L-2012-067, License Amendment Request No. 215, Request for Revision of the License Condition 3.D, Fire Protection

License Amendment Request No. 215, Request for Revision of the License Condition 3.D, Fire Protection

ML12083A294
Person / Time
Site:	Turkey Point
Issue date:	02/28/2012
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2012-067, LAR 215
Download: ML12083A294 (13)

Text

0 FPL.

POWERING TODAY.

Florida Power and Light Company, 9760 SW 34 4 th St., Homestead, FL 33035 FEB 2 8 2012 EMPOWERING TOMORROW.0 10 CFR 50.90 L-2012-067 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Generating Station Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request No. 215 Request for Revision of the Turkey Point Nuclear Generating Station License Condition 3.D, Fire Protection

References:

1) Florida Power and Light Company Letter L-2004-176 to the USNRC dated December 27, 2004, "Request for Exemption - Automatic Suppression in the Mechanical Equipment Room (Fire Zone 097) and Control Room Roof (106R)"

2) Florida Power and Light Company Letter L-2005-089 to the USNRC dated May 23, 2005, "Response to Request for Additional Information for Request for Exemption - Automatic Suppression in the Mechanical Equipment Room (Fire Zone 097) and Control Room Roof (106R)"

3) Florida Power and Light Company Letter L-2006-004 to the USNRC dated January 13, 2006, "Response to Request for Additional Information Ref:

Request for Exemption - Automatic Suppression in the Mechanical Equipment Room (Fire Zone 097) and Control Room Roof (106R)"

4) Florida Power and Light Company Letter L-2006-160 to the USNRC dated July 12, 2006, "Response to Request for Additional Information For Request for Exemption - Automatic Suppression in the Mechanical Equipment Room (Fire Zone 097) and Control Room Roof (106R)"

5) USNRC Letter to Florida Power and Light Company dated September 27, 2006, "Turkey Point Units 3 and 4 - Exemption from the Requirements of 10 CFR 50, Appendix R, Subsection III.G.3 (TAC Nos. MC5542 and MC5543)"

In accordance with the provisions of 10 CFR 50.90, Florida Power and Light Company (FPL) hereby requests an amendment to the Renewed Facility Operating Licenses (RFOL) for Turkey Point Nuclear Generating Station Units 3 and 4. This application revises the existing RFOL License Condition 3.D, Fire Protection, to incorporate the reference to the exemption approved by the NRC on September 27, 2006 (Reference 5).

By FPL letter L-2004-176 (Reference 1) as supplemented by FPL letters L-2005-089 (Reference 2), L-2006-004 (Reference 3), and L-2006-160 (Reference 4), FPL requested an exemption from an FPL Group company

Florida Power and Light Company L-2012-067 Turkey Point Nuclear Generating Station Page 2 of 2 License Amendment Request 215 Request for Revision of the Turkey Point Nuclear Generating Station License Condition 3..D, Fire Protection the requirements of 10 CFR 50, Appendix R, Subsection III.G.3 regarding automatic suppression in the Mechanical Equipment Room (Fire Zone 097) and Control Room Roof (106R).

The NRC approved the requested exemption by NRC letter dated September 27, 2006 (Reference 5). This revision to the RFOL for Turkey Point Nuclear Generating Station Units 3 and 4 is requested to incorporate the September 27, 2006 date of the NRC approved exemption to the list of NRC letters supplementing the approved Fire Protection Program approved by the NRC per Safety Evaluation Report dated March 21, 1979. provides an evaluation of the proposed change. Enclosure 1 also contains the following attachments:

• Attachment 1 provides the existing RFOL pages marked up to show the proposed change.

" Attachment 2 provides the proposed RFOL changes in final typed format.

In accordance with 10 CFR 50.91, a copy of this application, with attachments and enclosure, is being provided to the designated official of the State of Florida.

If you should have any questions regarding this application, please contact Robert Tornonto, Licensing Manager, at 305-246-7327.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 2 /,9'/2012.

Very truly yours, Michael Kiley Vice President - Turkey Point Nuclear Generating Station

Enclosure:

Evaluation of Proposed Change cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point USNRC Project Manager for Turkey Point Mr. W. A. Passetti, Florida Department of Health

Enclosure 1 Turkey Point Unit 3 Docket No. 50-250 License No. DPR-31 Turkey Point Unit 4 Docket No. 50-251 License No. DPR-41 License Amendment Request No. 215 Evaluation of Proposed Change Request for Revision of the Turkey Point Nuclear Generating Station License Condition 3.D, Fire Protection Contents 1.0 Summary Description and Justification 2.0 Significant Hazards Consideration 3.0 Environmental Consideration ATTACHMENTS - Marked RFOL page - RFOL change in final typed format.

Florida Power and Light Company L-2012-067 Turkey Point Nuclear Generating Station Enclosure 1 License Amendment Request No. 215 Page 1 of 4 Request for Revision of the Turkey Point Nuclear Generating Station License Condition 3.D, Fire Protection 1.0

SUMMARY

DESCRIPTION AND JUSTIFICATION In accordance with the provisions of 10 CFR 50.90, Florida Power and Light Company (FPL) hereby requests an amendment to the Renewed Facility Operating Licenses (RFOL) for Turkey Point Nuclear Generating Station Units 3 and 4. The license amendment request (LAR) will revise the existing RFOL License Condition 3.D, Fire Protection.

The existing License Condition 3.D reads as follows:

"FPL shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR) for Turkey Point Units 3 and 4 and as approved in the Safety Evaluation Report (SER) dated March 21, 1979 and supplemented by NRC letters dated April 3, 1980, July 9, 1980, December 8, 1980, January 26, 1981, May 10, 1982, March 27, 1984, April 16, 1984, August 12, 1987, and by Safety Evaluations dated February 25, 1994, February 24, 1998, October 8, 1998, December 22, 1998, May 4, 1999, and May 5, 1999, subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire."

The proposed revision to License Condition 3.D will add the NRC approved exemption dated September 27, 2006 to the list of NRC letters which supplement the Fire Protection Program and would read as follows:

"FPL shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR) for Turkey Point Units 3 and 4 and as approved in the Safety Evaluation Report (SER) dated March 21, 1979 and supplemented by NRC letters dated April 3, 1980, July 9, 1980, December 8, 1980, January 26, 1981, May 10, 1982, March 27, 1984, April 16, 1984, August 12, 1987, and by Safety Evaluations dated February 25, 1994, February 24, 1998, October 8, 1998, December 22, 1998, May 4, 1999, May 5, 1999, and September 27, 2006, subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire."

Florida Power and Light Company L-2012-067 Turkey Point Nuclear Generating Station Enclosure 1 License Amendment Request No. 215 Page 2 of 4 Request for Revision of the Turkey Point Nuclear Generating Station License Condition 3.D, Fire Protection The proposed amendment incorporates the reference of an approved exemption from the requirements of 10 CFR 50 Appendix R, Section III.G.3 as documented in an NRC letter dated September 27, 2006, into the RFOL. Inclusion of the NRC letter reference into RFOL License Condition 3..D is an administrative change; therefore, there is no technical justification related to the proposed amendment.

2.0 SIGNIFICANT HAZARDS CONSIDERATION FPL has evaluated the proposed changes using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed amendment incorporates the reference of an approved exemption from the requirements of 10 CFR 50 Appendix R, Section III.G.3 as documented in an NRC letter dated September 27, 2006, into the Renewed Facility Operating License (RFOL) License Condition 3.D. Inclusion of the NRC letter reference into the RFOL License Condition is administrative in nature and does not involve any modifications to the safety-related structures, systems or components (SSCs). The proposed change will not alter previously evaluated Updated Final Safety Analysis Report (UFSAR) design basis accident analysis assumptions, add any accident initiators, or affect the function of the plant safety-related SSCs as to how they are operated, maintained, modified, tested, or inspected.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed amendment incorporates the reference of an approved exemption from the requirements of 10 CFR 50 Appendix R, Section III.G.3 as documented by an NRC letter dated September 27, 2006, into RFOL License Condition 3.D. Inclusion of the NRC letter reference into the RFOL is administrative in nature and does not result in the need for any

Florida Power and Light Company L-2012-067 Turkey Point Nuclear Generating Station Enclosure 1 License Amendment Request No. 215 Page 3 of 4 Request for Revision of the Turkey Point Nuclear Generating Station License Condition 3.D, Fire Protection new or different UFSAR design basis accident analysis, and no new equipment failure modes are created. It does not introduce new equipment that could create a new or different kind of accident. As a result, no new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of this proposed amendment.

Therefore, the proposed amendment does not create a possibility for an accident of a new or different type than those previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The margin of safety is associated with the confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant pressure boundary, and containment structure) to limit the level of radiation to the public in normal, off-normal and accident conditions. The proposed amendment does not alter the way any safety-related SSC functions and does not alter the way the plant is operated. The proposed amendment incorporates the reference of an approved exemption from the requirements of 10 CFR 50 Appendix R, Section III.G.3 as documented in an NRC letter dated September 27, 2006, into the RFOL. Inclusion of the NRC letter reference into RFOL License Condition 3..D is administrative in nature and does not introduce any new uncertainties or change any existing uncertainties associated with any safety limit. The proposed amendment has no impact on the structural integrity of the fuel cladding, reactor coolant pressure boundary, or containment structure. Based on the above considerations, the proposed amendment does not degrade the confidence in the ability of the fission product barriers to limit the level of radiation to the public.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, FPL concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazards is justified.

In 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.

Florida Power and Light Company L-2012-067 Turkey Point Nuclear Generating Station Enclosure 1 License Amendment Request No. 215 Page 4 of 4 Request for Revision of the Turkey Point Nuclear Generating Station License Condition 3.D, Fire Protection

3.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment requests a revision to RFOL License Condition 3.D for the Turkey Point Nuclear Generating Station Units 3 and 4 to incorporate the reference to an NRC approved exemption from the requirements of 10 CFR 50 Appendix R, Section III.G. This proposed revision to RFOL License Condition 3.D is administrative in nature and will not involve any significant construction impacts. Pursuant to 10 CFR 51.22(c)(9) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Attachment 1 Turkey Point Unit 3 Docket No. 50-250 License No. DPR-31 Turkey Point Unit 4 Docket No. 50-251 License No. DPR-41 License Amendment Request No. 215 Proposed Renewed Facility Operating License Change (Mark-Up)

(2 pages)

4 D. Fire Protection FPL shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR) for Turkey Point Units 3 and 4 and as approved in the Safety Evaluation Report (SER) dated March 21, 1979 and supplemented by NRC letters dated April 3, 1980, July 9, 1980, December 8, 1980, January 26, 1981, May 10, 1982, March 27, 1984, April 16, 1984, August 12, 1987, and by Safety Evaluations dated February 25, 1994, February 24, 1998, October 8, 1998, December 22, 1998, May 4, 1999, aod May 5, 1999 and September 27, 2006, subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Florida Power and Light

& FPL Energy Seabrook Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan - Revision 3 "submitted by letter dated May 18, 2006.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Turkey 1 Point Nuclear Generating Station CSP was approved by License Amendment No. 245.

F. 1. The licensee shall restrict the combined number of fuel assemblies loaded in the existing spent fuel pool storage racks and cask pit rack to no more than the capacity of the spent fuel pool storage racks. This condition applies at all times, except during activities associated with a reactor core offload/reload refueling condition. This restriction will ensure the capability to unload and remove the cask pit rack when cask loading operations are necessary.

2. The licensee shall establish two hold points within the rack installation procedure to ensure proper orientation of the cask rack in each unit's spent fuel pool. Verification of proper cask pit rack orientation will be implemented by an authorized Quality Control inspector during installation of the racks to ensure consistency with associated spent fuel pool criticality analysis assumptions.

Renewed License No. DPR-31 Amendment No. 246 4

D. Fire Protection FPL shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR) for Turkey Point Units 3 and 4 and as approved in the Safety Evaluation Report (SER) dated March 21, 1979 and supplemented by NRC letters dated April 3, 1980, July 9, 1980, December 8, 1980, January 26, 1981, May 10, 1982, March 27, 1984, April 16, 1984, August 12, 1987, and by Safety Evaluations dated February 25, 1994, February 24, 1998, October 8, 1998, December 22, 1998, May 4, 1999, and May 5, 1999, and September 27, 2006 subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Florida Power and Light

& FPL Energy Seabrook Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan Revision 3, "submitted by letter dated May 18, 2006 The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Turkey Point Nuclear Generating Station CSP was approved by License Amendment No. 241.

F. 1. The licensee shall restrict the combined number of fuel assemblies loaded in the existing spent fuel pool storage racks and cask pit rack to no more than the capacity of the spent fuel pool storage racks. This condition applies at all times, except during activities associated with a reactor core offload/reload refueling condition. This restriction will ensure the capability to unload and remove the cask pit rack when cask loading operations are necessary.

2. The licensee shall establish two hold points within the rack installation procedure to ensure proper orientation of the cask rack in each unit's spent fuel pool. Verification of proper cask pit rack orientation will be implemented by an authorized Quality Control inspector during installation of the racks to ensure consistency with associated spent fuel pool criticality analysis assumptions.

Renewed License No. DPR-41 Amendment No. 244-

Attachment 2 Turkey Point Unit 3 Docket No. 50-250 License No. DPR-31 Turkey Point Unit 4 Docket No. 50-251 License No. DPR-41 License Amendment Request No. 215 Proposed Renewed Facility Operating License Change (Re-Typed)

(2 pages)

4 D. Fire Protection FPL shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR) for Turkey Point Units 3 and 4 and as approved in the Safety Evaluation Report (SER) dated March 21, 1979 and supplemented by NRC letters dated April 3, 1980, July 9, 1980, December 8, 1980, January 26, 1981, May 10, 1982, March 27, 1984, April 16, 1984, August 12, 1987, and by Safety Evaluations dated February 25, 1994, February 24, 1998, October 8, 1998, December 22, 1998, May 4, 1999, May 5, 1999 and September 27, 2006, subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Florida Power and Light

& FPL Energy Seabrook Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan - Revision 3," submitted by letter dated May 18, 2006.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Turkey Point Nuclear Generating Station CSP was approved by License Amendment No. 245.

F. 1. The licensee shall restrict the combined number of fuel assemblies loaded in the existing spent fuel pool storage racks and cask pit rack to no more than the capacity of the spent fuel pool storage racks. This condition applies at all times, except during activities associated with a reactor core offload/reload refueling condition. This restriction will ensure the capability to unload and remove the cask pit rack when cask loading operations are necessary.

2. The licensee shall establish two hold points within the rack installation procedure to ensure proper orientation of the cask rack in each unit's spent fuel pool. Verification of proper cask pit rack orientation will be implemented by an authorized Quality Control inspector during installation of the racks to ensure consistency with associated spent fuel pool criticality analysis assumptions.

Renewed License No. DPR-31 Amendment No.

4 D. Fire Protection FPL shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR) for Turkey Point Units 3 and 4 and as approved in the Safety Evaluation Report (SER) dated March 21, 1979 and supplemented by NRC letters dated April 3, 1980, July 9, 1980, December 8, 1980, January 26, 1981, May 10, 1982, March 27, 1984, April 16, 1984, August 12, 1987, and by Safety Evaluations dated February 25, 1994, February 24, 1998, October 8, 1998, December 22, 1998, May 4, 1999,May 5, 1999, and September 27, 2006 subject to the following provision:

The licensee may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

E. The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Florida Power and Light

& FPL Energy Seabrook Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan Revision 3, "submitted by letter dated May 18, 2006.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Turkey Point Nuclear Generating Station CSP was approved by License Amendment No. 241.

F. 1. The licensee shall restrict the combined number of fuel assemblies loaded in the existing spent fuel pool storage racks and cask pit rack to no more than the capacity of the spent fuel pool storage racks. This condition applies at all times, except during activities associated with a reactor core offload/reload refueling condition. This restriction will ensure the capability to unload and remove the cask pit rack when cask loading operations are necessary.

2. The licensee shall establish two hold points within the rack installation procedure to ensure proper orientation of the cask rack in each unit's spent fuel pool. Verification of proper cask pit rack orientation will be implemented by an authorized Quality Control inspector during installation of the racks to ensure consistency with associated spent fuel pool criticality analysis assumptions.

Renewed License No. DPR-41 Amendment No.