended loss of AC power (ELAP). The NX seal design has performed reliably as a single-cycle seal over the past several fuel cycles.
In 2015, Amendments 262 and 257 (Reference 6.3) authorized the transition to National Fire Protection Association Standard (NFPA) 805 as the basis for the Turkey Point Fire Protection Program (FPP). The transition implemented the use of a fire probabilistic risk assessment (PRA) model specific to the RCP seal design whereby the reduction in seal leakage increases the operator response time to reduce the evaluated risk for the fire damage scenarios.
In 2019, Turkey Point Amendments 286 and 280 (Reference 6.4), authorized the use of WCAP-16175-P-A (Reference 6.5) to model the RCP seals in the Fire PRA. Using human error probability values associated with the reduced time to trip the RCPs on loss of seal cooling, the Fire PRA was updated by adjusting the RCP seal failure probabilities with those presented in WCAP-16175-P-A for the Turkey Point seal design.
In 2024, Turkey Point Amendments 298 and 291 (Reference 6.1 and 6.2), authorized the FPP change associated with the installation of the Framatome RCP hydrostatic seal package equipped with the Passive Shutdown Seal (PSDS). The seal design consists of three mechanical shaft seals arranged in series along with a fourth seal, PSDS, which improves the ability to control RCP seal leakage during ELAP and station blackout (SBO) events. The PSDS actuates in response to the temperature rise that takes place within the seal assembly to seal the reactor coolant leak path between the pump shaft and the lower seal housing.
Amendments 298 and 291 only addressed the Fire PRA change to the FPP associated with the installations of the Framatome RCP Hydrostatic Seal with PSDS, consistent with Turkey Point Operating License Condition 3.D, "Fire Protection". No other attribute of the seal installations require prior NRC approval.
2.2 Current Requirements/ Description of the Proposed Change Amendment No. 291 (References 6.1 and 6.2) states that the license amendment is effective as of the date of issuance (January 22, 2024) and shall be implemented by the completion of refueling outage 4R35 (spring 2025) for Turkey Point Unit 4.
The proposed change would extend the implementation schedule for Amendment No. 291 from refueling outage 4R35 (spring 2025) to refueling outage 4R36 (spring 2027) for Turkey Point Unit 4. 

Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 2.3 Reason for the Proposed Change L-2025-019 Enclosure Page 3 of 6 Due to unforeseen circumstances, vendor fabrication of the RCP seal conversion equipment is delayed, preventing timely site delivery and thereby, orderly outage planning and scheduling. 

==3.0 TECHNICAL EVALUATION==
In Reference 6.6, as supplemented by References 6. 7 through 6.10, FPL requested authorization to modify the Turkey Point Fire PRA in support of a proposed transition to a new RCP seal design. The conclusions of FPL's Fire PRA evaluation determined that the seal replacement is maintenance level update rather than a Fire PRA upgrade, but required prior NRG approval. In addition to the impacts associated with the new seal design, the Fire PRA was also modified to include new and modified fire scenarios in accordance with the latest NRG endorsed guidance and industry standards. In Amendment Nos. 298 and 291, the NRG staff concluded that the Fire PRA change in support of the new RCP seal design results in a small increase in risk but has no impact on the defense-in-depth relative to fire protection and maintains adequate safety margin. Consistent with FPL's requested implementation schedule, Amendment No. 291 specified an implementation date of refueling outage 4R35 (spring 2025) for Turkey Point Unit 4.
The conversion to the new RCP seal design is a complex modification necessitating, amongst other changes, replacement of the rotating assembly seal housing and seal water injection piping, thereby requiring detailed planning, scheduling and equipment staging. Due to unforeseen circumstances, vendor fabrication of the seal conversion equipment is delayed.
Given the impracticality of completing the conversion without the requisite equipment on site well in advance of the scheduled outage, NextEra chooses to complete the scheduled rotating assembly replacements but install another set of Flowserve NX seals during the Unit 4 spring 2025 outage. The rotating assembly replacements will serve to reduce the installation scope and duration for the new RCP seal conversion during the following spring 2027 outage. As stated above, the Flowserve NX seal has performed reliably as a single-cycle seal during the past fuel cycles. Since the current FPP reflects the current seal design, operating for an additional cycle will not present new or heightened operational risk.
4.0 REGULA TORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.48(a) states that each holder of an operating license issued under this part or a combined license issued under part 52 of this chapter must have a fire protection plan that satisfies Criterion 3 of appendix A to this part.
10 CFR 50.48(c)(3)(ii) states that the licensee shall complete its implementation of the methodology in Chapter 2 of NFPA 805 (including all required evaluations and analyses), and upon completion, modify its fire protection plan required by paragraph ( a) of this section to reflect the licensee's decision to comply with NFPA 805, before changing its fire protection program or the nuclear power plant as permitted by NFPA 805."
General Design Criteria (GDC) 3, Fire Protection, of Appendix A to 10 CFR 50 states, in part, that structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.
Regulatory Guide (RG) 1.205 provides guidance for licensees to use in complying with the requirements of 10 CFR 50.48(c) for performance-based fire protection programs. 

Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 L-2025-019 Enclosure Page 4 of 6 The proposed license amendment will not contravene the requirements 10 CFR 50.48(a) and 10 CFR 50.48(c)(3)(ii), and will not alter the manner in which Turkey Point is operated and maintained consistent with GDC 3. All applicable requirements will continue to be satisfied as a result of the proposed change.
4.2 Precedent In Reference 6.11, Amendment Nos. 211, 211, and 211 were issued for Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively. The amendments extended the respective implementation dates associated with an approved risk-informed completion time (RICT) program.
The licensee requested the extensions due to unforeseen circumstances that required additional personnel resources to implement the RICT TS.
In Reference 6.12, Amendments 267 and 317 were issued for Arkansas Nuclear One (ANO), Units 1 and 2, respectively. The amendments extended the respective implementation dates associated with a revision to the ANO Emergency Action Level Scheme. The licensee requested the extensions due to unforeseen circumstances that resulted from an unplanned, extended unit outage.
4.3 No Significant Hazards Consideration Florida Power & Light Company (FPL) requests an extension of the implementation date specified in Amendment 291 to Subsequent Renewed Facility Operating License (SRFOL) DPR-41 from refueling outage (RFO) 4R35 (spring 2025) to RFO 4R36 (spring 2027) for Turkey Point Nuclear Generating Station (Turkey Point), Unit 4. In Reference 1, as supplemented by Reference 2, Amendment Nos. 298 and 291 to SRFOLs DPR-31 and DPR-41 were issued to Turkey Point, Units 3 and 4, respectively. The amendments revise the Turkey Point Fire Protection Program (FPP) in support of a new reactor coolant pump (RCP) seal design. FPL requested the amendments in accordance with Turkey Point Operating License Condition 3.D, "Fire Protection" regarding FPP changes that do not require prior NRC approval.
As required by 1 O CFR 50.91 (a), FPL has evaluated the proposed change using the criteria in 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration.
An analysis of the issue of no significant hazards consideration is presented below:
(1)
Do the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change would extend the implementation date for Amendment No. 291 from refueling outage (RFO) 4R35 (spring 2025) to RFO 4R36 (spring 2027) for Turkey Point Unit 4.
Since the current FPP reflects the current RCP seal design, the proposed change neither alters plant equipment nor the manner in which plant equipment is operated and maintained, and thereby cannot increase the probability of an accident. The proposed change cannot affect the type or quantity of radioactive effluent that may be released or increase occupational exposures resulting from any accident, and thereby cannot increase the consequences of a previously evaluated accident. The proposed change is an administrative change with no technical or safety aspects.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
(2)
Do the proposed amendments create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No 

Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 L-2025-019 Enclosure Page 5 of 6 The proposed change would extend the implementation schedule for Amendment No. 291 for Turkey Point Unit 4, and is thereby an administrative change with no technical or safety aspects. The proposed change neither installs new equipment nor introduces new equipment failure modes and thereby cannot introduce a new or different type of malfunction or accident. The proposed change does not create or revise any safety analysis inputs or projections and thereby cannot create new accident initiators or precursors.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.
(3)
Do the proposed amendments involve a significant reduction in a margin of safety?
Response: No The proposed change would extend the implementation schedule for Amendment No. 291 for Turkey Point Unit 4, and is thereby an administrative change with no technical or safety aspects. The proposed change does not alter the approach to any safety limits, limiting safety system settings, or safety analysis assumptions or inputs, and thereby cannot affect plant operating margins. The proposed change does not modify the design and capability of equipment credited in safety analyses, or introduce new energy sources, and thereby cannot affect the integrity of any radiological barrier.
Therefore, the proposed amendments do not involve a significant reduction in a margin of safety.
Based upon the above analysis, FPL concludes that the proposed license amendment does not involve a significant hazards consideration, under the standards set forth in 10 CFR 50. 92, "Issuance of Amendment,"
and accordingly, a finding of "no significant hazards consideration" is justified.
4.4 Conclusion Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. 

==5.0 ENVIRONMENTAL CONSIDERATION==
Florida Power & Light Company (FPL) has evaluated the proposed amendments for environmental considerations and determined that the proposed amendments would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments. 

==6.0 REFERENCES==
6.1 USN RC letter to Florida Power & Light Company, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Issuance of Amendment Nos. 298 and 291 Regarding Revising the Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project (EPID: L-2022-LLA-0128), January 22, 2024 (ADAMS Accession No. ML23320A306) 

Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 L-2025-019 Enclosure Page 6 of 6 6.2 USNRC letter to Florida Power & Light Company, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Correction of Safety Evaluation for Issuance of Amendment Nos. 298 and 291 Regarding Revising the Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project (EPID L-2022-LLA-0128), June 26, 2024 (ADAMS Accession No. ML24159A265) 6.3 USNRC letter to Florida Power & Light Company, Turkey Point Nuclear Generating Unit Nos. 3 and 4, Issuance of Amendments Regarding Transition to a Risk-Informed Performance-Based Fire Protection Program in Accordance with Title 10 of the Code of Federal Regulations Section 50.48(c),
(TAC Nos. ME8990 and ME8991), May 28, 2015 (ADAMS Accession No. ML15061A237) 6.4 USN RC letter to Florida Power & Light Company, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Issuance of Amendments Regarding Transition License Conditions for Reactor Coolant Pump Seals (EPID L-2018-LLA-0280), March 27, 2019 (ADAMS Accession No. ML19064A903) 6.5 USNRC letter to Westinghouse Owners Group, Final Safety Evaluation for Pressurized Water Reactor Owners Group (PWROG) Topical Report WCAP-16175-P-A, Rev. 0, (CE NPSD-1199, Revision 1) "Model for Failure of RCP Seals Given Loss of Seal Cooling in CE NSSS Plants,"
February 12, 2007 (ADAMS Accession No. ML070240429) 6.6 Florida Power & Light Company letter L-2022-110, License Amendment Request 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project, August 26, 2022 (ADAMS Accession Nos. ML22243A161, ML22243A162) 6.7 Florida Power & Light Company letter L-2023-069, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project, May 31, 2023 (ADAMS Accession Nos.
ML23151A607, ML23151A608) 6.8 Florida Power & Light Company letter L-2023-094, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project July 27, 2023 (ADAMS Accession No. ML23208A191) 6.9 Florida Power & Light Company letter L-2023-110, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project, August 25,2023 (ADAMS Accession Nos.
ML23240A153, ML23240A154) 6.10 Florida Power & Light Company letter L-2023-156, Supplement to Response to Request for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project, October 31, 2023 (ADAMS Accession No. M L23304A 156) 6.11 USN RC letter to Arizona Public Service Company, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Issuance of Amendment Nos. 211, 211, and 211 to Extend Implementation Date for Amendment Nos. 209, 209, and 209 Associated with Initiative 4b That Permit the Use of Risk-Informed Completion Times on the Technical Specifications (EPID L-2019-LLA-0289), February 10, 2020 (ADAMS Accession No. ML20016A458) 6.12 USNRC letter to Arkansas Nuclear One, Units 1 and 2 - Issuance of Amendment Nos. 267 and 317 to Extend Implementation Dates for Amendment Nos. 263 and 314 - Revision to Emergency Action Level Scheme (EPID L-2019-LLA-0192), October 22, 2019 (ADAMS Accession No. ML19269b672)}}