View source for L-2010-197, Response to Request for Additional Information Regarding Alternative Source Term License Amendment Request (LAR) 196 and Proposed Changes to Technical Specification (TS) 3/4.7.5 on Control Room Emergency Ventilation System

{{Adams
| number = ML102630160
| issue date = 09/15/2010
| title = Response to Request for Additional Information Regarding Alternative Source Term License Amendment Request (LAR) 196 and Proposed Changes to Technical Specification (TS) 3/4.7.5 on Control Room Emergency Ventilation System
| author name = Kiley M
| author affiliation = Florida Power &amp; Light Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000250, 05000251
| license number = 
| contact person = 
| case reference number = L-2010-197, TAC ME1624, TAC ME1625
| document type = Letter type:L
| page count = 18
| project = TAC:ME1624, TAC:ME1625
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:0 FPL.
SEP 15 2010 L-2010-197 POWERING TODAY.                                                                   10 CFR 50.90 EMPOWERING TOMORROW.0 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re:       Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196 and Proposed Changes to Technical Specification (TS) 3/4.7.5 on Control Room Emergency Ventilation System (CREVS) (TAC NOS. ME1624 and ME1625)

==References:==

(1) W. Jefferson (FPL) to U.S. Nuclear Regulatory Commission (L-2009-133),
              "License Amendment Request 196: Alternative Source Term and Conforming Amendment," Accession No. ML092050277, June 25, 2009.
(2) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-083),
              "Supplement to License Amendment Request (LAR) 196 and 3/24/2010 Request for Additional Information Regarding Alternative Source Term (AST) (TAC Nos.
ME1624 and ME1625)," Accession No. ML101450028, May 21, 2010 (3) Email from J. Paige (NRC) to S. Franzone (FPL), "Draft RAIs RE AST LAR,"
Accession No. ML102440185, August 25, 2010 By letter L-2009-133 dated June 25, 2009 [Reference 1], Florida Power and Light (FPL) requested to amend Facility Operating Licenses DPR-31 and DPR-41 and revise the Turkey Point Units 3 and 4 Technical Specifications (TS). The proposed amendments revise the TS to adopt the alternative source term (AST) as allowed in 10 CFR 50.67.
By letter L-2010-083 dated May 21, 2010 [Reference 2], FPL provided its response to NRC concerns over the current TS language in TS 3/4.7.5, Control Room Emergency Ventilation System (CREVS). In its response, FPL proposed TS changes consistent with the approach given in the Westinghouse Standard Technical Specifications (STS) as well as plant modifications intended to increase overall system reliability and availability.
Additional information regarding the proposed TS 3/4.7.5 changes was requested by the NRC staff via email dated August 25, 2010 [Reference 3]. The attachment to this letter provides the FPL response to the questions from the NRC staff.
In accordance with 10 CFR 50.91(b)(1), a copy of this letter is being forwarded to the State Designee of Florida.
A-Do!
an FPL Group company

Turkey Point Units 3 and 4                                                      L-2010-197 Docket Nos. 50-250 and 50-251                                                    Page 2 of 2 This submittal does not alter the significant hazards consideration previously submitted by FPL letter L-2010-083 [Reference 2] nor does it alter the environmental assessment previously submitted by FPL letter L-2009-133 [Reference 1].
This submittal contains two new FPL commitments and no revisions to existing commitments. The first new commitment is to perform a tracer gas test of the Control Room Envelope (CRE) prior to the implementation of the new CREVS TS changes. The second commitment is to design the compensatory filtration unit in accordance with the Class I Structures, Systems, and Equipment Design Requirements defined in Appendix 5A of the Turkey Point Updated Final Safety Analysis Report (UFSAR).
Should you have any questions regarding this submittal, please contact Mr. Robert J.
Tomonto, Licensing Manager, at (305) 246-7327.
I declare under penalty of perjury that the foregoing' is true and correct.
Executed on September          , 2010.
Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant Attachment cc:     USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Resident Inspector, Turkey Point Nuclear Plant Mr. W. A. Passetti, Florida Department of Health

Turkey Point Units 3 and 4                                        L-2010-197 Docket Nos. 50-250 and 50-251                                      Attachment Page I of 16 Attachment Response to 8/25/2010 RAI Regarding AST LAR 196 and Proposed Changes to TS 3/4.7.5 CREVS

Turkey Point Units 3 and 4                                                                 L-2010-197 Docket Nos. 510-250 and 50-251                                                             -Athachment Page 2 of 16 Response to Request for Additional Information The following information is provided by Florida Power & Light (FPL) in response to the U. S.
Nuclear Regulatory Commission's (NRC) Request for Additional Information (RAI). This information was requested to support License Amendment Request (LAR) 196, Alternative Source Term (AST) and Conforming Amendment, for Turkey Point Nuclear Plant (PTN) Units 3 and 4 that was submitted to the NRC by FPL via letter (L-2009-133) dated June 25, 2009 [Reference 1].
By letter L-2010-083 dated May 21, 2010 [Reference 2], FPL provided a response to NRC concerns over the current language in Technical Specification (TS) 3/4.7.5, Control Room Emergency Ventilation System (CREVS). In this response, FPL proposed TS changes consistent with the approach given in the Westinghouse Standard Technical Specifications (STS) as well as plant modifications intended to increase redundancy of key system components and functions, thereby increasing overall system reliability and availability. The response states that "The proposed plant modifications to the CREVS include installation of a compensatory filtration unit that may be manually placed into service in the event that the installed filter train becomes inoperable. The proposed location for the new filter unit is in the purge fan room adjacent to the southeast corner of the Control Room and will be designed as a safety-related, Seismic Class I backup to the installed system. This location is currently outside of the control room envelope and post maintenance testing will assure the leak tightness of the system. The new filtration unit design is currently planned to include a recirculation fan, charcoal and high efficiency particulate air filters and capable of being powered off of the swing bus from the EDGs."
By letter L-2010-131 dated June 23, 2010 [Reference 3], FPL retracted a proposed change to the methyl iodide penetration criteria in TS 4.7.5.c (2) that was included in the original AST LAR submittal [Reference 1] in response to a NRC comment made in the June 7, 2010 public meeting.
In an email dated August 25, 2010 [Reference 4], the NRC staff requested additional information regarding FPL's request to adopt the Alternate Source Term. The questions consisted of nine (9)
RAIs from NRC's Containment and Ventilation (RAIs 1-8) and Mechanical Engineering (RAI 9)
Branches on AST LAR 196 regarding the proposed changes to TS 3/4.7.5, Control Room Emergency Ventilation System (CREVS) and associated plant modifications that include the installation of a new compensatory filtration unit. Each of the nine (9) questions is documented below with the applicable FPL response.
: 1. Will the stated post maintenance testing be conducted in accordance with an NRC accepted standard such as ASTM E741? If not, what standard will be used?
FPL is committed to a Control Room Habitability (CRH) Program and the program requirements will be followed. The program includes requirements (consistent with GL 2003-01 and NEI 99-03) for periodic performance of a tracer gas test in accordance with ASTM E741. Post maintenance testing of the CREVS and the Control Room Envelope (CRE) will be conducted after completion of the proposed modifications to assure the functionality and integrity of the affected system, system components, and control room boundary prior to returning the system to service. In addition, a tracer gas test will be performed after satisfactory completion of appropriate post maintenance testing of the CREVS and compensatory filtration unit in order to implement the CREVS TS amendment.
Installation of the unit is expected to be completed as a non-outage activity in late 2011.

Turkey Point Units 3 and 4                                                                       L-2010-197 Docket Nos. 50-250 and 50-251                                                                    Attachment Page 3 of 16
: 2. In the May 21, 2010 letter you stated the proposed location of the compensatory filter unit is currently outside of the control room envelope (CRE) and post maintenance testing will assure the leak tightness of the system. How will leak tightness be assured?
The compensatory filtration unit is expected to be treated as an extension of the CRE. The ductwork outside of the control room boundary attached to the compensatory unit will be of welded construction. Manual "bubble tight" dampers will be used to isolate the unit from the rest of the system when the unit is not in operation and will be periodically inspected and tested. The filter housing will be pressure tested at the factory. Additional design provisions including the incorporation of test ports are being considered to facilitate onsite leak testing of the filter housing. Post maintenance testing will include functional and pressure boundary testing of the unit and affected CRE penetrations and isolation of the compensatory filtration unit prior to returning the system to service. As indicated in the response to RAI #1 above, a tracer gas test will be performed to rebaseline the CRE inleakage and will include the testing of the CREVS emergency (recirculation) mode and compensatory filtration unit alignments.
: 3. The proposed location of the compensatory filtration unit is outside the CRE and will be manually placed into service. How can this be accomplished without invalidating the results of the current ASTM E741 tracer gas test?
The compensatory filtration unit is outside of the existing CRE but, as discussed in the response to RAI #2 above, it will be treated as an extension of the CRE. The unit is normally isolated from the rest of the CREVS by manual "bubble tight" dampers. The unit must be manually aligned and its fan manually started in order to be placed in service. As indicated above, a tracer gas test will be performed to rebaseline CRE inleakage and include testing of CREVS emergency (recirculation) mode and compensatory filtration unit alignments..
: 4. Will the surveillance requirements for technical specification (TS) 3/4.7.5 be updated to include the compensatory filtration unit?
The compensatory filtration unit is not included in TS 3/4.7.5 LCO and, therefore, is not directly subject to its associated surveillance requirements since it is considered a mitigating action rather than a restoration of TS operability for the system. Nonetheless, maintenance of the unit will be conducted in a manner consistent with applicable surveillance requirements imposed on the normal CREVS filter train (TS 4.7.5.b, c and d) in order to assure its ability to maintain control room occupant radiological exposures within limits if utilized during a design basis accident. In addition, a footnote will be added to these TS surveillance requirements that will state "As the mitigating actions of TS 3.7.5.a.5 may include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room, and TS 4.7.5.c and d." See attached Figures 1 and 2 for markups of the proposed changes to the TS and TS Bases.
TS Change: TS 4.7.5 Surveillance Requirements Current (as previously submitted in L-2010-083 and as revised in L-2010-131) 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:
: a. At least once per 12 hours by verifying that the control room air temperature is less than or equal to 120'F; b.At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes;

Turkey Point Units 3 and 4                                                                           L-2010-197 Docket Nos. 50-250 and 50-25 F                                                                       Attachment Page 4 of 16
: c. At least once per 18 months or (1) after 720 hours of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (3) following operational exposure of the filters to effluents from painting, fire, or chemical release in any ventilation zone communicating with the system, or (4) after complete or partial replacement of a filter bank by:
: 1) Verifying that the air cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of greater than or equal to 99% DOP and halogenated hydrocarbon removal at a system flow rate of 1000 cfm +10%.
: 2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, and analyzed per ASTM D3803 - 1989 AT 30'C and 95%
relative humidity, meets the methyl iodide penetration criteria of less than 2.5% or the charcoal be replaced with charcoal that meets or exceeds the stated performance requirement, and
: 3) Verifying by a visual inspection the absence of foreign materials and gasket deterioration.
d.At least once per 12 months by verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 1000 cfm +10%;
: e. At least once per 18 months by verifying that on a Containment Phase "A" Isolation test signal the system automatically switches into the recirculation mode of operation.
: f. Perform system flow balancing within 12 hours following CREVS component maintenance affecting system performance, e.g., filter replacement, fan or damper adjustment.
Proposed TS 4.7.5 Surveillance Requirements 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:
: a. At least once per 12 hours by verifying that the control room air temperature is less than or equal to 120'F; b.At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes***;
: c. At least once per 18 months or (1) after 720 hours of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (3) following epe,.ationa. exposure of the filters to effluents from painting, fire, or chemical release in any ventilation zone communicating with the system that may have an adverse effect on the fiinctional capability of the system, or (4) after complete or partial replacement of a filter bank by:
: 1) Verifying that the air cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of greater than or equal to 99% DOP and halogenated hydrocarbon removal at a system flow rate of 1000 cfm +10%***.
: 2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, and analyzed per ASTM D3803 - 1989 at 30'C and 95%
relative humidity, meets the methyl iodide penetration criteria of less than 2.5% or the charcoal be replaced with charcoal that meets or exceeds the stated performance requirement***, and

Turkey Point Units 3 and 4                                                                        L-2010-197 Docket Nos. 50-250 and 50-251                                                                     Attachment Page 5 of 16
: 3) Verifying by a visual inspection the absence of foreign materials and gasket deterioration***.
: d. At least once per 12 months by verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 1000 cfrn +10%***;
: e. At least once per 18 months by verifying that on a Containment Phase "A" Isolation test signal the system automatically switches into the recirculation mode of operation.
: f. At least once per 18 months by verifying operabilityof the kitchen and toilet area exhaust dampers.
        *As the mitigatingactions of TS 3.7.5 Action a.5 may include the use of the compensatoiyfiltration unit, the unit shall meet the surveillance requirementsof TS 4.7.5. b. by manual initiationfirom outside the control room, and TS 4. 7.5. c and d.
Justification The deletion of the term "operational" from TS 4.7.5.c (3) and inclusion of the additional descriptive text are necessary to remove an identified inconsistency with the current regulatory guidance given in RG 1.52 Rev 3 regarding communication with the system. The addition of footnote is appropriate as the maintenance of the compensatory filtration unit must satisfy the applicable surveillance requirements imposed on the normal CREVS filter train (TS 4.7.5.b, c and d) in order to assure its operational readiness. The revision to TS 4.7.5.f is necessary to correct an inadvertent change to the language of the surveillance requirement introduced during retraction of the proposed change to the methyl iodide penetration criteria in L-2010-13 I on June 23, 2010. The revised language restores that originally proposed in L-2010-083 on May 21, 2010.
: 5. Will the charcoal in the compensatory filtration unit be tested in accordance with the testing methods and at the frequencies specified for the charcoal in the CREVS?
Yes. TS 4.7.5.b, c and d surveillance requirements will be applied to the compensatory filtration unit. See response to RAI 4.
: 6. On page 6 of 24 under SURVEILLANCE REQUIREMENTS item c. states "At least" once per 18 months or (1) after 720 hours of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal absorber housing, or (3) following operational exposure of the filters to effluents from painting, fire or chemical releases in any ventilation zone communicating with the system, or (4) after complete or partial replacement of a filter bank by...". In this context, what is the meaning of "operational"? This appears to be inconsistent with the NRC staff's intent when discussing ventilation zones communicating with systems (see Regulatory Guide 1.52 Revision 3, June 2001, Regulatory Position C.6.3 footnote 8).
The surveillance requirements of TS 4.7.5 specify compliance with RG 1.52, Rev 2. TS 4.7.5.c states "The Control Room Emergency Ventilation System shall be demonstrated OPERABLE ... following operational exposure of the filters to effluents from painting, fire, or chemical release in any ventilation zone communicating with the system." The term "operational" is used in the current TS language to provide clarification as to when such activities are to be considered in communication with the system. This language is consistent with RG 1.52, Rev 2 noting that it does not have the cited footnote defining communication.

Turkey Point Units 3 and 4                                                                         L-2010-197 Docket Nos. 50-250 and 50-251                                                                      Attachment Page 6 of 16 RG 1.52, Rev 3, Section 6.3 states "tests should be performed... following painting, fire, or chemical release in any ventilation zone communicating with the system that may have an adverse effect on the functional capability of the system.'8" Footnote 8 states "Painting, fire, or chemical release is 'not communicating' with the HEPA filter or adsorber if the ESF atmosphere cleanup system is not in operation, the isolation dampers for the system are closed, and there is no pressure differential across the filter housing. This provides reasonable assurance that air is not passing through the filters and adsorbers."
Although FPL is not committed to RG 1.52 Rev 3, FPL will delete the word "operational" from TS 4.7.5.c (3) and add "that may have an adverse effect on the functional capability of the system" to be consistent with the cited RG language. In addition, the content of the cited footnote will be added to the TS Bases discussion in order to address the reviewer's concern.
For proposed TS change, see the response to RAI #4 above. See attached Figures 1 and 2 for markups of the proposed changes to the TS and TS Bases.
: 7. To facilitate a more clear understanding, the NRC staff is requesting that the first sentence (page 7 of 24 item a.5.) be revised as follows: "With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable recirculation fans, and/or two inoperable recirculation dampers, immediately suspend all movement of irradiated fuel, and immediately initiate action to implement mitigating actions, and, within 24 hours, verify mitigating actions ensure control room occupant radiological exposures will not exceed limits and, within 7 days, restore the filter train to OPERABLE status."
FPL will revise the proposed wording in TS 3.7.5 Action a.5 as requested. In addition, FPL will revise TS Bases discussion on page 23 of 24 to remove any ambiguity. It will be revised to read "When the filter train is inoperable, ... , all movement of fuel in the spent fuel pool is required to be immediately suspended and mitigating actions, e.g., use of the compensatory filtration unit, are required to be immediately initiated, and, within 24 hours, the mitigating actions are required to be verified in place to ensure the control room occupant radiological exposures will not exceed limits...". See attached Figures 1 and 2 for the proposed changes to the TS and TS Bases.
Current TS 3/4.7.5 ACTIONS a.5   With the filter train inoperable (due to re*toiis otller thar) inwoelabe CRL bou-dar
[ SlT-448j), e.g., an inoperable filter, and/or two inoperable recirculation fans, and/or two inoperable recirculation dampers, immediately suspend all movement of irradiated fuel and initiate action to implement mitigating actions, and, within 24 hours, verify mitigating actions ensure control room occupant radiological exposures will not exceed limits and, within 7 days, restore the filter train to OPERABLE status.
With the above requirements not met, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
Proposed TS 3/4.7.5 ACTIONS a.5   With the filter train inoperable (due to reasons other that inoperable CR botndarv
[i1"F"-4:481), e.g., an inoperable filter, and/or two inoperable recirculation fans, and/or two inoperable recirculation dampers, immediately suspend all movement of irradiated fuel and, immediately, initiate action to implement mitigating actions, and, within 24

Turkey Point Units 3 and 4                                                                        L-2010-197 Docket Nos. 50-250 and 50-251                                                                     Attachlimient-Page 7 of 16 hours, verify mitigating actions ensure control room occupant radiological exposures will not exceed limits and, within 7 days, restore the filter train to OPERABLE status.
With the above requirements not met, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
Justification a.5:   The addition of "immediately" prior to initiation of mitigating actions removes any perceived ambiguity in the language relative to the required timing of the action.
: 8. In the BASES on page 23 of 24, the second paragraph states that a 24 hour allowed outage time (AOT) is reasonable based on the low probability of a... This statement is not consistent with ACTION statement a.5 of TS 3/4.7.5, i.e., there is no 24 hour AOT.
The NRC staff requests that FPL revise this paragraph in accordance with the TS action statement.
As stated in the attachment to the May 21, 2010 letter [Reference 2] on page 9 of 24, "The 24 hour allowance is considered reasonable based on the low probability of a DBA occurring during this period and is a reasonable amount of time to initiate and accomplish the mitigating actions described here." The cited TS Bases discussion on page 23 of 24 will be revised to read "The 24 hour allowance is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions, i.e., compensatory filtration unit." See attached Figure 2 for the proposed change to the TS Bases.
: 9. In the attachment to the May 21, 2010 letter, page 4 of 24 indicates that the compensatory filtration unit will be designed as a safety-related, Seismic Class I backup to the installed system.
a) Describe the methodology utilized to perform the seismic qualification of the compensatory filtration unit. Additionally, confirm that the methodology described is in accordance with the Turkey Point licensing basis. If the methodology is not in accordance with the Turkey Point licensing basis, provide justification for this deviation.
The compensatory filtration unit will be designed as Seismic Class I in accordance with Turkey Point's licensing basis that is summarized in UFSAR Appendix 5A Seismic Classification and Design Basis for Structures, Systems and Equipment for Turkey Point. The equipment Design Specifications require the fan assemblies, including the fan motor, to remain operable during and after a maximum hypothetical seismic event (Safe Shutdown Earthquake - SSE). The required response spectra will be specific for its location in the Control Building at Elevation 42'-0". Qualification of the equipment will be done using seismic analyses methods advocated by IEEE Standard 344-1975 - IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations. As allowed by the referenced IEEE standard, the equivalent static coefficient method or dynamic analysis using NRC approved computer software may be used to demonstrate seismic qualification for the equipment. If the static method is used, peak acceleration 'g' values for the required damping will be used with 1.5 modal amplification factor applied to the peak spectra value. In accordance with the Turkey Point UFSAR,

Turkey Point Units 3 and 4                                                                L-2010-197 Docket Nos. 50-250 and 50-251                                                             Attachment Page 8 of 16 seismic forces are combined by absolute summation of the effect of the forces in the vertical direction and a single orthogonal component in the horizontal direction. The seismic loads will be combined simultaneously with other applicable design loads in accordance with existing licensing basis.
b) Provide a summary of the results of the seismic qualification of the compensatory filtration unit demonstrating that this unit, including the individual filtration unit components and all connected components, meets the acceptance criteria for Seismic Class I structures, systems, and components at PTN.
The results of the seismic qualification of the compensatory filtration unit that demonstrate that the unit, including the individual filtration unit components and all connected components, meets the acceptance criteria for Seismic Class I structures, systems, and components at Turkey Point cannot be provided until the unit's design has been finalized and its supporting analyses completed. Accordingly, as discussed with the NRC, FPL provides the following commitment with regard to the seismic design and qualification of the proposed CREVS compensatory filtration unit:
                "The Control Room Emergency Ventilation System (CREVS) compensatory filtration unit, which is being installed by Florida Power and Light (FPL) as part of the Alternative Source Term (AST) methodology implementation at Turkey Point Nuclear Plant, Units 3 and 4 (PTN), will be designed in accordance with the Class I Structures, Systems, and Equipment Design Requirements defined in Appendix 5A of the PTN Updated Final Safety Analysis Report (UFSAR). As such, the compensatory filtration unit will be designed so that the stress limits found in Table 5A- 1 of the PTN UFSAR will not be exceeded due to the loadings imposed by a maximum hypothetical earthquake. This modification is scheduled to be completed following NRC approval of this AST License Amendment Request and prior to the start of the Unit 3 Spring 2012 refueling outage."
References
: 1. W. Jefferson (FPL) to U.S. Nuclear Regulatory Commission (L-2009-133), "License Amendment Request 196: Alternative Source Term and Conforming Amendment,"
Accession No. ML092050277, June 25, 2009.
: 2. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-083), "Supplement to License Amendment Request (LAR) 196 and 3/24/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST)," Accession No. ML101450028, May 21, 2010
: 3. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-13 1), "Response to 5/28/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196 (TAC Nos. ME1624 and ME1625),"
Accession No. ML101760019, June 23, 2010.
: 4. Email from J. Paige (NRC) to S. Franzone (FPL), "Draft RAIs RE AST LAR," Accession No. ML102440185, August 25, 2010

Turkey Point Units 3 and 4                                                                                                   L-2010-197 Docket Nos. 50-250 and 50-251                                                                                                Attachment Page 9 of 16 Figure 1 TS 3/4.7.5 PLANT SYSTEMS 3/47.5 CONTROL ROOM EMERGENCY'VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.5   The Control Room Emergency Ventilation System shall be OPERABLE.                          Insert.
APPLICABILITY:               All MODES.
ACTION:
MODES 1, 2 3 and 4:
Wihthi the CoQntrl RGOm Emergny etiaio                 yse inoperable, suspend all movement of fuel in the spent fueal pool and rostoro thp inoperFable sys&#xfd;tem&#xfd;to OPEIRABLEG rtptus ;A.'ihiR 84 hourr or be in tles HOT STANDBY Vwithin IhARAXxtA hOUrt and- nCODS TOW wi.4thin thA follnwi.ne 30 hours. If this~
ACTION qppio to bohunt -*sim ultaneously, be ;in HOT S-TANDB8Y within 12 hours and in COLD aR     +60   A"H-1 %VKH! A Fj!;Gwlpq  aw   a-PA;             -FIn-s e-rt 21 MODES 5 and 6:
With the Control Room Emergency Ventilation System inoperable, suspend all bperations involving CORE ALTERATIONS, movement, of fuel in the spent fuel pool, or positive reactivity changes. This ACTION shall-apply to both units simultaneously.
SURVEILLANCE REQUIREMENTS!
4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:
: a.         At least once per12 hours by verifying'that the control room air temperature is less than or equal to 1201F; b;         At least once per 31 days by :initiatihg, from theconirol room, flow through the V      A filters and charcoal adsorbers and verifying that the system operates for at least 15 mi nutes,*
: c.         At least once per 18 months or(1li after 720 hours of system operation, or (2) after any structural mairitenance on the HEPA filter or charcoal adsorber housings, or (3) following qperatioaa exposure of the filters to effluents from painting, fire, or chemical release in any ventilation zone communicating with the syste or (4) after complete or partial replacement of a filter bank by:
Ithat may have an adverse effect on the functional capability of the systemi TURKEY POINT - UNITS 3 & 4                           3/4 7-16              AMENDMENT NOS. 137 AND 132

Turkey Point Units 3 and 4                                                                                               L-2010-197 Docket Nos. 50-250 and 50-251                                                                                             Attachment Page 10 of 16 Figure 1 TS 3/4.7.5 (continued)
PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
: 1)      Verifying that the air cleanup system satisfiesi the in-place pepetration and bypass leakage tesing, acceptance criteria of greater than or equal to 99% Dop and halogenated hydrocarbon reimnoval at a system flow rate of 000. cfm +/-10%.*
: 2)       Verifying, within 31 days after removal, that a laboratory analysis of a representative
                                     &#xfd;carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide .152, Revision 2, March 1978, and analyzed per ASTM D3803 - 1989 AT 30'C and 95% relative humidity, meets the methyl iodide penetration criteria of less than 2.5% or.
the charcoal be replaced with charcoal that meets or exceeds the stated performance requirementlj                                                                                 Id
: 3)      Verifying by a Visual inspection the absence of.foreign materials and gasket deterioration.
: d.      At least once per 12 months byverifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 1000 cfm +/-10%,E*]
e;      At leastonce per 18 months by verifying that onla;Containment Phase "A" Isolation test signal the system automatically switches, into the recirculation mode of operation:
: f. At least once per 18a months by verifying operability of the kitchen and toilet area exhaust dampers,                                                                                            I
             ***As the mitigating actions of TS 3.7.5 Action a.5 may include the use, of the: compensatory filtration unit, the unit shall meet the surveillance requirements of TSA45.b,. by manual initiation from outside the control room and"TS 4.7,5.c and d TURKEY POINT - UNITS 3 & 4                         3/4 7-17            AMENDMENT NOS. &#xfd;205 AND 199,

Turkey Point Units 3 and 4                                                          L-2010-197 Dbo&ketNos. 50-250 and 50-251                                                       Attachment Page 11 of 16 Figure 1 TS 3/4.7.5 LCO Insert 1
: a. Three air handling units,
: b. Two condensing units,
: c. Two control room recirculation fans,
: d. Two recirculation dampers,
: e. One filter train,
: f. Two isolation dampers in the normal outside air intake duct,
: g. Two isolation dampers in the emergency outside air intake duct,
: h. Two isolation dampers in the kitchen area exhaust duct, and
: i. Two isolation dampers in the toilet area exhaust duct.
Insert 2 a.1   With one air handling unit inoperable, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable air handling unit to OPERABLE status or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
a.2   With two condensing units inoperable, immediately suspend all movement of irradiated fuel and, within 7 days, restore at least one of the inoperable condensing units to OPERABLE status or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
a.3   With one recirculation fan inoperable, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable fan to OPERABLE status or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours. If the mitigating actions of action a.5 are implemented, then this action does not apply.

Turkey Point Units 3 and 4                                                         L-2010-197 Docket Nos. 50-250 and 50-251                                                      Attachment Page 12 of 16 Figure 1 TS 3/4.7.5 LCO (continued) a.4   With one recirculation damper inoperable, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or place and maintain at least one of the recirculation dampers in the open position and place the system in recirculation mode** or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours. If the mitigating actions of action a.5 are implemented, then this action does not apply.
a.5   With the filter train inoperable (due to reasons other than inoperable CRE boundary [TSTF-448j), e.g., an inoperable filter, and/or two inoperable recirculation fans, and/or two inoperable recirculation dampers, immediately suspend all movement of irradiated fuel and, immediately, initiate action to implement mitigating actions, and, within 24 hours, verify mitigating actions ensure control room occupant radiological exposures will not exceed limits and, within 7 days, restore the filter train to OPERABLE status.
With the above requirements not met, be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
a.6   With an inoperable damper in the normal outside air intake, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or place and maintain at least one of the normal outside air intake isolation dampers in the closed position and place the system in recirculation mode** or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
a.7   With an inoperable damper in the emergency outside air intake, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or place and maintain at least one of the emergency outside air intake isolation dampers in the open position** or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours. If the mitigating actions of action a.5 are implemented, then this action does not apply.

Turkey Point Units 3 and 4                                                             L-2010-197 Docket Nos. 50-250 and 50-251                                                          Affachmhent Page 13 of 16 Figure 1 TS 3/4.7.5 LCO (continued) a.8    With an isolation damper inoperable in the kitchen area exhaust duct, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or isolate the flow path** or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
a.9    With an isolation damper inoperable in the toilet area exhaust duct, immediately suspend all movement of irradiated fuel and, within 7 days, restore the inoperable damper to OPERABLE status or isolate the flow path** or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours and in COLD SHUTDOWN within the following 30 hours.
       **If action is taken such that indefinite operation is permitted, then movement of irradiated fuel may resume.

Turkey Point Units 3 and 4                                                                                                                   L-2010-197 Docket Nos. 50-250 and 50-251                                                                                                                Attachment Page 14 of 16 Figure 2 - TS 3/4.7.5 Bases (Information Only)
Procedure No               Procedure,

==Title:==
Page:
100 Approval Date:
0=ADM-536                   Technical Specification Bases Control Program                                         I/!19/10 ATTACHMENT 1 (Page 89 of 112)
TECHNICAL SPECIFICATION BASES 3/4.7.5 (Cont'd) 444a Cnt~rel Reeff F5~Rwgeqt '                   Weetilatizr. Sylmtafh ias       aiz         to~+0 ORPER-ABLE 0eRfJN          P+N 91NP 92 04) vIt 4)T+i-                                                  i~'              oUf e1 of avalable eedetn &a4epefbe 4i)04 reiralat                                    filertfit       it          hIrae 4) Tw AII~a          "gur        atitle     64h                           fndr,..Aw 4el  opffW             ----
AHU3               *l aamlal iupjl ig              ait       themi                 singh ferdtmifeatrltwo A1149- would e inrgn, a               altiltar Fhn 41644 AII 4 t f                    ~i r'1Ur        r       14M i          in4     4140 fa1r                       .m1 hIat 9             &#xfd; 'uut~~a n     Jplabi itfor          jqv giam tth+h Offiefgetie5.
eja*R              4f II;: t        446:
A Wzi;g4      (Air ;zndftiaair4g) system ioaa ah1         p a mamtauin th          artie wlith       aguainf teste       igttffi6 amfra~rtee              idett foa         fta4rnglo and1 Th~,.nczoaan~ng41044a iA-                                      h ta'R loniilRti Af- 44vi~                              5itu
                                                                                                                                               *mfatngth ahili                           Romy Eof hfRbjf                                             44"oasiagaa
                                                                                                                -eaaaniaia       Uatlto iRedtan r bv Am t ti;       f ::r?;.
                                             !*;n.         ; 1?*n~ctM ;*a       .... Add Insert 1 next page I Systei componhefts are not subject to rapid .dete ioran, having Jiletines of many years, even under'continious flow conditions. Visual inispectibn and operating tests provide assurance of system reliability and Will ensure early detection of conditions which could.
cause the system to fail dr operate improperly. The filters peffortnance tests prove that filters have been properly installed, that no deterioration or damage has occurred, and that all components and subsystems operate properly. The in~situ tests are performed in accordance with the methodology and intent of ANSI N510 (1975) and provide assurance that filter performance :has not deteriorated below returned specification values due to aging, contamination, or other effects. Charcoal samples are tested using ASTM D3803-1989 in accordancewith Generic Letter 99-02.- The test conditions (30'C and 95%
relative humidity) are as specified in the Generic Letter., Table 1 of the ASTM standard provides the tolerances that must, be met during the test for each test parameter. The specified methyl iodide penetration value is based on the assumptions used in the L(C A Anpalysis.,
3/4.7.6      Snubbers All snubbers are required OPERABLE to ensure that the stictural integrity of the Reactor Coolant System and all other safety-related systems is, maintained during and following a seismic oi other event initiaiting dynaaiic 16lads.
The visual. inspection frequency is, based upon maintaining a constant level of snubber protection to each safety-related system during an earthquake or severe transient.
Therefore,, the required inspection interval varies inversely with the observed snubber failures and is determined by the number of inoperable snubbers found during an inspection. Inspections performed before that interval has elapsed may be used as a new
                       .reference point to determine the next inspection. ihowever, the results of such early inspections perfomied before the original required time interval has elapsed (nominal time less 25%) may not be used to lengthen the required inspection interval. Any inspection whose results require a shorter. inspection interval will oveiride the previous schedule.

Turkey Point Units 3 and 4                                                                 L-2010-197 Docket Nos. 50-250 and 50-251                                                              Attachment Page 15 of 16 Figure 2 TS 3/4.7.5 Bases (Information Only) (continued)
Insert I The Control Room Emergency Ventilation System (CREVS) is considered to be OPERABLE (Ref: JPNPTNSENP-92-017) when 1) Three air handling units (AHUs) (three out of three) are operable, 2) Two condensing (air conditioning (AC)) units (two out of three) are operable, 3)
Two recirculation fans are operable, 4) Two recirculation dampers are operable, 5) One recirculation filter unit is operable, 6) Two normal outside air intake dampers are operable, 7)
Two emergency outside air intake dampers are operable, 8) Two isolation dampers (one motor-operated damper and one gravity backdraft damper) in the kitchen area exhaust duct are operable, and 9) Two isolation dampers (one motor-operated damper and one gravity backdraft damper) in the toilet area exhaust duct are operable. The reason three AHUs are required is that in the event of a single failure, only two AHUs would be available to supply air to the suction of the recirculation filter and fan. This is the configuration tested to support Technical Specification operability for flow through the emergency charcoal filter unit. Taking one AHU out of service renders the system incapable of operating in accordance with the tested configuration assuming an accident and a single failure, i.e., only one air handling unit available instead of the two assumed in the analysis. Any one of the three condensing (A/C) units is capable of maintaining control room equipment within environmental limits for temperature and humidity.
Thus, one condensing unit can be taken out of service without impacting the ability of CREVS to accomplish its intended function under single failure conditions.
The LCO actions allow inoperability of the redundant active CREVS components (one AHU, two condensing units, one recirculation fan, one recirculation damper, one normal outside air intake damper, and/or one emergency outside air intake damper) for a period of up to 7 days consistent with the approach provided in the Westinghouse Standard Technical Specifications and based on the low probability of occurrence of a Design Basis Accident (DBA) challenging
.the Control Room Habitability during this time period and the continued capability of the remaining operable system components to perform the required CREVS safety function. When the motor-operated isolation damper in a kitchen or toilet area exhaust duct becomes inoperable, the damper is required to be restored to operability within 7 days or a damper in the flow path be closed (either the motor-operated damper or its associated manual isolation damper) until it can be restored to operability. This 7 day AOT is predicated on continued operability of its associated gravity backdraft damper.
When one damper in the normal outside air intake is inoperable, it can either be restored within 7 days or one of the two in-series dampers closed and CREVS run in recirculation mode. When one recirculation damper is inoperable, it can either be restored or one of the two paralleled dampers opened and the CREVS run in recirculation mode. With one or both emergency outside air intake dampers inoperable, they can either be restored or opened without adversely impacting the normal or emergency mode of operation. (See TSA 03-03-025-024 for evaluation). The placement of the dampers in their "fail-safe" position in lieu of restoration is allowed as the dampers fail "as-is" in the event of loss of offsite power (except for the emergency outside air intake dampers which go to their emergency "open" position) and are in their emergency mode position in the event of receipt of an emergency actuation signal.

Turkey Point Units 3 and 4                                                                 L-2010-197 Docket Nos. 50(-250 and 50-251                                                              Attachment Page 16 of 16 Figure 2 TS 3/4.7.5 Bases (Information Only) (continued)
As indicated in LCO footnote, if an action is taken such that indefinite operation is permitted (a.4, a.6, a.7, a.8, a.9), then movement of irradiated fuel is allowed. Although still technically in the Action due to component inoperability, system configuration, as modified, satisfies the design requirement to support system emergency operation with ability to withstand a single active failure.
When the filter train is inoperable (for reasons other than an inoperable CRE boundt y 7TSTF-448]), e.g., the filter is inoperable, and/or two recirculation fans are inoperable, and/or two recirculation dampers are inoperable, all movement of fuel in the spent fuel pool is required to be immediately suspended and mitigating actions, e.g., use of compensatory filtration unit, are required to be immediately initiated, and, within 24 hours, the mitigating actions are requiredto be verified to be in place to ensure the control room occupant radiological exposures will not exceed limits, e.g., the compensatory filtration unit is placed into service, and, within 7 days, the inoperable filter train is required to be restored to OPERABLE status. The 24 hour allowance is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions, i.e., compensatory filtration unit. The 7 day AOT is reasonable based on the determination that the mitigating actions will ensure protection of Control Room occupants within analyzed limits. In addition, the 7 day AOT is a reasonable time to diagnose, plan, repair, and test most problems with the inoperable filter train.
The compensatory filtration unit is designed as a manual, safety-related, Seismic Class I backup to the installedsystem with the same functional and operationalcapabilitiesas the installed filter train. In addition, the unit is surveillance tested in accordance with the same requirementsas those imposed on the installed filter train per TS 4.7.5.b, c, and d except that the requirements of TS 4.0.1 - 4.0.4 do not apply to the compensatory unit as it is not included in CREVS LCO.
Regarding exposure of the filters to effluents that may have an adverse effect on the functional capability of the system, painting, fire, or chemical releases are considered "notcommunicating" with the HEPA filter or adsorberif the system is not in operation, the isolation dampers for the system are closed, and there is no pressure differential across the filter housing. This provides reasonableassurance that airis not passing through the filters and adsorbers.
In addition, the CREVS includes the emergency outside air intakes, located beyond the southeast and northeast corners of the Auxiliary Building. The CREVS emergency outside air intakes are considered OPERABLE when: 1) both flow paths are available, 2) have balanced intake flow rates and 3) a flow path capable of drawing outside makeup air from only the analyzed intake locations. The alternative source term radiological analyses assume both emergency outside air intake flow paths are available with parallel dampers ensuring outside makeup air can be drawn through both intake locations during a design basis accident and a single active failure. These analyses rely on a provision in Regulatory Guide 1.194 Section 3.3.2 that allows a reduction in the atmospheric dispersion factors (X/Qs) for dual intake arrangements with balanced flow rates to one half of the more limiting X/Q value provided the two intakes are not within the same wind direction window for each release / receptor location.
Accordingly, any maintenance on the emergency outside intake dampers or associated duct work that would prevent the CREVS from accomplishing these functions would require entering action statement a.7. The provisions of LCO 3.0.6 apply to the surveillance testing required to demonstrate operability of the emergency intake flow paths.}}