ML17345A790

Application for Amends to Licenses DPR-31 & DPR-41,changing TS 3.3.2 Re ESFAS,3.3.3.4 Re Fire Detection Instrumentation, 3/4.7.8.3 Re Fire Hose Stations & 3.8.3 Re Onsite Power Distribution Per Emergency Power Enhancement Project

ML17345A790
Person / Time
Site:	Turkey Point
Issue date:	04/04/1991
From:	Bohlke W FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17345A791	List: ML17345A790 ML17345A793
References
L-91-089, L-91-89, TAC-69023, TAC-69024, NUDOCS 9104150012
Download: ML17345A790 (41)

Text

', ACCELERATED DISTRIBUTION DEMONSTFMTION SYSTEM

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REGULATORY'NFORMATXON DXSTRXBUTION SYSTEM (RIDS)

,ACCESSION NBR:9104150012 DOC.DATE: 91/04/04 NOTARXZED: YES DOCKETff FACIL:50-250 Turkey Point Plant, Unit .3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFXLIATION BOHLKE,W.H. Florida Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION R Document Control Branch (Document Control Desk)

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SUBJECT:

Application for amends to Licenses DPR-31 & DPR-41,changing  !

TS 3.3.2 re ESFAS,3.3.3.4 re fire detection instrumentation, D 3/4.7.8.3 re fire hose stations 6 3.8.3 re onsite power distribution per emergency power enhancement project. S DXSTRIBUTION CODE: A006D TITLE: OR/Licensing Submittal:

COPIES RECEIVED:LTR Fire Protection ENCL SIZE: +!8 NOTES A RECIPIENT COPIES RECIPIENT COPIES D ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 0 PD2-2 PD 1 1 D AULUCK,R 2 2 S

INTERNAL NRR WERME IL i J 1 0 NRR/DET/ECMB 9H 2 2 NRR/DST 8E2 1 1 NRR/DST/SPLB8D1 1 1 NUDOCS-ABSTRACT 1 1 0 1 0 OGC/HDS3 1 0 REG FI 01 1 1 EXTERNAL: NRC PDR NSIC 1 1 D

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LINIS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF. COPXES REQUIRED: LTTR 15 ENCL 11

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0 P.O. Box)4000,Juno Beach, FL 33408-0420 APR 04 1991 L-91-089 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendment Emergency Power System (EPS) Enhancement Project-Undervoltage Relay Setpoint and Fire Protection NRC TAC Nos. 69023 and 69024 In accordance with 10 CFR 50.90, Florida Power & Light Company (FPL) requests that Facility Operating License DPR-31 and DPR-41 be amended to modify Turkey Point Units 3 and 4 Technical Specifications. The sections to be modified include Technical Specification 3.3.2, Engineered Safety Features Actuation System Instrumentation; 3.3.3.4, Fire Detection Instrumentation; 3.5.2, ECCS Subsystems; 3/4.7.8.3, Fire Hose Stations; 4.8.1.1.2, AC Sources Operating; and 3.8.3, Onsite Power Distribution. The purpose of this amendment is to revise the Technical Specifications to reflect (a) the undervoltage relay setpoints for the Emergency Power System (EPS) Enhancement Project, (b) add an additional fire zone and (c) incorporate administrative changes.

The NRC issued Amendment No. 138 to Facility Operating License No. DPR-31 and Amendment No. 133 to Facility Operating License No. DPR-41 for the Turkey Point Units, to accommodate changes to the plant as a result of the EPS Enhancement Project. The proposed license amendment supplements Amendments 138 and 133 by providing the revised undervoltage relay setpoints, and the addition of a fire zone area for the EPS Enhancement Project.

FPL has determined that the proposed license amendment does not involve a significant hazard pursuant to 10 CFR 50.92. A description of the amendment request is provided in Attachment l.

The no significant hazards determination in support of the proposed Technical Specification change is provided in Attachment

2. Attachment 3 provides the proposed revised Technical Specification changes.

In accordance with 10 CFR 50.91 (b)(1), a copy of this proposed License Amendment is being forwarded to the State Designee for the State of Florida.

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L-91-089 Page 2 The proposed amendment has been reviewed by the Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board.

Should there be any questions on this request, please contact us.

Very truly yours, W. H. Bohlke Vice President Nuclear Engineering and Licensing WHB/RJT/r jt Attachments cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point, Plant Mr. Jacob Daniel Nash, Florida Department of Health and Rehabilitative Services

STATE OF FLORIDA )

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COUNTY OF DADE )

W. H. Bohlke being first duly sworn, deposes and says:

That he is Vice President Nuclear En ineerin and Licensin of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.

W. H. Bohlke Subscribed and sworn to before me this day of 1991.

NOTARY PUBLIC, in and for the County of

,Dade, State of Florida Votary Public, 5tato of florida f<ly Commissioa Expires lao. 16, 1993 My tCommission expires

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ATTACHMENT 1 DESCRIPTZON OF AMENDMENT REQUEST

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L-91-089 Page 1 of 3 DESCRIPTION OF AMENDMENT RE UEST The proposed amendment revises the Turkey Point Technical Specifications to reflect (a) the undervoltage relay setpoints for the Emergency Power System (EPS) Enhancement Project, (b) adds an additional fire zone and (c) incorporates administrative changes. The description of these changes are provided below.

Undervolta e Rela Set pints FPL transmitted letter L-90-68, dated July 2, 1990 describing the scope of the Emergency Power System (EPS) Enhancement Project and requesting approval of Technical Specification changes to support this project. The EPS Enhancement Project involves separating, to the extent practical, the AC electrical system for Turkey Point Units 3 and 4 and adding two new Class lE Emergency Diesel Generators (EDG's).

In response to the L-90-68 submittal, the NRC issued Amendment No. 138 to Facility Operating License DPR-31 and Amendment No.

133 to Facility Operating License DPR-41 for Turkey Point Units 3 and 4, respectively. These amendments modified the Technical Specifications to reflect changes to the plant as a result of the EPS Enhancement Project.

This proposed license amendment involves revising Table 3.3-3, items 7.b and 7.c, 480V Load Centers (LCs) undervoltage relay setpoints for instantaneous degraded voltage and inverse time degraded voltage. FPL has revised the design calculations performed in support of Amendment 138 and 133 of the Turkey Point Technical Specifications to reflect plant changes recently finalized. Recalculation was necessitated because of the replacement of MOV motors as a result of FPL actions in response to Generic Letter 89-10 (Reference 4), and the availability of final vendor data on some HVAC equipment added during the dual unit outage. These plant modifications resulted in different voltage requirements for the load centers. The assumptions and calculational methodology used in the revised calculation are consistent with those of the calculation performed to determine the existing setpoint values.

Since the same undervoltage protection is afforded by the revised setpoint values, there is no significant increase in the probability or consequences of an accident previously evaluated.

L-91-089 Page 2 of 3 Fire Protection S stem Changes to the Fire Protection System include (a) the addition of one fire zone to Table 3.3-6; (b) revising the number of fire detection instruments in three fire zones in Table 3.3-6; and (b) the addition of a fire hose station as listed in Table 3.7-4.

(a) Table 3.3-6, Fire Detection Instruments for Essential Equipments, is revised to include one additional fire zone (Fire Zone 25A). Fire Zone 25A is a unique fire zone identifier which has been assigned to the Spare Battery Room. The two Function A type heat detectors shown for Fire Zone 25 will now be associated with Fire Zone 25A. Also the number of Function A type smoke detectors shown for Fire Zone 25 is updated from 5 to 6 ~

The additional fire zone added to Table 3.3-6 is consistent with the existing listed fire zones and provides assurance that the Spare Battery located in this fire zone will be appropriately monitored. Since different types of detection are appropriate for the Spare Battery Room and the Electrical Equipment Room within the Fire Area G, unique fire zone identifiers have been assigned to each room for convenience. To ensure that failure of a single detector does not result in a total loss of detection in the fire zone, a minimum of two detectors are required for each area.

Due to modifications to the geometry of the Electrical Equipment Room, an additional smoke detector has been added in Fire Zone 25, in accordance with the National Fire Protection Association (NFPA) Standard 72E.

Therefore, the current listing of five smoke detectors in Fire Zone 25 has been updated to six.

(b) The total number of fire detection instruments listed in Table 3.3-6, Fire Detection Instruments for Essential Equipments, is revised to reflect the actual plant configuration. The actual number of Function A type smoke detectors in Zone 106, Control Room, is 16, as opposed to 17, while the total number of smoke detectors in Zone 132, Control Room Electrical Chase, is increased by two.

The total number of detectors in the combined zones is consistent with the actual plant configuration and is in accordance with NFPA Standard 72E.

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L-91-089 Page 3 of 3 (c) Fire Hose Station HS-04-09, located at the entrance to the new Unit 4 EDG Building, is added to Table 3.7-4.

The addition of this hose station ensures that an appropriate level of protection is provided for the new Unit 4 EDG Building, as compared to the existing Unit 3 EDG Building, for mitigating the consequences of a fire.

These proposed changes do not affect the initiator of any accident evaluated in the FSAR nor the mitigation of any accident.

Administrative Chan es The following administrative changes are proposed:

(a) Insert the word "status" after the word "OPERABLE" in ACTION statement c of Technical Specification 3.5.2, ECCS Subsystems. Also, delete the word "OPERABLE" in ACTION statement f of TS 3.5.2.

(b) In Technical Specification 4.8.1.1.2, AC Sources Operating, the specified EDG loading is replaced with the acceptable loading bands, (c) In Technical Specification 3.8.3.1, (Table 3.8-2) Onsite Power Distribution, delete the word "if". Insert the word

"(hours)" as presented in Tables 3.8-1 and 3.8-2.

(d) In Technical Specification 3.8.3.2, Onsite Power Distribution, delete the word "in" and insert the phrase "on the same DC bus for", to achieve consistency with the same type of footnote provided for LCO 3.8.3.1.

(e) In ACTION statement b of Technical Specification 3.3.3.4, Fire Detection Instrumentation, change the Table number from "Table 3.3-11" to "Table 3.3-6". (Table 3.3-11 does not exist in the Technical Specifications.)

These administrative changes are considered editorial or non-technical in nature and are intended to make the Technical Specifications more consistent.

ATTACHMENT 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION

L-91-089 Page 1 of 16 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The commission has provided standards for determining whether a significant hazards consideration exists (10 CFR 50.92(c)). A proposed amendment to an operating license for a facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The basis that the proposed amendment does not involve a significant hazards consideration is provided in the following pages.

III L-91-089 Page 2 of 16 II. EVALUATIONS TS 3 ' ' ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION Plant Modification Changes Each of the 480V Load Centers'LCs) undervoltage relay setpoints for instantaneous degraded voltage and inverse time degraded voltage specified in Table 3.3-3, items 7.b and 7.c, respectively, are revised.

1 ~ Operation of the facility in accordance with the proposed amendment would not involve a significant, increase in the probability or consequences of an accident previously evaluated.

The design calculation (Reference 3) which established the trip setpoint values provided in Amendments 138 and 133 of the Turkey Point Units 3 and 4 Technical Specifications, respectively, has been revised to reflect plant changes recently finalized. Recalculation was necessary primarily because of the replacement of MOV motors as a result of FPL actions in response to generic Letter 89-10 (Reference 4),

and the availability of final vendor data on some safety-related HVAC equipment added during the dual unit outage.

These plant modifications resulted in different voltage requirements for the LCs. The assumptions and calculational methodology used in the revised calculation (Reference 5) are consistent with those of the calculation performed to determine the existing setpoint values. Since the same undervoltage protection is afforded by the revised setpoint values, there is no significant increase in the probability or consequences of an accident previously evaluated.

2 ~ 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.

No new types of equipment are added by this change. The proposed change introduces no changes in operation or new modes of operation. The ability of the system to detect and appropriately respond to an off-normal undervoltage condition is maintained.

L-91-089 Page 3 of 16 3 ~ Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The same criteria utilized in the calculation of the existing setpoints has been applied to the calculation of the revised setpoints. The purpose of the specified trip settings is to separate the busses from the offsite power and reenergize these same busses from the onsite power unacceptable voltage drop should occur on the offsite power if an system. The margin of safety provided by the new values is commensurate with the existing values since they were calculated in a similar manner.

1 p L-91-089 Page 4 of 16 TS 3 ' ' ' FIRE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION Plant Modification Changes On Table 3.3-6, one additional fire zone is added to the table. The additional fire zone (Fire Zone 25A) is a unique fire zone identifier which has been assigned to the Spare Battery Room. The two Function A type heat detectors shown for Fire Zone 25 will now be associated with Fire Zone 25A.

The number of Function A type smoke detectors shown for Fire Zone 25 is updated from 5 to 6. In addition, two Type B smoke detectors are added to Fire Zone 132, Control Room Electrical Chase.

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The additional fire zone added to Table 3.3-6 is consistent with the existing listed fire zones and provides assurance that the Spare Battery located in this fire zone will be appropriately monitored. As described in Reference 6, the Spare Battery Room and the Electrical Equipment Room are both within one fire area labeled as G. Originally, this whole area (formerly the Auxiliary Building Machine Shop) was labeled as Fire Zone 25. Conversion of this room into the Electrical Equipment Room and Spare Battery Room, as part of the EPS Enhancement Project, resulted in unique fire detection requirements for the equipment being monitored.

In accordance with NUREG/CR-1798 (Reference 7), thermal detectors are to be used for detection in the battery rooms and ionization smoke detectors in the area containing the electrical equipment. Since different types of detection are appropriate for the Spare Battery Room and the Electrical Equipment. Room within the Fire Area G, unique fire zone identifiers have been assigned to each room for convenience. To ensure that failure of a single detector does not result in a total loss of detection in the fire zone, a minimum of two detectors are required for each area.

Due to the geometry of the Electrical Equipment Room and the location of HVAC ducts, an additional smoke detector has been added in Fire Zone 25, in accordance with the National Fire Protection Association (NFPA) Standard 72E (Reference 8). Therefore, the current listing of five smoke detectors in zone 25 has been updated to six.

1 L-90-089 Page 5 of 16 The probability or consequences of an accident is not affected by this change. The new fire zone identifier, 25A, and the revision of the number of smoke detectors in Fire Zone 25 do not affect the initiator of any accident evaluated in the FSAR nor the mitigation of any accident.

2 ~ 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.

The additional fire zone added to Table 3.3-6 is consistent with the existing listed fire zones. The resulting number of detectors indicated provide adequate fire detection capability. No new types of fire detectors are being added to the plant. The proposed change introduces no changes in operation or new modes of operation.

3. Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The margin of safety remains unchanged since the additional fire zone does not affect the level of detection and warning currently provided by the existing Technical Specification requirements. The resulting number of detectors indicated are consistent with the industry standards, i.e., NFPA and NUREG/CR-1798, for providing adequate fire detection capability; thus the margin of safety is maintained.

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L-91-089 Page 6 of 16 TS 3 3.3 4 FIRE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION Administrative Changes On Table 3.3-6, the number of Type A smoke detectors in Fire Zone 106, Control Room, was incorrectly identified as 17 as opposed to 16 detectors.

Fire Zone 132, Control Room Electrical Chase, was created from the original Fire Zone 106. At that time, the number of Type A smoke detectors in Fire Zone 106, was incorrectly accounted for.

This proposed amendment. revises Table 3.3-6 to reflect the actual plant configuration.

In addition, in ACTION statement b of this Technical Specification, change the Table number from "Table 3.3-11" to "Table 3.3-6". This is an editorial change, since the correct table is Table 3.3-6, and the incorrect Table 3.3-11 does not exist in the Technical Specifications.

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

This change is editorial in nature, since the original plant configuration has not changed and this change has no impact on plant operating requirements or FSAR analyzed accidents.

This change is proposed solely to ensure the consistency of the Technical Specifications with the actual plant configuration and the associated Technical Specifications.

2 ~ 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.

This change is of an editorial nature, and has no effect on the possibility of accidents. The resulting number of detectors indicated provide adequate fire detection capability. No new types of fire detectors are being added to the plant. The proposed change introduces no change in operation or new modes of operation.

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L-91-089 Attachment 2

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3. Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The resulting number of detectors are consistent with the industry standards, i.e., NFPA and NUREG/CR-1798, for providing adequate fire detection capability; thus the margin of safety is maintained.

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L-91-089 Page 8 of 16 TS 3 ~ 5 ~ 2 ECCS SUBSYSTEMS T~yG GREATER THAN OR EQUAL TO 350 F LIMITING CONDITION FOR OPERATION ACTIONS Administrative Changes The word "status" is inserted after the word "OPERABLE" in ACTION statement c. In ACTION statement f, the word "OPERABLE" is deleted before the words "diesel generator", since for Technical Specifications purposes an inoperable EDG is defined as not capable of supplying power to the associated safety injection pump.

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consecpxences of an accident previously evaluated.

This change is editorial in nature and has no impact on plant operating requirements or FSAR analyzed accidents.

This change is proposed solely to enhance the consistency in the wording of ACTION statements in the Turkey Point Technical Specifications.

2 ~ 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.

This change is editorial in nature and has no effect on the possibility of accidents. The proposed change introduces no changes in operation or new modes of operation.

3 ~ Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

This change is editorial in nature and has no effect on the margin of safety.

L-91-089 Attachment 2

.Page 9 of 16 TS 3/4 ~ 7~8~3 FIRE HOSE STATIONS LIMITING CONDITION FOR OPERATION Plant Modification Changes Fire Hose Station HS-04-09 on Elevation (EL.) 18', located at the entrance to the new Unit 4 EDG Building, is added to Table 3.7-4.

1 ~ Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The addition of this new Hose Station to Table 3.7-4 provides for the same OPERABILITY requirements as specified for the existing Fire Hose Stations. Note this hose station was added to Turkey Point's design per FPL's commitment in Reference 6. This additional requirement ensures that an appropriate level of protection is provided for the new Unit 4 EDG Building, as compared to the existing Unit 3 EDG Building, for mitigating the consequences of a fire.

Therefore, the probability of or consequences of losing an EDG due to a fire is not increased. This added Hose Station does not affect the initiator of any other accident evaluated in the FSAR and provides assurance that adequate fire protection is available for required plant equipment in the vicinity of the new Unit 4 EDG Building.

2. 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.

The Hose Station at the new Unit 4 EDG, Building provides a similar degree of protection against fire-induced losses of an EDG as provided for the existing Unit 3 EDG Building.

The new Hose Station will be maintained and operated in accordance with the existing fire protection program, and therefore, will not create the possibility of a new or different kind of accident. The proposed change introduces no changes in operation or new modes of operation.

L-91-089 Page 10 of 16

3. Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The new Unit 4 EDG Building Hose Station will assure that the safety-related equipment in this new building is provided with the same level of protection as the safety-related equipment in the existing Unit 3 EDG Building.

Thus, the margin of safety is not reduced.

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L-91-089 Page 11 of 16 TS 4 8 1 1 2 AC SOURCES - OPERATING SURVEILLANCE RE UIREMENTS Administrative Changes The specified EDG loading in the double asterisk footnote associated with Surveillance Requirement 4.8.1.1.2.g.7) on the bottom of p. 3/4 8-8 is replaced with acceptable loading bands.

1 ~ Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident, previously evaluated.

The probability of occurrence of an accident previously evaluated in the FSAR has not been affected, since the surveillance testing of EDGs does not affect the probability of occurrence of accidents. The consequences of an accident previously evaluated in the FSAR are not affected by this change either. The revisions to this surveillance footnote are proposed to enhance consistency with the rest of Turkey Point's EDG's surveillance requirements (e.g.', 4.8.1.1.2.a.5 and .g.7). The specification of load bands versus a single specific value is endorsed by the EDG vendors and the NRC.

(The NRC has endorsed a similar change for both Carolina Power and Light Shearon Harris Unit 1 and Texas Utilities Comanche Peak Unit 1.) The specified bands provide the same EDG performance assurance as the existing criteria, but minimize the wear and tear on the EDG. The specified bands preclude testing the EDGs while excessively loaded.

2 ~ 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.

The revisions to the surveillance footnote are proposed to enhance consistency with the rest of Turkey Point's EDG's surveillance requirements (e.g., 4.8.1.1.2.a.5 and .g.7) and do not require any new types of testing. The proposed change introduces no basic changes in operation or new modes of operation.

L-91-089 Page 12 of 16 3 ~ operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The surveillance footnote has been revised to enhance consistency with the requirements of the other EDG surveillances at Turkey Point. The revised footnote provides a commensurate level of confidence that the EDGs will perform as designed.

1 L-91-089 Page 13 of 16 TS 3 ~ 8 ~ 3 ~ 1 I ONS TE POWER DISTRIBUTION OPERATION Administrative Changes Delete the word "if" from the phrase, the out-of-service time if is not applicable ..." from the single asterisk footnote on Table 3.8-2. Insert "(hours)" in the column header of Tables 3.8-1 and 3.8-2.

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

These changes are editorial in nature and have no impact on plant operating requirements or FSAR analyzed accidents.

The addition of "(hours)" is provided for clarity. The specified Allowable Outage Times provided in these table is in units of hours; however, this was not explicitly shown.

2. 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.

These changes are editorial in nature and have no effect on the possibility of accidents. The proposed changes introduce no changes in operation or new modes of operation.

3 ~ Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

These changes are editorial in nature and have no effect on the margin of safety.

L-91-089 Page 14 of 16 TS 3 ' 3 2 ONSITE POWER DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION Administrative Changes The double asterisk footnote of LCO 3.8.3.2 has been revised by deleting the word "in" and inserting the phrase "on the same DC bus for" to achieve consistency with the same type of footnote provided in LCO 3.8.3.1.

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The editorial change to the double asterisk footnote is proposed to enhance consistency within Turkey Point's Technical Specifications. The addition of the clarification phrase provides better understanding for the operator regarding the configuration and usage of a backup inverter.

The proposed change does not result in any new plant operating requirements. No accident initiating events are affected. The change is editorial and does not affect the probabilities of the occurrence of, or the consequences of, an accident.

2 ~ 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.

The proposed change in the footnote is basically editorial in nature and does not require any new types of testing.

The proposed change introduces no basic changes in operation or new modes of operation.

3 ~ Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The change only enhances the Technical Specifications by providing better consistency and providing more understandable footnotes.

L-91-089 Page 15 of 16 IXX~ CONCLUSION Based on the foregoing, a determination of No Significant Hazards Consideration is appropriate. The amendment request does not, (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the probability of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

Further, the amendment is of a type specifically identified by the NRC as not likely to involve a significant hazards consideration. (See 51 FR 7751 (Reference 9), examples (i),

(ii) and (ix) .)

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L-91-089 Page 16 of 16 REFERENCES 1 ~ FPL letter, L-90-196, dated June 4, 1990 from K. N. Harris to USNRC with attachments:

(a) Emergency Power System Enhancement Design Report, Revision 1, (b) Emergency Power System Enhancement Report Supplement 1 Testing, Revision 1, (c) Emergency Power System Enhancement Report Supplement 2 Safety Analysis, Revision 0, and (d) Emergency Power System Enhancement Report -Response to NRC s Request for Additional Information, Revision l.

2. Title 10 Code of Federal Regulations Part 50, latest edition.

3 ~ PSB-1 Voltage Analysis for Electrical Auxiliary System; EBASCO Calculation EC-145 Revision 2, dated June 1990.

4 ~ USNRC Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance (10 CFR 50.54 (f)), issued June 28, 1989.

5. PSB-1 Voltage Analysis for Electrical Auxiliary System; EBASCO Calculation EC-145 Revision 4, dated March 1991.

6. FPL Letter, L-90-256, date July 23, 1990, Emergency Power System Enhancement Project Response to NRC's Request for Additional Information regarding Fire Protection and Compliance with Appendix R.

7 ~ NUREG/CR 1798, Acceptance and Verification for Early Warning Fire Detection Systems.

8. National Fire Protection Association Standard 72E-1984, Automatic Fire Detectors.

9. Federal Register, Volume 51, No 44, page 7751, dated March 6, 1986.