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

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:0 FPL.POWERING TODAY.EMPOWERING TOMORROW.10 CFR 50.90 L-2010-022 February 16, 2010 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request No. 202 Technical Specification Changes Regarding Heavy Loads over the Spent Fuel Pools In accordance with the provisions of Sections 50.90 and 50.91 (a)(1) of Title 10 of the Code of Federal Regulations (10 CFR), Florida Power and Light Company (FPL) hereby submits an application for amendment to the Renewed Facility Operating License DPR-31 for Turkey Point Unit 3 and DPR-41 for Turkey Point Unit 4. The application proposes changes to the Technical Specifications (TS) for the removal of two TS that restrict movements of heavy loads over the spent fuel pools.The proposed changes to the TS are related to heavy load transport activities by crane travel over the spent fuel pools of Turkey Point Units 3 and 4. Specifically, it is proposed to delete TS 3/4.9.7 requirements, associated with load limitations over the spent fuel pool, and retain them in licensee controlled documents.
{{#Wiki_filter:0 FPL.
The deletion of TS 3/4.9.7 requirements is based on the operational limits and safety margins that are in place for the control of heavy loads, consistent with the Turkey Point responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, in licensee controlled documents.
POWERING TODAY.
Additionally, it is proposed to delete TS 3/4.9.12 that limits the handling of the spent fuel cask under certain conditions.
EMPOWERING TOMORROW.
The deletion of TS 3/4.9.12 is justified based on the installation of a new single-failure-proof spent fuel cask handling crane meeting the requirements of NUREG-0554, "Single-Failure-Proof Cranes For Nuclear Power Plants," May 1979.Attachment 1 provides the proposed changes and the supporting justification including the Determination of No Significant Hazards and Environmental Considerations.
10 CFR 50.90 L-2010-022 February 16, 2010 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re:       Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request No. 202 Technical Specification Changes Regarding Heavy Loads over the Spent Fuel Pools In accordance with the provisions of Sections 50.90 and 50.91 (a)(1) of Title 10 of the Code of Federal Regulations (10 CFR), Florida Power and Light Company (FPL) hereby submits an application for amendment to the Renewed Facility Operating License DPR-31 for Turkey Point Unit 3 and DPR-41 for Turkey Point Unit 4. The application proposes changes to the Technical Specifications (TS) for the removal of two TS that restrict movements of heavy loads over the spent fuel pools.
Attachment 2 contains marked copies of the proposed TS pages. Attachment 3 is a NUREG-0554 compliance matrix for the new single-failure-proof crane.Acc,(an FPL Group company Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 2 of 2 The Plant Nuclear Safety Committee has reviewed the proposed amendment.
The proposed changes to the TS are related to heavy load transport activities by crane travel over the spent fuel pools of Turkey Point Units 3 and 4. Specifically, it is proposed to delete TS 3/4.9.7 requirements, associated with load limitations over the spent fuel pool, and retain them in licensee controlled documents. The deletion of TS 3/4.9.7 requirements is based on the operational limits and safety margins that are in place for the control of heavy loads, consistent with the Turkey Point responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, in licensee controlled documents.
In accordance with 10 CFR 50.91 (b)(1), copies of the proposed amendment are being forwarded to the State Designee for the State of Florida.FPL requests approval of this application within 12 months of receipt by the NRC in order to prepare for the transfer of spent fuel to dry storage in 2011. Implementation by FPL will be within 60 days of license amendment issuance by the NRC.Please contact Mr. Robert Tomonto at 305-246-7327 if there are any questions about this license amendment application.
Additionally, it is proposed to delete TS 3/4.9.12 that limits the handling of the spent fuel cask under certain conditions. The deletion of TS 3/4.9.12 is justified based on the installation of a new single-failure-proof spent fuel cask handling crane meeting the requirements of NUREG-0554, "Single-Failure-Proof Cranes For Nuclear Power Plants," May 1979. provides the proposed changes and the supporting justification including the Determination of No Significant Hazards and Environmental Considerations. Attachment 2 contains marked copies of the proposed TS pages. Attachment 3 is a NUREG-0554 compliance matrix for the new single-failure-proof crane.
I declare under penalty of perjury that the foregoing is true and correct.Very truly yours, Executed on Michael Kiley Vice President
Acc,(
-Turkey Point Nuclear Plant Attachments:
an FPL Group company
: 1) Evaluation of Proposed Technical Specification Changes 2) Marked-up Technical Specification Pages 3) NUREG-0554 Compliance Matrix cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Mr. W. A. Passetti, Florida Department of Health Attachment 1 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Evaluation of Proposed Changes Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I Page 1 of 14


==1.0 INTRODUCTION==
Turkey Point Units 3 and 4                                                              L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 2 of 2 The Plant Nuclear Safety Committee has reviewed the proposed amendment. In accordance with 10 CFR 50.91 (b)(1), copies of the proposed amendment are being forwarded to the State Designee for the State of Florida.
FPL requests approval of this application within 12 months of receipt by the NRC in order to prepare for the transfer of spent fuel to dry storage in 2011. Implementation by FPL will be within 60 days of license amendment issuance by the NRC.
Please contact Mr. Robert Tomonto at 305-246-7327 if there are any questions about this license amendment application.
I declare under penalty of perjury that the foregoing is true and correct.
Very truly yours, Executed on                                    Michael Kiley Vice President - Turkey Point Nuclear Plant Attachments: 1)        Evaluation of Proposed Technical Specification Changes
: 2)      Marked-up Technical Specification Pages
: 3)      NUREG-0554 Compliance Matrix cc:    Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Mr. W. A. Passetti, Florida Department of Health
 
Attachment 1 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Evaluation of Proposed Changes
 
Turkey Point Units 3 and 4                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                              Page 1 of 14
 
==1.0   INTRODUCTION==


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


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


OF PROPOSED LICENSE AMENDMENTS The proposed TS changes for Turkey Point Units 3 and 4 are as follows: TS 3/4.9.7, "Crane Travel -Spent Fuel Storage Areas," would be deleted. TS 3/4.9.7 defines restrictions for heavy loads carried over irradiated fuel stored in the spent fuel pool. The load limitation defined in TS 3/4.9.7 is preserved and implemented in existing plant documents which have been established based on the operating limits and safety margins for the control of heavy loads consistent with FPL responses to NUREG-0612,"Control of Heavy Loads at Nuclear Power Plants," July 1980 [Reference I].TS 3/4.9.12, "Handling of Spent Fuel Cask," would be deleted. TS 3/4.9.12 specifies the requirements for the movement of a spent fuel cask. The deletion of TS 3/4.9.12 is based on the installation of a new single-failure-proof spent fuel cask handling crane meeting the requirements of NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979 [Reference 2].
==3.0    BACKGROUND==


==3.0 BACKGROUND==
Turkey Point Units 3 and 4 are owned and operated by FPL. The plant is located on the shore of Biscayne Bay in Miami-Dade County, Florida, about 25 miles south of Miami, Florida. The plant consists of two Westinghouse pressurized water reactor nuclear units.
Each unit utilizes a spent fuel pool for the storage of spent nuclear fuel assemblies to remove decay heat and provide radiation shielding.
The spent fuel handling crane, described in the Turkey Point Updated Final Safety Analysis Report (UFSAR), Section 9.5.4, "Fuel Handling System," and used for spent fuel handling, is a traveling bridge with a top-running trolley mounted on an overhead structure. Loads in excess of 2000 pounds are prohibited from travel over fuel assemblies by TS 3/4.9.7. The spent fuel handling crane has operational limits and safety


Turkey Point Units 3 and 4 are owned and operated by FPL. The plant is located on the shore of Biscayne Bay in Miami-Dade County, Florida, about 25 miles south of Miami, Florida. The plant consists of two Westinghouse pressurized water reactor nuclear units.Each unit utilizes a spent fuel pool for the storage of spent nuclear fuel assemblies to remove decay heat and provide radiation shielding.
Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                Page 2 of 14 margins that are currently in place for the control of heavy loads consistent with NUREG-0612. The trolley is equipped with two hoists, one on each side of the bridge.
The spent fuel handling crane, described in the Turkey Point Updated Final Safety Analysis Report (UFSAR), Section 9.5.4, "Fuel Handling System," and used for spent fuel handling, is a traveling bridge with a top-running trolley mounted on an overhead structure.
The hoists are provided with limit switches, overload sensors and other safety features to withstand two-blocking, load hang-ups and other overloading, mis-reeving, and single cable failures. The capacity of each hoist is two tons.
Loads in excess of 2000 pounds are prohibited from travel over fuel assemblies by TS 3/4.9.7. The spent fuel handling crane has operational limits and safety Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 2 of 14 margins that are currently in place for the control of heavy loads consistent with NUREG-0612.
In addition, an in-line weight sensing system is provided for each hoist to limit the lifting load to preclude accidental fuel damage should binding occur. When lifting over spent fuel, the total load is limited to 2000 pounds by procedures, limit switches and load sensors.
The trolley is equipped with two hoists, one on each side of the bridge.The hoists are provided with limit switches, overload sensors and other safety features to withstand two-blocking, load hang-ups and other overloading, mis-reeving, and single cable failures.
The current spent fuel cask handling crane is a 105/15 ton main/auxiliary hook capacity cask crane of the overhead bridge type, and services both units for spent fuel cask handling operations. The crane is located outdoors, where it can access each unit's auxiliary building, as well as adjacent outside laydown areas and the plant road. The crane is not currently single-failure-proof and its original design included only static seismic factors. Access to the cask handling/storage area of each unit's spent fuel pool is through an opening in the Auxiliary Building's roof and east wall, which is normally closed, by an inverted "L" shaped door. The crane is prevented by electrical interlocks and the physical location of the sliding roof/door opening, from carrying a load over the fuel storage areas of the spent fuel pools.
The capacity of each hoist is two tons.In addition, an in-line weight sensing system is provided for each hoist to limit the lifting load to preclude accidental fuel damage should binding occur. When lifting over spent fuel, the total load is limited to 2000 pounds by procedures, limit switches and load sensors.The current spent fuel cask handling crane is a 105/15 ton main/auxiliary hook capacity cask crane of the overhead bridge type, and services both units for spent fuel cask handling operations.
Based on the current inventory and the anticipated future generation of spent fuel at Turkey Point, FPL has decided on the implementation of an Independent Spent Fuel Storage Installation (ISFSI) for future storage of spent fuel in a dry cask storage system. In a typical cask loading campaign, the casks are loaded with spent fuel assemblies inside the spent fuel pool area; then the cask is lifted out of the pool using the spent fuel cask handling crane and placed in a cask handling facility where it is prepared for transfer to the ISFSI storage facility. The cask assembly for this system is a multiple fuel assembly configuration, in contrast to a single fuel assembly configuration as currently specified by TS 3/4.9.12.
The crane is located outdoors, where it can access each unit's auxiliary building, as well as adjacent outside laydown areas and the plant road. The crane is not currently single-failure-proof and its original design included only static seismic factors. Access to the cask handling/storage area of each unit's spent fuel pool is through an opening in the Auxiliary Building's roof and east wall, which is normally closed, by an inverted "L" shaped door. The crane is prevented by electrical interlocks and the physical location of the sliding roof/door opening, from carrying a load over the fuel storage areas of the spent fuel pools.Based on the current inventory and the anticipated future generation of spent fuel at Turkey Point, FPL has decided on the implementation of an Independent Spent Fuel Storage Installation (ISFSI) for future storage of spent fuel in a dry cask storage system. In a typical cask loading campaign, the casks are loaded with spent fuel assemblies inside the spent fuel pool area; then the cask is lifted out of the pool using the spent fuel cask handling crane and placed in a cask handling facility where it is prepared for transfer to the ISFSI storage facility.
FPL is in the process of upgrading the spent fuel cask handling crane to a single-failure-proof crane design (design rated load of 130 tons for the main hoist and 25 tons for the auxiliary hoist), which includes the replacement of the main and auxiliary hoists, trolley, bridge and electronics. Upgrade of the crane support structure is also being implemented to meet the increased load handling capabilities of the spent fuel cask handling crane.
The cask assembly for this system is a multiple fuel assembly configuration, in contrast to a single fuel assembly configuration as currently specified by TS 3/4.9.12.FPL is in the process of upgrading the spent fuel cask handling crane to a single-failure-proof crane design (design rated load of 130 tons for the main hoist and 25 tons for the auxiliary hoist), which includes the replacement of the main and auxiliary hoists, trolley, bridge and electronics.
 
Upgrade of the crane support structure is also being implemented to meet the increased load handling capabilities of the spent fuel cask handling crane.
Turkey Point Units 3 and 4                                                              L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                              Page 3 of 14
Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 3 of 14 4.0 TECHNICAL ANALYSIS Description of Proposed Changes Marked-up pages of the proposed Unit 3 and Unit 4 TS changes are shown in Attachment 2 to this application.
 
The description of the proposed changes is summarized below.The following TS are to be deleted: Section 3/4.9.7 Crane Travel -Spent Fuel Storage Areas Section 3/4.9.12 Handling of Spent Fuel Cask TS 3/4.9.7 Limiting Condition for Operation (LCO) prohibits loads in excess of 2000 pounds from travel over fuel assemblies in the spent fuel storage pools.TS 3/4.9.12 LCO specifies the spent fuel cask configuration and fuel aging requirements that must be met before the spent fuel cask can be moved. The LCO is applicable during movement of the spent fuel cask in the spent fuel storage area.Proposed Technical Specification Changes A. TS 3/4.9.7, Crane Travel -Spent Fuel Storage Areas (both units)Summary of Specification and Its Bases The TS 3/4.9.7 LCO prohibits loads weighing in excess of the nominal weight of a fuel assembly, control rod assembly, and associated handling tool from travel over irradiated fuel assemblies in the spent fuel pool. This weight limit is 2000 pounds and is the same for both units. The Surveillance Requirements (SR) specify verification of the load being 2000 pounds or less prior to the operation of the spent fuel handling crane over fuel assemblies.
==4.0    TECHNICAL ANALYSIS==
The Bases for these load restrictions support analyses assumptions to: 1) limit the activity released on a load drop to no more than the contents of a single fuel assembly; and 2) prevent a load drop from distorting fuel in the storage racks that would result in a critical geometry.Evaluation of Proposed Change TS 3/4.9.7 is being deleted because the spent fuel-related crane requirements are not of controlling importance to operational safety. This rationale is consistent with the Improved Standard Technical Specifications for Westinghouse Plants and the 1993 Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 4 of 14 NRC Policy Statement.
 
The proposed deletion of TS 3/4.9.7 is based on the guidelines of the NRC Staff Review of NSSS Vendor Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications
Description of Proposed Changes Marked-up pages of the proposed Unit 3 and Unit 4 TS changes are shown in Attachment 2 to this application. The description of the proposed changes is summarized below.
("split report"), dated May 9, 1988. TS 3/4.9.7 is listed in Appendix B, Table 2 (Westinghouse Plants) of the "split report" as an LCO which may be"wholly or partially relocated" to licensee controlled documents.
The following TS are to be deleted:
FPL proposes to delete TS 3/4.9.7 and relocate its requirements that are currently implemented in existing plant documents which include procedures and the Updated Final Safety Analysis Report. These documents have been established based on the operating limits and safety margins for the control of heavy loads consistent with FPL responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980. Therefore, an administrative basis exists for removing the TS 3/4.9.7 load limiting requirements and associated Bases from the Turkey Point Units 3 and 4 TS.B. TS 3/4.9.12, Handling of Spent Fuel Cask (both units)Summary of Specification and its Bases The TS 3/4.9.12 LCO prohibits the handling of the spent fuel cask under certain conditions.
Section 3/4.9.7                Crane Travel - Spent Fuel Storage Areas Section 3/4.9.12              Handling of Spent Fuel Cask TS 3/4.9.7 Limiting Condition for Operation (LCO) prohibits loads in excess of 2000 pounds from travel over fuel assemblies in the spent fuel storage pools.
These conditions include a limitation that the cask not be moved into the spent fuel pit (pool) until all the fuel in the spent fuel pit has decayed for a minimum of 1525 hours. Second, only a single element cask can be moved into the spent fuel pit. Finally, a fuel assembly shall not be removed from the pit in a shipping cask until it has decayed for a minimum of 120 days. Limiting spent fuel decay time from last time critical to a minimum of 1,525 hours prior to moving a spent fuel cask into the spent fuel pit ensures that potential offsite doses are a fraction of 10 CFR Part 100 limits should a dropped cask strike stored fuel assemblies.
TS 3/4.9.12 LCO specifies the spent fuel cask configuration and fuel aging requirements that must be met before the spent fuel cask can be moved. The LCO is applicable during movement of the spent fuel cask in the spent fuel storage area.
The SR require determination of the required decay times of the spent fuel assemblies prior to the movement of the spent fuel cask. In addition, the spent fuel cask handling crane interlock shall be demonstrated operable within 7 days of crane operation and at least once per 7 days when the crane is being used.The restriction to allow only a single element cask to be moved into the spent fuel pit ensures the maintenance of water inventory in the unlikely event of an uncontrolled cask descent. Use of a single element cask, which nominally weighs about twenty-five tons, increases crane safety margins by about a factor of four.Requiring that spent fuel decay time from last time critical be at least 120 days prior to moving fuel assemblies outside the fuel storage pit in a shipping cask ensures that potential offsite doses are a fraction of 10 CFR 100 limits should a dropped Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 5 of 14 cask and ruptured fuel assembly release activity directly to the atmosphere.
Proposed Technical Specification Changes A. TS 3/4.9.7, Crane Travel - Spent Fuel Storage Areas (both units)
Summary of Specification and Its Bases The TS 3/4.9.7 LCO prohibits loads weighing in excess of the nominal weight of a fuel assembly, control rod assembly, and associated handling tool from travel over irradiated fuel assemblies in the spent fuel pool. This weight limit is 2000 pounds and is the same for both units. The Surveillance Requirements (SR) specify verification of the load being 2000 pounds or less prior to the operation of the spent fuel handling crane over fuel assemblies. The Bases for these load restrictions support analyses assumptions to: 1) limit the activity released on a load drop to no more than the contents of a single fuel assembly; and 2) prevent a load drop from distorting fuel in the storage racks that would result in a critical geometry.
Evaluation of Proposed Change TS 3/4.9.7 is being deleted because the spent fuel-related crane requirements are not of controlling importance to operational safety. This rationale is consistent with the Improved Standard Technical Specifications for Westinghouse Plants and the 1993
 
Turkey Point Units 3 and 4                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                              Page 4 of 14 NRC Policy Statement. The proposed deletion of TS 3/4.9.7 is based on the guidelines of the NRC Staff Review of NSSS Vendor Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications ("split report"), dated May 9, 1988. TS 3/4.9.7 is listed in Appendix B, Table 2 (Westinghouse Plants) of the "split report" as an LCO which may be "wholly or partially relocated" to licensee controlled documents. FPL proposes to delete TS 3/4.9.7 and relocate its requirements that are currently implemented in existing plant documents which include procedures and the Updated Final Safety Analysis Report. These documents have been established based on the operating limits and safety margins for the control of heavy loads consistent with FPL responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants,"
July 1980. Therefore, an administrative basis exists for removing the TS 3/4.9.7 load limiting requirements and associated Bases from the Turkey Point Units 3 and 4 TS.
B. TS 3/4.9.12, Handling of Spent Fuel Cask (both units)
Summary of Specification and its Bases The TS 3/4.9.12 LCO prohibits the handling of the spent fuel cask under certain conditions. These conditions include a limitation that the cask not be moved into the spent fuel pit (pool) until all the fuel in the spent fuel pit has decayed for a minimum of 1525 hours. Second, only a single element cask can be moved into the spent fuel pit. Finally, a fuel assembly shall not be removed from the pit in a shipping cask until it has decayed for a minimum of 120 days. Limiting spent fuel decay time from last time critical to a minimum of 1,525 hours prior to moving a spent fuel cask into the spent fuel pit ensures that potential offsite doses are a fraction of 10 CFR Part 100 limits should a dropped cask strike stored fuel assemblies. The SR require determination of the required decay times of the spent fuel assemblies prior to the movement of the spent fuel cask. In addition, the spent fuel cask handling crane interlock shall be demonstrated operable within 7 days of crane operation and at least once per 7 days when the crane is being used.
The restriction to allow only a single element cask to be moved into the spent fuel pit ensures the maintenance of water inventory in the unlikely event of an uncontrolled cask descent. Use of a single element cask, which nominally weighs about twenty-five tons, increases crane safety margins by about a factor of four.
Requiring that spent fuel decay time from last time critical be at least 120 days prior to moving fuel assemblies outside the fuel storage pit in a shipping cask ensures that potential offsite doses are a fraction of 10 CFR 100 limits should a dropped
 
Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                               Page 5 of 14 cask and ruptured fuel assembly release activity directly to the atmosphere.
Evaluation of Proposed Change The determination has been made that TS 3/4.9.12 can be deleted based on the upgrade of the new spent fuel cask handling crane to a single-failure-proof design, meeting applicable requirements of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, and NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979, ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)" [Reference 6] and CMAA 70-04, "Specifications for Top Running Bridge & Gantry Type Multiple Girder Electric Overhead Traveling Cranes" [Reference 7]. Operating experience and inspection information related to upgrading existing cranes to single-failure-proof for the movement of heavy loads, provided in NRC Regulatory Issue Summary 2005-25 [Reference 8] is also incorporated in the design considerations.
Evaluation of Proposed Change The determination has been made that TS 3/4.9.12 can be deleted based on the upgrade of the new spent fuel cask handling crane to a single-failure-proof design, meeting applicable requirements of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, and NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979, ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)" [Reference 6] and CMAA 70-04, "Specifications for Top Running Bridge & Gantry Type Multiple Girder Electric Overhead Traveling Cranes" [Reference 7]. Operating experience and inspection information related to upgrading existing cranes to single-failure-proof for the movement of heavy loads, provided in NRC Regulatory Issue Summary 2005-25 [Reference 8] is also incorporated in the design considerations.
A Compliance Matrix is contained in Attachment 3 to this application demonstrating specific compliance with each section of NUREG-0554.
A Compliance Matrix is contained in Attachment 3 to this application demonstrating specific compliance with each section of NUREG-0554.
This implementation of the new single-failure-proof spent fuel cask handling crane eliminates the need for the cask drop accident analyses currently included in the UFSAR for each plant because the potential for a cask drop is considered to be extremely small.The single-failure-proof spent fuel cask handling crane is designed, and will be fabricated, installed and tested to ensure that a single failure will not result in the loss of the capability of the system to safely retain the load. Dynamic analysis has been performed for the applicable seismic conditions defined in the UFSAR.During a seismic event (Design Earthquake and Maximum Earthquake), the crane and main and auxiliary hoists are designed to retain control of and hold the maximum critical load (MCL). The analyzed design rated load (DRL) of the trolley and main hoist of the spent fuel cask handling crane is 130 tons. The DRL for the auxiliary hoist is 25 tons. The spent fuel cask handling crane system component parts subject to wear and exposure are designed for a minimum of 15 percent above the design rated load in accordance with Section 2.2 of NUREG-0554 for additional safety margin. Similarly, the bridge and trolley are designed to remain in place on their respective runways with their wheels prevented from leaving the tracks during a seismic event.The operational limits, interlocks, procedural and administrative controls, that Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 6 of 14 restrict the handling of heavy loads over fuel stored in the spent fuel pool will continue to be in place and will be applicable to the new spent fuel cask handling crane.The deletion of TS 3/4.9.12 is based on the new single-failure-proof crane and the implementing procedures that will meet the applicable requirements of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," Section 5.1.6, "Single Failure Proof Handling Systems," July 1980, and NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979.5.0 REGULATORY ANALYSIS Applicable Regulatory Requirements/Criteria Section 182a of the Atomic Energy Act of 1954, as amended (the Act) requires applicants for nuclear power plant operating licenses to include the TSs as part of the license. The Commission's regulatory requirements related to the content of TSs are set forth in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR). The regulation requires that the TSs include items in specific categories, including:
This implementation of the new single-failure-proof spent fuel cask handling crane eliminates the need for the cask drop accident analyses currently included in the UFSAR for each plant because the potential for a cask drop is considered to be extremely small.
(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5)administrative controls.The regulation does not specify the particular requirements to be included in the TSs.The four criteria defined by 10 CFR 50.36(c)(2)(ii)
The single-failure-proof spent fuel cask handling crane is designed, and will be fabricated, installed and tested to ensure that a single failure will not result in the loss of the capability of the system to safely retain the load. Dynamic analysis has been performed for the applicable seismic conditions defined in the UFSAR.
[Reference 3] determine whether particular items are required to be included in the TS LCOs. The design basis accidents and transient analyses discussed in Criteria 2 and 3 include any design basis event described in the UFSAR, not.just those events described in Chapters 6, "Engineered Safety Features," or Chapter 15, "Accident Analysis." The initial conditions captured under Criterion 2 should not be limited to only process variables assumed in the safety analyses, they should also include certain active design features and operating restrictions needed to preclude unanalyzed accidents.
During a seismic event (Design Earthquake and Maximum Earthquake), the crane and main and auxiliary hoists are designed to retain control of and hold the maximum critical load (MCL). The analyzed design rated load (DRL) of the trolley and main hoist of the spent fuel cask handling crane is 130 tons. The DRL for the auxiliary hoist is 25 tons. The spent fuel cask handling crane system component parts subject to wear and exposure are designed for a minimum of 15 percent above the design rated load in accordance with Section 2.2 of NUREG-0554 for additional safety margin. Similarly, the bridge and trolley are designed to remain in place on their respective runways with their wheels prevented from leaving the tracks during a seismic event.
In this context, active design features include only those design features under the control of operations personnel (i.e., licensed operators and personnel who perform control functions at the direction of licensed operators).
The operational limits, interlocks, procedural and administrative controls, that
Furthermore, should the TSs involve physical, designed-in features that prevent operations staff from immediately exceeding the assumptions in the bounding analysis in the course of operations, then the TSs would not meet Criterion 2 and could be relocated to the UFSAR or other similarly controlled document.
 
The NRC staff documented its Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 7 of 14 decisions on the relocation of TSs in the "NRC Staff Review of Nuclear Steam Supply System Vendor Groups' Application of the Commission's Interim Policy Criteria to Standard Technical Specifications," transmitted to the various nuclear industry owners groups on May 9, 1988. Existing TSs that fall within or satisfy any of the above criteria must be retained in the TSs; those that do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.
Turkey Point Units 3 and 4                                                             L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                             Page 6 of 14 restrict the handling of heavy loads over fuel stored in the spent fuel pool will continue to be in place and will be applicable to the new spent fuel cask handling crane.
NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants," dated May 1979, identifies features of the design, fabrication, installation, inspection, testing, and operation of single-failure-proof overhead crane handling systems that are used for handling critical loads. The NUREG superseded Draft Regulatory Guide 1.104, Overhead Crane Handling Systems for Nuclear Power Plants, dated 1976.In NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, the NRC staff provided regulatory guidelines for control of heavy load lifts to assure safe handling of heavy loads in areas where a load drop could impact on stored spent fuel, fuel in the reactor core, or equipment that may be required toachieve safe shutdown or permit continued decay heat removal. Section 5.1.1 of NUREG-0612 provides guidelines for reducing the likelihood of dropping heavy loads and provides criteria for establishing safe load paths; procedures for load-handling operations; training of crane operators; design, testing, inspection, and maintenance of cranes and lifting devices; and analyses of the impact of heavy load drops.The guidelines in Sections 5.1.2 through 5.1.6 ofNUREG-0612 address alternatives to either further reduce the probability of a load handling accident or mitigate the consequences of heavy load drops. These alternatives include using a single-failure-proof crane to improve reliability through increased factors of safety and through redundancy or duality in certain active components.
The deletion of TS 3/4.9.12 is based on the new single-failure-proof crane and the implementing procedures that will meet the applicable requirements of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," Section 5.1.6, "Single Failure Proof Handling Systems," July 1980, and NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979.
Criteria for design of single-failure-proof cranes are included in NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants." In NRC Bulletin (NRCB) 96-02, Movement of Heavy Loads over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment, dated April 1996, the NRC staff addressed specific instances of heavy load handling concerns and requested licensees to provide specific information detailing their extent of compliance with the guidelines and their licensing basis.6.0 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION FPL has evaluated these TS changes to determine if a significant hazard is present. The Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 8 of 14 No Significant Hazards Consideration evaluation required by 10 CFR 50.92 is provided below for each TS change.TS 3/4.9.7, Crane Travel-Spent Fuel Storage Areas (reviewed for both units)FPL has evaluated whether or not a significant hazards consideration is involved with removing the TS 3/4.9.7, "Crane Travel -Spent Fuel Storage Areas," from the Turkey Point Units 3 and 4 TS by focusing on the three standards set forth in 10 CFR 50.92,"Issuance of amendment," as discussed below: 1) Would operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
 
Response:
==5.0   REGULATORY ANALYSIS==
No The removal of TS 3/4.9.7 will not increase the probability of a fuel handling accident (FHA), as evaluated in Chapter 14.2.1 of the UFSAR, and is considered remote because of the administrative controls and physical limitations imposed on fuel handling operations.
 
The load limit restriction, in conjunction with existing plant documents (for example, Turkey Point heavy load handling procedures) that restrict crane or other heavy load handling operations provide a defense-in-depth approach to handling heavy loads in the spent fuel pool vicinity.
Applicable Regulatory Requirements/Criteria Section 182a of the Atomic Energy Act of 1954, as amended (the Act) requires applicants for nuclear power plant operating licenses to include the TSs as part of the license. The Commission's regulatory requirements related to the content of TSs are set forth in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR). The regulation requires that the TSs include items in specific categories, including: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls.
The load limitation defined in TS 3/4.9.7 is preserved and will be implemented based on the operation limits and safety margins for the control of heavy loads consistent with NUREG-0612.
The regulation does not specify the particular requirements to be included in the TSs.
The TS change does notrepresent any physical change to the plant systems, structures, or components.
The four criteria defined by 10 CFR 50.36(c)(2)(ii) [Reference 3] determine whether particular items are required to be included in the TS LCOs. The design basis accidents and transient analyses discussed in Criteria 2 and 3 include any design basis event described in the UFSAR, not.just those events described in Chapters 6, "Engineered Safety Features," or Chapter 15, "Accident Analysis." The initial conditions captured under Criterion 2 should not be limited to only process variables assumed in the safety analyses, they should also include certain active design features and operating restrictions needed to preclude unanalyzed accidents. In this context, active design features include only those design features under the control of operations personnel (i.e., licensed operators and personnel who perform control functions at the direction of licensed operators).
Therefore, the systems credited with mitigating the dose consequences of a FHA remain in place. The dose consequences of a fuel handling accident as discussed in Turkey Point UFSAR Chapter 14.2.1 will not increase because of the administrative controls and physical limitations imposed on fuel handling operations which minimize the likelihood of a FHA.Therefore, facility operation in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.
Furthermore, should the TSs involve physical, designed-in features that prevent operations staff from immediately exceeding the assumptions in the bounding analysis in the course of operations, then the TSs would not meet Criterion 2 and could be relocated to the UFSAR or other similarly controlled document. The NRC staff documented its
: 2) Would operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
 
Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I Page 9 of 14 Response:
Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                               Page 7 of 14 decisions on the relocation of TSs in the "NRC Staff Review of Nuclear Steam Supply System Vendor Groups' Application of the Commission's Interim Policy Criteria to Standard Technical Specifications," transmitted to the various nuclear industry owners groups on May 9, 1988. Existing TSs that fall within or satisfy any of the above criteria must be retained in the TSs; those that do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.
No The removal of TS 3/4.9.7 does not represent any physical change to the plant systems, structures, or components.
NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants," dated May 1979, identifies features of the design, fabrication, installation, inspection, testing, and operation of single-failure-proof overhead crane handling systems that are used for handling critical loads. The NUREG superseded Draft Regulatory Guide 1.104, Overhead Crane Handling Systems for Nuclear Power Plants, dated 1976.
The same operational functions of moving new fuel, spent fuel, or other loads over the spent fuel pool are retained and therefore do not create or increase the possibility of a new or different kind of accident from any accident previously evaluated.
In NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, the NRC staff provided regulatory guidelines for control of heavy load lifts to assure safe handling of heavy loads in areas where a load drop could impact on stored spent fuel, fuel in the reactor core, or equipment that may be required toachieve safe shutdown or permit continued decay heat removal. Section 5.1.1 of NUREG-0612 provides guidelines for reducing the likelihood of dropping heavy loads and provides criteria for establishing safe load paths; procedures for load-handling operations; training of crane operators; design, testing, inspection, and maintenance of cranes and lifting devices; and analyses of the impact of heavy load drops.
Additionally, the load limit of 2000 pounds over the spent fuel pool defined in TS 3/4.9.7 is preserved and implemented in existing plant documents and are established based on the operational limits and safety margins for the control of heavy loads consistent with NUREG-0612.
The guidelines in Sections 5.1.2 through 5.1.6 ofNUREG-0612 address alternatives to either further reduce the probability of a load handling accident or mitigate the consequences of heavy load drops. These alternatives include using a single-failure-proof crane to improve reliability through increased factors of safety and through redundancy or duality in certain active components. Criteria for design of single-failure-proof cranes are included in NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants."
Other measures which preclude the creation of a new or different type of accident include interlocks and physical stops, operator training, and load handling procedures.
In NRC Bulletin (NRCB) 96-02, Movement of Heavy Loads over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment, dated April 1996, the NRC staff addressed specific instances of heavy load handling concerns and requested licensees to provide specific information detailing their extent of compliance with the guidelines and their licensing basis.
6.0   NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION FPL has evaluated these TS changes to determine if a significant hazard is present. The
 
Turkey Point Units 3 and 4                                                             L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                           Page 8 of 14 No Significant Hazards Consideration evaluation required by 10 CFR 50.92 is provided below for each TS change.
TS 3/4.9.7, Crane Travel-Spent Fuel Storage Areas (reviewed for both units)
FPL has evaluated whether or not a significant hazards consideration is involved with removing the TS 3/4.9.7, "Crane Travel - Spent Fuel Storage Areas," from the Turkey Point Units 3 and 4 TS by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1)   Would operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The removal of TS 3/4.9.7 will not increase the probability of a fuel handling accident (FHA), as evaluated in Chapter 14.2.1 of the UFSAR, and is considered remote because of the administrative controls and physical limitations imposed on fuel handling operations. The load limit restriction, in conjunction with existing plant documents (for example, Turkey Point heavy load handling procedures) that restrict crane or other heavy load handling operations provide a defense-in-depth approach to handling heavy loads in the spent fuel pool vicinity. The load limitation defined in TS 3/4.9.7 is preserved and will be implemented based on the operation limits and safety margins for the control of heavy loads consistent with NUREG-0612. The TS change does notrepresent any physical change to the plant systems, structures, or components. Therefore, the systems credited with mitigating the dose consequences of a FHA remain in place. The dose consequences of a fuel handling accident as discussed in Turkey Point UFSAR Chapter 14.2.1 will not increase because of the administrative controls and physical limitations imposed on fuel handling operations which minimize the likelihood of a FHA.
Therefore, facility operation in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2)   Would operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
 
Turkey Point Units 3 and 4                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                             Page 9 of 14 Response: No The removal of TS 3/4.9.7 does not represent any physical change to the plant systems, structures, or components. The same operational functions of moving new fuel, spent fuel, or other loads over the spent fuel pool are retained and therefore do not create or increase the possibility of a new or different kind of accident from any accident previously evaluated. Additionally, the load limit of 2000 pounds over the spent fuel pool defined in TS 3/4.9.7 is preserved and implemented in existing plant documents and are established based on the operational limits and safety margins for the control of heavy loads consistent with NUREG-0612. Other measures which preclude the creation of a new or different type of accident include interlocks and physical stops, operator training, and load handling procedures.
Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3) Would operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?Response:
: 3)   Would operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?
No The removal of TS 3/4.9.7 does not change the operational process of moving loads over the spent fuel pool. There are no changes to any physical plant systems, structures, or components.
Response: No The removal of TS 3/4.9.7 does not change the operational process of moving loads over the spent fuel pool. There are no changes to any physical plant systems, structures, or components. The spent fuel handling crane has weight sensors that are interlocked to limit the total load. In addition, an in-line weight sensing system is provided for each hoist to limit the lifting load to preclude accidental fuel damage should binding occur. When lifting over spent fuel, the total load is limited to 2000 pounds by current procedures, limit switches and load sensors. Because of these measures no margin of safety is reduced or compromised.
The spent fuel handling crane has weight sensors that are interlocked to limit the total load. In addition, an in-line weight sensing system is provided for each hoist to limit the lifting load to preclude accidental fuel damage should binding occur. When lifting over spent fuel, the total load is limited to 2000 pounds by current procedures, limit switches and load sensors. Because of these measures no margin of safety is reduced or compromised.
Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.
Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.Based on the above, FPL concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
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),
Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I Page 10 of 14 TS 3/4.9.12, Handling of Spent Fuel Cask (reviewed for both units)FPL has evaluated whether or not a significant hazards consideration is involved with the proposed amendment of removing TS 3/4.9.12, "Handling of Spent Fuel Cask," by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: I) Would operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
and, accordingly, a finding of "no significant hazards consideration" is justified.
Response:
 
No The removal of TS 3/4.9.12 will not involve a significant increase in the probability or consequences of an accident previously evaluated.
Turkey Point Units 3 and 4                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                           Page 10 of 14 TS 3/4.9.12, Handling of Spent Fuel Cask (reviewed for both units)
The accident evaluated for the existing spent fuel cask handling crane is the drop of a single element cask as cited in UFSAR Section 14.2.1.3, "Cask Drop Accident." This cask drop accident was analyzed and the radiological dose consequence, as a result of the cask drop, is determined to be within the limits of 10 CFR 100. The current spent fuel cask handling crane at Turkey Point Units 3 and 4 has a single 105/15 ton main/auxiliary hook design capacity and is not designed as single-failure-proof.
FPL has evaluated whether or not a significant hazards consideration is involved with the proposed amendment of removing TS 3/4.9.12, "Handling of Spent Fuel Cask," by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
The new spent fuel cask handling crane will be single-failure-proof meeting all of the requirements of NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" and also NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems." The probability of a cask drop accident using a single-failure-proof crane designed and operated to these NUREG requirements is considered to be extremely small.The design for the upgrade of the spent fuel cask handling crane is to increase the capacity to 130/25 tons (main/auxiliary hook). All crane components (hoist, bridge, girders, etc.) are designed and fabricated to retain control of and hold the maximum critical load (a planned 32 element spent fuel cask) in the unlikely event of the failure of a single component, coincident with a Design or Maximum earthquake.
I)   Would operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
The objectives cited in Section 5.1 of NUREG-0612, "Recommended Guidelines," for the control of heavy loads are satisfied.
Response: No The removal of TS 3/4.9.12 will not involve a significant increase in the probability or consequences of an accident previously evaluated. The accident evaluated for the existing spent fuel cask handling crane is the drop of a single element cask as cited in UFSAR Section 14.2.1.3, "Cask Drop Accident." This cask drop accident was analyzed and the radiological dose consequence, as a result of the cask drop, is determined to be within the limits of 10 CFR 100. The current spent fuel cask handling crane at Turkey Point Units 3 and 4 has a single 105/15 ton main/auxiliary hook design capacity and is not designed as single-failure-proof. The new spent fuel cask handling crane will be single-failure-proof meeting all of the requirements of NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" and also NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems." The probability of a cask drop accident using a single-failure-proof crane designed and operated to these NUREG requirements is considered to be extremely small.
The probability of a cask drop accident using the new single-failure-proof spent fuel cask crane, as compared to the existing non-single-failure-proof crane, is therefore not increased.
The design for the upgrade of the spent fuel cask handling crane is to increase the capacity to 130/25 tons (main/auxiliary hook). All crane components (hoist, bridge, girders, etc.) are designed and fabricated to retain control of and hold the maximum critical load (a planned 32 element spent fuel cask) in the unlikely event of the failure of a single component, coincident with a Design or Maximum earthquake.
The increase of the consequences of an accident previously evaluated is also not increased because the potential for a cask drop by the new upgraded spent fuel cask handling crane is considered to be extremely small.
The objectives cited in Section 5.1 of NUREG-0612, "Recommended Guidelines,"
Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 11 of 14 Further, operational limits, interlocks, procedural and administrative controls, that restrict the handling of heavy loads over fuel stored in the spent fuel pool, provide additional defense-in depth to ensure that a load could not be dropped that would result in dose consequences greater than previously evaluated.
for the control of heavy loads are satisfied. The probability of a cask drop accident using the new single-failure-proof spent fuel cask crane, as compared to the existing non-single-failure-proof crane, is therefore not increased. The increase of the consequences of an accident previously evaluated is also not increased because the potential for a cask drop by the new upgraded spent fuel cask handling crane is considered to be extremely small.
 
Turkey Point Units 3 and 4                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                           Page 11 of 14 Further, operational limits, interlocks, procedural and administrative controls, that restrict the handling of heavy loads over fuel stored in the spent fuel pool, provide additional defense-in depth to ensure that a load could not be dropped that would result in dose consequences greater than previously evaluated.
It is concluded that facility operation in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.
It is concluded that facility operation in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2) Would operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
: 2)   Would operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response:
Response: No Operation of the spent fuel cask handling crane after the upgrade to a single-failure-proof design will remain the same as the operation of the existing spent fuel cask handling crane. The distinction is the load that will be lifted.
No Operation of the spent fuel cask handling crane after the upgrade to a single-failure-proof design will remain the same as the operation of the existing spent fuel cask handling crane. The distinction is the load that will be lifted.The new spent fuel cask is a multiple assembly cask, in contrast to a single assembly cask as currently specified for use. The current spent fuel cask handling crane is designed to lift a single element spent fuel cask. The upgraded capacity of the new spent fuel cask handling crane will allow for lifting a cask designed to hold a maximum of 32 spent fuel assemblies.
The new spent fuel cask is a multiple assembly cask, in contrast to a single assembly cask as currently specified for use. The current spent fuel cask handling crane is designed to lift a single element spent fuel cask. The upgraded capacity of the new spent fuel cask handling crane will allow for lifting a cask designed to hold a maximum of 32 spent fuel assemblies. Current operating and administrative procedures that restrict the movement of heavy loads over fuel stored in the spent fuel pool remain in place. The new spent fuel cask handling crane is designed, fabricated and tested to single-failure-proof requirements (NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" and NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems") and will be operated within the procedural and administrative framework as the currently installed spent fuel cask handling crane. Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created from the removal of TS 3/4.9.12.
Current operating and administrative procedures that restrict the movement of heavy loads over fuel stored in the spent fuel pool remain in place. The new spent fuel cask handling crane is designed, fabricated and tested to single-failure-proof requirements (NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" and NUREG-0612, Section 5.1.6,"Single Failure Proof Handling Systems")
Therefore, it can be concluded that the operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
and will be operated within the procedural and administrative framework as the currently installed spent fuel cask handling crane. Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created from the removal of TS 3/4.9.12.Therefore, it can be concluded that the operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3)   Would operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?
: 3) Would operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?
 
Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 1 Page 12 of 14 Response:
Turkey Point Units 3 and 4                                                               L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                             Page 12 of 14 Response: No The existing spent fuel cask handling crane is not designed as single-failure-proof in accordance with NUREG-0612. The new spent fuel cask handling crane is designed, and will be fabricated, installed and tested to the single-failure-proof requirements as outlined in NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems." The use of the defense-in-depth approach for the control and handling of heavy loads as cited in Section 5.1 of NUREG-0612, "Recommended Guidelines," provides assurance that there is a sufficient margin of safety in the handling of heavy loads. Thereby, the removal of TS 3/4.9.12 will not involve a significant reduction in the margin of safety.
No The existing spent fuel cask handling crane is not designed as single-failure-proof in accordance with NUREG-0612.
Defense-in-depth measures include operational limits, interlocks, procedural and administrative controls, rigging, load paths, testing, training, maintenance and other related considerations. These measures provide assurance that the margin of safety is not reduced in the operation of the facility by meeting all the requirements of NUREG-0612 and NUREG-0554. The specific requirements and FPL compliance with them is documented in the NUREG-0554 Compliance Matrix [Attachment 3 to this application].
The new spent fuel cask handling crane is designed, and will be fabricated, installed and tested to the single-failure-proof requirements as outlined in NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems." The use of the defense-in-depth approach for the control and handling of heavy loads as cited in Section 5.1 of NUREG-0612, "Recommended Guidelines," provides assurance that there is a sufficient margin of safety in the handling of heavy loads. Thereby, the removal of TS 3/4.9.12 will not involve a significant reduction in the margin of safety.Defense-in-depth measures include operational limits, interlocks, procedural and administrative controls, rigging, load paths, testing, training, maintenance and other related considerations.
These measures provide assurance that the margin of safety is not reduced in the operation of the facility by meeting all the requirements of NUREG-0612 and NUREG-0554.
The specific requirements and FPL compliance with them is documented in the NUREG-0554 Compliance Matrix [Attachment 3 to this application].
The design for the upgrade of the spent fuel cask handling crane is to increase the capacity to 130/25 tons (main/auxiliary hook). The spent fuel cask handling crane has a Main Hoist and Auxiliary Hoist Cable Safety Factor of a minimum 10:1 on nominal breaking strength at 130 tons and 25 tons respectively and is fully compliant with ASME NOG-1 Section 5425.1. The Main Hoist Hook and Auxiliary Hoist Hook Safety Factor have a 10:1 minimum on ultimate strength at 130 tons and 25 tons, respectively.
The design for the upgrade of the spent fuel cask handling crane is to increase the capacity to 130/25 tons (main/auxiliary hook). The spent fuel cask handling crane has a Main Hoist and Auxiliary Hoist Cable Safety Factor of a minimum 10:1 on nominal breaking strength at 130 tons and 25 tons respectively and is fully compliant with ASME NOG-1 Section 5425.1. The Main Hoist Hook and Auxiliary Hoist Hook Safety Factor have a 10:1 minimum on ultimate strength at 130 tons and 25 tons, respectively.
Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.Based on the above, FPL concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.
7.0 ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION 10 CFR 51.22(c)(9) provides criteria for identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment.
Based on the above, FPL concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
A proposed amendment to an operating license for a facilityrequires no environmental Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I Page 13 of 14 assessment if operation of the facility in accordance with the proposed amendment would not: (i) involve a significant hazards consideration, (ii) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) result in a significant increase in individual or cumulative occupational radiation exposure.FPL has reviewed the proposed amendment to remove two TS, which restrict movements of loads over the spent fuel pool, from the Turkey Point Nuclear Plant Unit 3 and 4 Operating Licenses.
7.0   ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION 10 CFR 51.22(c)(9) provides criteria for identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facilityrequires no environmental
It has been concluded that the proposed amendment involves no significant increase in the amounts, with no significant change in the types, of any effluents that may be released offsite since existing effluent pathways are not impacted by the proposed change and new pathways are not created. There is no significant increase in individual or cumulative occupational radiation exposure since the activities supported by the load handling systems involved in the proposed amendment are not changed. The proposed amendment also involves no significant hazards consideration as discussed in Section 6.0 of this evaluation and meets the criteria for categorical exclusion set forth in 10 CFR 51.22(b).
 
An environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.
Turkey Point Units 3 and 4                                                                 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                             Page 13 of 14 assessment if operation of the facility in accordance with the proposed amendment would not:
8.0 PRECEDENT Licensing precedents for similar changes to remove spent fuel-related heavy load limitations include: Oyster Creek received a license amendment on January 23, 2002 [Reference 4] which deleted Oyster Creek TS 5.3.1.B and 5.3.1 .C. These TS restricted the handling of heavy loads over irradiated fuel stored in the spent fuel pool. The basis for deleting these TS was the upgrade of the reactor building crane and associated handling systems to a single-failure-proof system. In comparison, from a spent fuel handling point of view, the Oyster Creek reactor building crane is equivalent to the Spent Fuel Cask Crane at Turkey Point Units 3 and 4.St. Lucie Units 1 and 2 received license amendments on April 28, 2004 [Reference 5] for the relocation of Spent Fuel Crane TS requirements by applying the 10 CFR 50.36 criteria.
(i)     involve a significant hazards consideration, (ii)     result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii)   result in a significant increase in individual or cumulative occupational radiation exposure.
The basis for the relocation of the TS was the certification that the replacement Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I Page 14 of 14 cask cranes were designed, installed, and load tested to the single-failure-proof criteria of NUREG-0554 under 10 CFR 50.59. Even though Turkey Point is not "relocating" the TS as described in the St. Lucie amendments, the load handling requirements and the associated activities, such as the replacement of the cask crane(s), are equivalent for comparison.
FPL has reviewed the proposed amendment to remove two TS, which restrict movements of loads over the spent fuel pool, from the Turkey Point Nuclear Plant Unit 3 and 4 Operating Licenses. It has been concluded that the proposed amendment involves no significant increase in the amounts, with no significant change in the types, of any effluents that may be released offsite since existing effluent pathways are not impacted by the proposed change and new pathways are not created. There is no significant increase in individual or cumulative occupational radiation exposure since the activities supported by the load handling systems involved in the proposed amendment are not changed. The proposed amendment also involves no significant hazards consideration as discussed in Section 6.0 of this evaluation and meets the criteria for categorical exclusion set forth in 10 CFR 51.22(b). An environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.
8.0   PRECEDENT Licensing precedents for similar changes to remove spent fuel-related heavy load limitations include:
Oyster Creek received a license amendment on January 23, 2002 [Reference 4] which deleted Oyster Creek TS 5.3.1.B and 5.3.1 .C. These TS restricted the handling of heavy loads over irradiated fuel stored in the spent fuel pool. The basis for deleting these TS was the upgrade of the reactor building crane and associated handling systems to a single-failure-proof system. In comparison, from a spent fuel handling point of view, the Oyster Creek reactor building crane is equivalent to the Spent Fuel Cask Crane at Turkey Point Units 3 and 4.
St. Lucie Units 1 and 2 received license amendments on April 28, 2004 [Reference 5] for the relocation of Spent Fuel Crane TS requirements by applying the 10 CFR 50.36 criteria. The basis for the relocation of the TS was the certification that the replacement


==9.0 REFERENCES==
Turkey Point Units 3 and 4                                                              L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I                                                                          Page 14 of 14 cask cranes were designed, installed, and load tested to the single-failure-proof criteria of NUREG-0554 under 10 CFR 50.59. Even though Turkey Point is not "relocating" the TS as described in the St. Lucie amendments, the load handling requirements and the associated activities, such as the replacement of the cask crane(s), are equivalent for comparison.
: 1. NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980.2. NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979.3. 10 CFR 50.36(c)(2)(ii), Technical Specifications
 
[screening criteria].
==9.0  REFERENCES==
: 4. Letter from NRC to Mr. Oliver D. Kingsley, Exelon Nuclear, "Oyster Creek Nuclear Generating Station- Issuance of Amendment Re: Handling of Heavy Loads Over Irradiated Fuel Stored in the Spent Fuel Pool (TAC No. MB1747)," January 23, 2002.5. Letter from NRC to Mr. J. A. Stall, Florida Power and Light, "St. Lucie Units 1 and 2- Issuance of Amendments Regarding the Relocation of Spent Fuel Pool Crane Technical Specification Requirements (TAC Nos. MB5667 and MB 5668)," April 28, 2004.6. ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)," May 2005.7. CMAA 70-04, "Specifications for Top Running Bridge & Gantry Type Multiple Girder Electric Overhead Traveling Cranes," January 2004 8. NRC Regulatory Issue Summary 2005-25: Clarification of NRC Guidelines for Control of Heavy Loads, October 31, 2005.
: 1. NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980.
Attachment 2 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Marked-up Technical Specification Pages INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.9 REFUELING OPERATIONS 3/4.9.1 BO RO N CO NCENTRATIO N .........................................................................
: 2. NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979.
3/4 9-1 3/4.9.2 INSTR U M ENTAT IO N ....................................................................................
: 3. 10 CFR 50.36(c)(2)(ii), Technical Specifications [screening criteria].
3/4 9-2 3/4 .9.3 D E C A Y T IM E ................................................................................................
: 4. Letter from NRC to Mr. Oliver D. Kingsley, Exelon Nuclear, "Oyster Creek Nuclear Generating Station- Issuance of Amendment Re: Handling of Heavy Loads Over Irradiated Fuel Stored in the Spent Fuel Pool (TAC No. MB1747)," January 23, 2002.
3/4 9-3 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS  
: 5. Letter from NRC to Mr. J. A. Stall, Florida Power and Light, "St. Lucie Units 1 and 2- Issuance of Amendments Regarding the Relocation of Spent Fuel Pool Crane Technical Specification Requirements (TAC Nos. MB5667 and MB 5668)," April 28, 2004.
..............................................
: 6. ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)," May 2005.
3/4 9-4 3/4.9.5 C O M M U N IC A T IO N S .....................................................................................
: 7. CMAA 70-04, "Specifications for Top Running Bridge & Gantry Type Multiple Girder Electric Overhead Traveling Cranes," January 2004
3/4 9-5 3/4.9.6 M A N IPULATO R C RA N E ...............................................................................
: 8. NRC Regulatory Issue Summary 2005-25: Clarification of NRC Guidelines for Control of Heavy Loads, October 31, 2005.
3/4 9-6/-DELETED 3/4.9.7 RANETRAVE  
 
-SPENT F L STORAGE AREAS ..................
Attachment 2 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Marked-up Technical Specification Pages
3/4 9-7 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION H igh W ater Level ..........................................................................................
 
3/4 9-8 Low W ater Level ...........................................................................................
INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION                                                                                                                      PAGE 3/4.9 REFUELING OPERATIONS 3/4.9.1      BO RO N CO NCENTRATIO N.........................................................................                3/4 9-1 3/4.9.2       INSTR UMENTAT IO N....................................................................................           3/4 9-2 3/4 .9.3     D E C AY T IME ................................................................................................ 3/4 9-3 3/4.9.4       CONTAINMENT BUILDING PENETRATIONS ..............................................                                 3/4 9-4 3/4.9.5       C O MMUNIC A T IO NS .....................................................................................       3/4 9-5 3/4.9.6       MA NIPULATO R C RA NE ...............................................................................           3/4 9-6
3/4 9-9 TURKEY POINT -UNITS 3 & 4 xii AMENDMENT NOS.A-1"ANDA-8n INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.9.9 CONTAINMENT VENTILATION ISOLATION SYSTEM ...............................................
              /-DELETED 3/4.9.7         RANETRAVE - SPENT F                         L STORAGE AREAS                             .................. 3/4 9-7 3/4.9.8       RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION High W ater Level .......................................................................................... 3/4 9-8 Low W ater Level ........................................................................................... 3/4 9-9 TURKEY POINT - UNITS 3 & 4                                     xii                             AMENDMENT NOS.A-1"ANDA-8n
3/4 9-10 3/4.9.10 REFUELING CAVITY W ATER LEVEL .........................................................................
 
3/4 9-11 3/4.9.11 W ATER LEVEL -STORAGE POOL .............................................................................
INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION                                                                                                                                   PAGE 3/4.9.9     CONTAINMENT VENTILATION ISOLATION SYSTEM ...............................................                                     3/4 9-10 3/4.9.10     REFUELING CAVITY W ATER LEVEL .........................................................................                       3/4 9-11 3/4.9.11     WATER LEVEL - STORAGE POOL .............................................................................
3/4 9-12 g-DELETED) 3/4.9.12 1, AN , eF SPEN T F.U.EL GA K ............................................................................
g-DELETED)                                                                                                                    3/4 9-12 3/4.9.12     1, AN E,*"N* eF SPEN, TF.U.EL GA K ............................................................................               3/4 9-13 3/4.9.13     RA D IATIO N M O N ITO R ING ........................................................................................         3/4 9-14 3/4.9.14     S PE NT FU EL STO RA G E ..............................................................................................       3/4 9-15 3/4.10       SPECIAL TEST EXCEPTIONS 3/4.10.1     S H U T D O W N M A R G IN .................................................................................................. 3/4 10-1 3/4.10.2     GROUP HEIGHT, INSERTION, AND POWER DISTRIBUTION LIMITS ......................                                                 3/4 10-2 3/4.10.3     P H Y S IC S T E S T S   ................................................................................................... 3/4 10-3 3/4.10.4     (This specification num ber is not used) .........................................................................           3/4 10-4 3/4.10.5     POSITION INDICATION SYSTEM - SHUTDOWN .......................................................                                 3/4 10-5 TURKEY POINT - UNITS 3 &4                                           xiii                           AMENDMENT NOS.3,*9"AND,?.,<
3/4 9-13 3/4.9.13 RA D IATIO N M O N ITO R ING ........................................................................................
 
3/4 9-14 3/4.9.14 S PE NT FU EL STO RA G E ..............................................................................................
REFUELING OPERATIONS 3/4.9.7 J .. NE TRAVEL - SPENT FUEL. STORACE AREAS
3/4 9-15 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 S H U T D O W N M A R G IN ..................................................................................................
        '-DE LETED "LMITING   CONDITION FOR OPERATION 3.9.       od   'exes       of 2000 pounds shall be prohibited from travel over fuel assemblies ntstrg           ool. A APPLICABILITY:       Witl      asemblies in the storage pool.
3/4 10-1 3/4.10.2 GROUP HEIGHT, INSERTION, AND POWER DISTRIBUTION LIMITS ......................
ACTION:
3/4 10-2 3/4.10.3 P H Y S IC S T E S T S ...................................................................................................
: a.       With the requirements oe     above specification not s   ied, place the crane load in a safe condition.
3/4 10-3 3/4.10.4 (This specification num ber is not used) .........................................................................
: b.       The provisions of Specification 3.0.     n applicable.
3/4 10-4 3/4.10.5 POSITION INDICATION SYSTEM -SHUTDOWN .......................................................
SUREL                 sai                                                                                       "ET 4.9.. nor to crane operation over fuel assemblies in the spent fuel storage pool, verify that each load is 20 nds or less.
3/4 10-5 TURKEY POINT -UNITS 3 & 4 xiii AMENDMENT REFUELING OPERATIONS 3/4.9.7 J ..NE TRAVEL -SPENT FUEL. STORACE AREAS'-DE LETED"LMITING CONDITION FOR OPERATION 3.9. od 'exes of 2000 pounds shall be prohibited from travel over fuel assemblies ntstrg ool. A APPLICABILITY:
TURKEY POINT - UNITS 3 & 4                             3/4 9-7                   AMENDMENT NOS.,2,4AND,249
Wi tl asemblies in the storage pool.ACTION: a. With the requirements oe above specification not s ied, place the crane load in a safe condition.
 
: b. The provisions of Specification 3.0. n applicable.
REFUELING OPERATIONS 3/4.9.12 j       -D LeF SPEN'T TAED~LIqe FULEL CGASK "I&IMITING CONDITION FOR OPERATION 3.91       eadling of spent fuel cask shall be limited to the following conditions:
SUREL sai "ET 4.9.. nor to crane operation over fuel assemblies in the spent fuel storage pool, verify that each load is 20 nds or less.TURKEY POINT -UNITS 3 & 4 3/4 9-7 AMENDMENT NOS.,2,4AND,249 REFUELING OPERATIONS 3/4.9.12 j -D L TAED~LIqe eF SPEN'T FULEL CGASK"I&IMITING CONDITION FOR OPERATION 3.91 eadling of spent fuel cask shall be limited to the following conditions:
: 1)     "he   spent fuel cask shall not be moved into the spent fuel pit until all the spen ffel in the pit has ayed for a minimum of one thousand five hundred twenty-five (1,525) h         rs.
: 1) "he spent fuel cask shall not be moved into the spent fuel pit until all the spen ffel in the pit has ayed for a minimum of one thousand five hundred twenty-five (1,525) h rs.2) Only a gle element cask may be moved into the spent fuel pit.3) A fuel assem shall not be removed from the spent fuel pit in hipping cask until it has'decayed for a mmum of one hundred twenty (120) days.APPLICABILITY:
: 2)       Only a     gle element cask may be moved into the spent fuel pit.
During movement o"pent fuel cask in the spent fu torage area.ACTION: With the requirement of the above specification no atisfie , suspend all movement of the spent fuel cask within the spent fuel storage area.4.9.12.1 The following required decay time of the spent fuel a mblies shall be determined prior to the movement of a spent fuel cask by verific i n of date and time the s nt fuel assemblies were placed into the spent fuel pit: a. 1525 hours of d ay of all spent fuel assemblies in the spen uel pit for movement of a spent fuel cask into the ent fuel pit.b. 120 da of decay of the spent fuel assembly in the spent fuel cask pi r to removal of the spent fuel sk from the spent fuel pit.4.9.12.2 Prior t any operations involving spent fuel cask movement into the spent fuel pit, veri only a single element ca will be moved into the spent fuel pit.4.9.1 The spent fuel cask crane interlock shall be demonstrated OPERABLE within 7 days of crane o ration an t least once per 7 days (7 days is maximum time between tests; specification 4.0.2 does not apply he en the crane is being used to maneuver the spent fuel cask.TURKEY POINT -UNITS 3 & 4 3/4 9-13 AMENDMENT NOS. ,144AND;1$4" Attachment 3 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools NUREG-0544 Compliance Matrix Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment 3 Page 1 of 42 Table of Contents NUREG-0554 Compliance Matrix Pages 2-42 NOTES: 1. NUREG-0612 incorporates NUREG-0554 as the referenced document for single-failure-proof cranes. Compliance with NUREG-0554 stated herein also ensures compliance with NUREG-0612.
: 3)       A fuel assem     shall not be removed from the spent fuel pit in     hipping cask until it has' decayed for a mmum of one hundred twenty (120) days.
: 2. The crane including main and auxiliary hoists, trolley and bridge are designed, manufactured and tested in accordance with the specific requirements of ASME NOG-I -2004 for a Type I Crane (i.e. single-failure-proof crane). The ASME committee has prepared a matrix comparing the requirements of ASME NOG-1 Type I vs. NUREG-0554.
APPLICABILITY:       During movement o"pent fuel cask in the spent fu       torage area.
This matrix indicates that a design compliant with ASME NOG-l for a Type 1 Crane meets or exceeds the intent of NUREG-0554.
ACTION:
The intent for the body of this document is to address specific requirements of NUREG-0554, unless otherwise indicated.
With the requirement of the above specification no     atisfie , suspend all movement of the spent fuel cask within the spent fuel storage area.
4.9.12.1 The following required decay time of the spent fuel a         mblies shall be determined prior to the movement of a spent fuel cask by verific i n of date and time the s nt fuel assemblies were placed into the spent fuel pit:
: a.       1525 hours of d ay of all spent fuel assemblies in the spen uel pit for movement of a spent fuel cask into the ent fuel pit.
: b.       120 da of decay of the spent fuel assembly in the spent fuel cask pi r to removal of the spent fuel sk from the spent fuel pit.
4.9.12.2 Prior t any operations involving spent fuel cask movement into the spent fuel pit, veri       only a single element ca will be moved into the spent fuel pit.
4.9.1   The spent fuel cask crane interlock shall be demonstrated OPERABLE within 7 days of crane o ration an t least once per 7 days (7 days is maximum time between tests; specification 4.0.2 does not apply he en the crane is being used to maneuver the spent fuel cask.
TURKEY POINT - UNITS 3 & 4                             3/4 9-13                     AMENDMENT NOS. ,144AND;1$4"
 
Attachment 3 Florida Power and Light Company Turkey Point Units 3 and 4 Renewed Facility Operating License Nos. DPR-31 and DPR-41 Docket Nos. 50-250 and 50-251 License Amendment Request to Change the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools NUREG-0544 Compliance Matrix
 
Turkey Point Units 3 and 4                                                             L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                           Page 1 of 42 Table of Contents NUREG-0554 Compliance Matrix                                                       Pages 2-42 NOTES:
: 1. NUREG-0612 incorporates NUREG-0554 as the referenced document for single-failure-proof cranes. Compliance with NUREG-0554 stated herein also ensures compliance with NUREG-0612.
: 2. The crane including main and auxiliary hoists, trolley and bridge are designed, manufactured and tested in accordance with the specific requirements of ASME NOG-I -
2004 for a Type I Crane (i.e. single-failure-proof crane). The ASME committee has prepared a matrix comparing the requirements of ASME NOG-1 Type I vs. NUREG-0554.
This matrix indicates that a design compliant with ASME NOG-l for a Type 1 Crane meets or exceeds the intent of NUREG-0554. The intent for the body of this document is to address specific requirements of NUREG-0554, unless otherwise indicated.
: 3. NRC REGULATORY ISSUE  
: 3. NRC REGULATORY ISSUE  


==SUMMARY==
==SUMMARY==
2005-25, SUPPLEMENT I CLARIFICATION OF NRC GUIDELINES FOR CONTROL OF HEAVY LOADS, states "ASME NOG-1,"Rules for Construction of Overhead and Gantry Cranes." In Revision 1 to Section 9.1.5 of the Standard Review Plan (NUREG-0800), the NRC staff also enhanced the RIS 2005-25, Supplement I guidelines for the design of single-failure-proof cranes. The NRC staff has concluded that the application of the criteria for Type I cranes from ASME NOG-1-2004,"Rules for Construction of Overhead and Gantry Cranes," to the design of new overhead heavy load handling systems is an acceptable method for satisfying the guidelines of NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants." These guidelines provide licensees and applicants with guidance that the NRC considers acceptable for the use in designing new single-failure-proof cranes. The NRC staff has participated in the ASME Cranes for Nuclear Facilities Committee as it
2005-25, SUPPLEMENT I CLARIFICATION OF NRC GUIDELINES FOR CONTROL OF HEAVY LOADS, states "ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes." In Revision 1 to Section 9.1.5 of the Standard Review Plan (NUREG-0800), the NRC staff also enhanced the RIS 2005-25, Supplement I guidelines for the design of single-failure-proof cranes. The NRC staff has concluded that the application of the criteria for Type I cranes from ASME NOG-1-2004, "Rules for Construction of Overhead and Gantry Cranes," to the design of new overhead heavy load handling systems is an acceptable method for satisfying the guidelines of NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants." These guidelines provide licensees and applicants with guidance that the NRC considers acceptable for the use in designing new single-failure-proof cranes. The NRC staff has participated in the ASME Cranes for Nuclear Facilities Committee as it has developed a comparison of ASME NOG-I design criteria to the criteria of NUREG-0554. The NRC staff understands that the committee will provide the comparison as an appendix to a future revision of ASME NOG-1."
: 4. This document applies to the new components supplied as part of FPL'S vendor's scope for the new crane including the new bridge, trolley, main hoist, auxiliary hoist and electrical controls.
 
Turkey Point Units 3 and 4                                                                                                L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools                                                                                                                Page 2 of 42 SEC #                NUREG-0554 GUIDANCE                          TURKEY POINT CRANE
Additionally, operator and maintenance training Is provided by the crane manufacturer on-site.}}
Additionally, operator and maintenance training Is provided by the crane manufacturer on-site.}}

Revision as of 22:28, 13 November 2019

Request to Amend License Proposed Changes to the Technical Specifications (TS) for the Removal of Two TS That Restrict Movements of Heavy Loads Over the Spent Fuel Pools
ML100600441
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 02/16/2010
From: Kiley M
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2010-022
Download: ML100600441 (65)


Text

0 FPL.

POWERING TODAY.

EMPOWERING TOMORROW.

10 CFR 50.90 L-2010-022 February 16, 2010 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request No. 202 Technical Specification Changes Regarding Heavy Loads over the Spent Fuel Pools In accordance with the provisions of Sections 50.90 and 50.91 (a)(1) of Title 10 of the Code of Federal Regulations (10 CFR), Florida Power and Light Company (FPL) hereby submits an application for amendment to the Renewed Facility Operating License DPR-31 for Turkey Point Unit 3 and DPR-41 for Turkey Point Unit 4. The application proposes changes to the Technical Specifications (TS) for the removal of two TS that restrict movements of heavy loads over the spent fuel pools.

The proposed changes to the TS are related to heavy load transport activities by crane travel over the spent fuel pools of Turkey Point Units 3 and 4. Specifically, it is proposed to delete TS 3/4.9.7 requirements, associated with load limitations over the spent fuel pool, and retain them in licensee controlled documents. The deletion of TS 3/4.9.7 requirements is based on the operational limits and safety margins that are in place for the control of heavy loads, consistent with the Turkey Point responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, in licensee controlled documents.

Additionally, it is proposed to delete TS 3/4.9.12 that limits the handling of the spent fuel cask under certain conditions. The deletion of TS 3/4.9.12 is justified based on the installation of a new single-failure-proof spent fuel cask handling crane meeting the requirements of NUREG-0554, "Single-Failure-Proof Cranes For Nuclear Power Plants," May 1979. provides the proposed changes and the supporting justification including the Determination of No Significant Hazards and Environmental Considerations. Attachment 2 contains marked copies of the proposed TS pages. Attachment 3 is a NUREG-0554 compliance matrix for the new single-failure-proof crane.

Acc,(

an FPL Group company

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 2 of 2 The Plant Nuclear Safety Committee has reviewed the proposed amendment. In accordance with 10 CFR 50.91 (b)(1), copies of the proposed amendment are being forwarded to the State Designee for the State of Florida.

FPL requests approval of this application within 12 months of receipt by the NRC in order to prepare for the transfer of spent fuel to dry storage in 2011. Implementation by FPL will be within 60 days of license amendment issuance by the NRC.

Please contact Mr. Robert Tomonto at 305-246-7327 if there are any questions about this license amendment application.

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

Very truly yours, Executed on Michael Kiley Vice President - Turkey Point Nuclear Plant Attachments: 1) Evaluation of Proposed Technical Specification Changes

2) Marked-up Technical Specification Pages
3) NUREG-0554 Compliance Matrix cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Mr. W. A. Passetti, Florida Department of Health

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

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

1.0 INTRODUCTION

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

2.0 DESCRIPTION

OF PROPOSED LICENSE AMENDMENTS The proposed TS changes for Turkey Point Units 3 and 4 are as follows:

TS 3/4.9.7, "Crane Travel - Spent Fuel Storage Areas," would be deleted. TS 3/4.9.7 defines restrictions for heavy loads carried over irradiated fuel stored in the spent fuel pool. The load limitation defined in TS 3/4.9.7 is preserved and implemented in existing plant documents which have been established based on the operating limits and safety margins for the control of heavy loads consistent with FPL responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980 [Reference I].

TS 3/4.9.12, "Handling of Spent Fuel Cask," would be deleted. TS 3/4.9.12 specifies the requirements for the movement of a spent fuel cask. The deletion of TS 3/4.9.12 is based on the installation of a new single-failure-proof spent fuel cask handling crane meeting the requirements of NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979 [Reference 2].

3.0 BACKGROUND

Turkey Point Units 3 and 4 are owned and operated by FPL. The plant is located on the shore of Biscayne Bay in Miami-Dade County, Florida, about 25 miles south of Miami, Florida. The plant consists of two Westinghouse pressurized water reactor nuclear units.

Each unit utilizes a spent fuel pool for the storage of spent nuclear fuel assemblies to remove decay heat and provide radiation shielding.

The spent fuel handling crane, described in the Turkey Point Updated Final Safety Analysis Report (UFSAR), Section 9.5.4, "Fuel Handling System," and used for spent fuel handling, is a traveling bridge with a top-running trolley mounted on an overhead structure. Loads in excess of 2000 pounds are prohibited from travel over fuel assemblies by TS 3/4.9.7. The spent fuel handling crane has operational limits and safety

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 2 of 14 margins that are currently in place for the control of heavy loads consistent with NUREG-0612. The trolley is equipped with two hoists, one on each side of the bridge.

The hoists are provided with limit switches, overload sensors and other safety features to withstand two-blocking, load hang-ups and other overloading, mis-reeving, and single cable failures. The capacity of each hoist is two tons.

In addition, an in-line weight sensing system is provided for each hoist to limit the lifting load to preclude accidental fuel damage should binding occur. When lifting over spent fuel, the total load is limited to 2000 pounds by procedures, limit switches and load sensors.

The current spent fuel cask handling crane is a 105/15 ton main/auxiliary hook capacity cask crane of the overhead bridge type, and services both units for spent fuel cask handling operations. The crane is located outdoors, where it can access each unit's auxiliary building, as well as adjacent outside laydown areas and the plant road. The crane is not currently single-failure-proof and its original design included only static seismic factors. Access to the cask handling/storage area of each unit's spent fuel pool is through an opening in the Auxiliary Building's roof and east wall, which is normally closed, by an inverted "L" shaped door. The crane is prevented by electrical interlocks and the physical location of the sliding roof/door opening, from carrying a load over the fuel storage areas of the spent fuel pools.

Based on the current inventory and the anticipated future generation of spent fuel at Turkey Point, FPL has decided on the implementation of an Independent Spent Fuel Storage Installation (ISFSI) for future storage of spent fuel in a dry cask storage system. In a typical cask loading campaign, the casks are loaded with spent fuel assemblies inside the spent fuel pool area; then the cask is lifted out of the pool using the spent fuel cask handling crane and placed in a cask handling facility where it is prepared for transfer to the ISFSI storage facility. The cask assembly for this system is a multiple fuel assembly configuration, in contrast to a single fuel assembly configuration as currently specified by TS 3/4.9.12.

FPL is in the process of upgrading the spent fuel cask handling crane to a single-failure-proof crane design (design rated load of 130 tons for the main hoist and 25 tons for the auxiliary hoist), which includes the replacement of the main and auxiliary hoists, trolley, bridge and electronics. Upgrade of the crane support structure is also being implemented to meet the increased load handling capabilities of the spent fuel cask handling crane.

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

4.0 TECHNICAL ANALYSIS

Description of Proposed Changes Marked-up pages of the proposed Unit 3 and Unit 4 TS changes are shown in Attachment 2 to this application. The description of the proposed changes is summarized below.

The following TS are to be deleted:

Section 3/4.9.7 Crane Travel - Spent Fuel Storage Areas Section 3/4.9.12 Handling of Spent Fuel Cask TS 3/4.9.7 Limiting Condition for Operation (LCO) prohibits loads in excess of 2000 pounds from travel over fuel assemblies in the spent fuel storage pools.

TS 3/4.9.12 LCO specifies the spent fuel cask configuration and fuel aging requirements that must be met before the spent fuel cask can be moved. The LCO is applicable during movement of the spent fuel cask in the spent fuel storage area.

Proposed Technical Specification Changes A. TS 3/4.9.7, Crane Travel - Spent Fuel Storage Areas (both units)

Summary of Specification and Its Bases The TS 3/4.9.7 LCO prohibits loads weighing in excess of the nominal weight of a fuel assembly, control rod assembly, and associated handling tool from travel over irradiated fuel assemblies in the spent fuel pool. This weight limit is 2000 pounds and is the same for both units. The Surveillance Requirements (SR) specify verification of the load being 2000 pounds or less prior to the operation of the spent fuel handling crane over fuel assemblies. The Bases for these load restrictions support analyses assumptions to: 1) limit the activity released on a load drop to no more than the contents of a single fuel assembly; and 2) prevent a load drop from distorting fuel in the storage racks that would result in a critical geometry.

Evaluation of Proposed Change TS 3/4.9.7 is being deleted because the spent fuel-related crane requirements are not of controlling importance to operational safety. This rationale is consistent with the Improved Standard Technical Specifications for Westinghouse Plants and the 1993

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 4 of 14 NRC Policy Statement. The proposed deletion of TS 3/4.9.7 is based on the guidelines of the NRC Staff Review of NSSS Vendor Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications ("split report"), dated May 9, 1988. TS 3/4.9.7 is listed in Appendix B, Table 2 (Westinghouse Plants) of the "split report" as an LCO which may be "wholly or partially relocated" to licensee controlled documents. FPL proposes to delete TS 3/4.9.7 and relocate its requirements that are currently implemented in existing plant documents which include procedures and the Updated Final Safety Analysis Report. These documents have been established based on the operating limits and safety margins for the control of heavy loads consistent with FPL responses to NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants,"

July 1980. Therefore, an administrative basis exists for removing the TS 3/4.9.7 load limiting requirements and associated Bases from the Turkey Point Units 3 and 4 TS.

B. TS 3/4.9.12, Handling of Spent Fuel Cask (both units)

Summary of Specification and its Bases The TS 3/4.9.12 LCO prohibits the handling of the spent fuel cask under certain conditions. These conditions include a limitation that the cask not be moved into the spent fuel pit (pool) until all the fuel in the spent fuel pit has decayed for a minimum of 1525 hours0.0177 days <br />0.424 hours <br />0.00252 weeks <br />5.802625e-4 months <br />. Second, only a single element cask can be moved into the spent fuel pit. Finally, a fuel assembly shall not be removed from the pit in a shipping cask until it has decayed for a minimum of 120 days. Limiting spent fuel decay time from last time critical to a minimum of 1,525 hours0.00608 days <br />0.146 hours <br />8.680556e-4 weeks <br />1.997625e-4 months <br /> prior to moving a spent fuel cask into the spent fuel pit ensures that potential offsite doses are a fraction of 10 CFR Part 100 limits should a dropped cask strike stored fuel assemblies. The SR require determination of the required decay times of the spent fuel assemblies prior to the movement of the spent fuel cask. In addition, the spent fuel cask handling crane interlock shall be demonstrated operable within 7 days of crane operation and at least once per 7 days when the crane is being used.

The restriction to allow only a single element cask to be moved into the spent fuel pit ensures the maintenance of water inventory in the unlikely event of an uncontrolled cask descent. Use of a single element cask, which nominally weighs about twenty-five tons, increases crane safety margins by about a factor of four.

Requiring that spent fuel decay time from last time critical be at least 120 days prior to moving fuel assemblies outside the fuel storage pit in a shipping cask ensures that potential offsite doses are a fraction of 10 CFR 100 limits should a dropped

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 5 of 14 cask and ruptured fuel assembly release activity directly to the atmosphere.

Evaluation of Proposed Change The determination has been made that TS 3/4.9.12 can be deleted based on the upgrade of the new spent fuel cask handling crane to a single-failure-proof design, meeting applicable requirements of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, and NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979, ASME NOG-1, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)" [Reference 6] and CMAA 70-04, "Specifications for Top Running Bridge & Gantry Type Multiple Girder Electric Overhead Traveling Cranes" [Reference 7]. Operating experience and inspection information related to upgrading existing cranes to single-failure-proof for the movement of heavy loads, provided in NRC Regulatory Issue Summary 2005-25 [Reference 8] is also incorporated in the design considerations.

A Compliance Matrix is contained in Attachment 3 to this application demonstrating specific compliance with each section of NUREG-0554.

This implementation of the new single-failure-proof spent fuel cask handling crane eliminates the need for the cask drop accident analyses currently included in the UFSAR for each plant because the potential for a cask drop is considered to be extremely small.

The single-failure-proof spent fuel cask handling crane is designed, and will be fabricated, installed and tested to ensure that a single failure will not result in the loss of the capability of the system to safely retain the load. Dynamic analysis has been performed for the applicable seismic conditions defined in the UFSAR.

During a seismic event (Design Earthquake and Maximum Earthquake), the crane and main and auxiliary hoists are designed to retain control of and hold the maximum critical load (MCL). The analyzed design rated load (DRL) of the trolley and main hoist of the spent fuel cask handling crane is 130 tons. The DRL for the auxiliary hoist is 25 tons. The spent fuel cask handling crane system component parts subject to wear and exposure are designed for a minimum of 15 percent above the design rated load in accordance with Section 2.2 of NUREG-0554 for additional safety margin. Similarly, the bridge and trolley are designed to remain in place on their respective runways with their wheels prevented from leaving the tracks during a seismic event.

The operational limits, interlocks, procedural and administrative controls, that

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 6 of 14 restrict the handling of heavy loads over fuel stored in the spent fuel pool will continue to be in place and will be applicable to the new spent fuel cask handling crane.

The deletion of TS 3/4.9.12 is based on the new single-failure-proof crane and the implementing procedures that will meet the applicable requirements of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," Section 5.1.6, "Single Failure Proof Handling Systems," July 1980, and NUREG-0554, "Single-Failure Proof Cranes For Nuclear Power Plants," May 1979.

5.0 REGULATORY ANALYSIS

Applicable Regulatory Requirements/Criteria Section 182a of the Atomic Energy Act of 1954, as amended (the Act) requires applicants for nuclear power plant operating licenses to include the TSs as part of the license. The Commission's regulatory requirements related to the content of TSs are set forth in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR). The regulation requires that the TSs include items in specific categories, including: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls.

The regulation does not specify the particular requirements to be included in the TSs.

The four criteria defined by 10 CFR 50.36(c)(2)(ii) [Reference 3] determine whether particular items are required to be included in the TS LCOs. The design basis accidents and transient analyses discussed in Criteria 2 and 3 include any design basis event described in the UFSAR, not.just those events described in Chapters 6, "Engineered Safety Features," or Chapter 15, "Accident Analysis." The initial conditions captured under Criterion 2 should not be limited to only process variables assumed in the safety analyses, they should also include certain active design features and operating restrictions needed to preclude unanalyzed accidents. In this context, active design features include only those design features under the control of operations personnel (i.e., licensed operators and personnel who perform control functions at the direction of licensed operators).

Furthermore, should the TSs involve physical, designed-in features that prevent operations staff from immediately exceeding the assumptions in the bounding analysis in the course of operations, then the TSs would not meet Criterion 2 and could be relocated to the UFSAR or other similarly controlled document. The NRC staff documented its

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 7 of 14 decisions on the relocation of TSs in the "NRC Staff Review of Nuclear Steam Supply System Vendor Groups' Application of the Commission's Interim Policy Criteria to Standard Technical Specifications," transmitted to the various nuclear industry owners groups on May 9, 1988. Existing TSs that fall within or satisfy any of the above criteria must be retained in the TSs; those that do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.

NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants," dated May 1979, identifies features of the design, fabrication, installation, inspection, testing, and operation of single-failure-proof overhead crane handling systems that are used for handling critical loads. The NUREG superseded Draft Regulatory Guide 1.104, Overhead Crane Handling Systems for Nuclear Power Plants, dated 1976.

In NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980, the NRC staff provided regulatory guidelines for control of heavy load lifts to assure safe handling of heavy loads in areas where a load drop could impact on stored spent fuel, fuel in the reactor core, or equipment that may be required toachieve safe shutdown or permit continued decay heat removal. Section 5.1.1 of NUREG-0612 provides guidelines for reducing the likelihood of dropping heavy loads and provides criteria for establishing safe load paths; procedures for load-handling operations; training of crane operators; design, testing, inspection, and maintenance of cranes and lifting devices; and analyses of the impact of heavy load drops.

The guidelines in Sections 5.1.2 through 5.1.6 ofNUREG-0612 address alternatives to either further reduce the probability of a load handling accident or mitigate the consequences of heavy load drops. These alternatives include using a single-failure-proof crane to improve reliability through increased factors of safety and through redundancy or duality in certain active components. Criteria for design of single-failure-proof cranes are included in NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants."

In NRC Bulletin (NRCB) 96-02, Movement of Heavy Loads over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment, dated April 1996, the NRC staff addressed specific instances of heavy load handling concerns and requested licensees to provide specific information detailing their extent of compliance with the guidelines and their licensing basis.

6.0 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION FPL has evaluated these TS changes to determine if a significant hazard is present. The

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 8 of 14 No Significant Hazards Consideration evaluation required by 10 CFR 50.92 is provided below for each TS change.

TS 3/4.9.7, Crane Travel-Spent Fuel Storage Areas (reviewed for both units)

FPL has evaluated whether or not a significant hazards consideration is involved with removing the TS 3/4.9.7, "Crane Travel - Spent Fuel Storage Areas," from the Turkey Point Units 3 and 4 TS by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1) Would operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The removal of TS 3/4.9.7 will not increase the probability of a fuel handling accident (FHA), as evaluated in Chapter 14.2.1 of the UFSAR, and is considered remote because of the administrative controls and physical limitations imposed on fuel handling operations. The load limit restriction, in conjunction with existing plant documents (for example, Turkey Point heavy load handling procedures) that restrict crane or other heavy load handling operations provide a defense-in-depth approach to handling heavy loads in the spent fuel pool vicinity. The load limitation defined in TS 3/4.9.7 is preserved and will be implemented based on the operation limits and safety margins for the control of heavy loads consistent with NUREG-0612. The TS change does notrepresent any physical change to the plant systems, structures, or components. Therefore, the systems credited with mitigating the dose consequences of a FHA remain in place. The dose consequences of a fuel handling accident as discussed in Turkey Point UFSAR Chapter 14.2.1 will not increase because of the administrative controls and physical limitations imposed on fuel handling operations which minimize the likelihood of a FHA.

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

2) Would operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I Page 9 of 14 Response: No The removal of TS 3/4.9.7 does not represent any physical change to the plant systems, structures, or components. The same operational functions of moving new fuel, spent fuel, or other loads over the spent fuel pool are retained and therefore do not create or increase the possibility of a new or different kind of accident from any accident previously evaluated. Additionally, the load limit of 2000 pounds over the spent fuel pool defined in TS 3/4.9.7 is preserved and implemented in existing plant documents and are established based on the operational limits and safety margins for the control of heavy loads consistent with NUREG-0612. Other measures which preclude the creation of a new or different type of accident include interlocks and physical stops, operator training, and load handling procedures.

Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Would operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

Response: No The removal of TS 3/4.9.7 does not change the operational process of moving loads over the spent fuel pool. There are no changes to any physical plant systems, structures, or components. The spent fuel handling crane has weight sensors that are interlocked to limit the total load. In addition, an in-line weight sensing system is provided for each hoist to limit the lifting load to preclude accidental fuel damage should binding occur. When lifting over spent fuel, the total load is limited to 2000 pounds by current procedures, limit switches and load sensors. Because of these measures no margin of safety is reduced or compromised.

Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.

Based on the above, FPL concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I Page 10 of 14 TS 3/4.9.12, Handling of Spent Fuel Cask (reviewed for both units)

FPL has evaluated whether or not a significant hazards consideration is involved with the proposed amendment of removing TS 3/4.9.12, "Handling of Spent Fuel Cask," by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

I) Would operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The removal of TS 3/4.9.12 will not involve a significant increase in the probability or consequences of an accident previously evaluated. The accident evaluated for the existing spent fuel cask handling crane is the drop of a single element cask as cited in UFSAR Section 14.2.1.3, "Cask Drop Accident." This cask drop accident was analyzed and the radiological dose consequence, as a result of the cask drop, is determined to be within the limits of 10 CFR 100. The current spent fuel cask handling crane at Turkey Point Units 3 and 4 has a single 105/15 ton main/auxiliary hook design capacity and is not designed as single-failure-proof. The new spent fuel cask handling crane will be single-failure-proof meeting all of the requirements of NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" and also NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems." The probability of a cask drop accident using a single-failure-proof crane designed and operated to these NUREG requirements is considered to be extremely small.

The design for the upgrade of the spent fuel cask handling crane is to increase the capacity to 130/25 tons (main/auxiliary hook). All crane components (hoist, bridge, girders, etc.) are designed and fabricated to retain control of and hold the maximum critical load (a planned 32 element spent fuel cask) in the unlikely event of the failure of a single component, coincident with a Design or Maximum earthquake.

The objectives cited in Section 5.1 of NUREG-0612, "Recommended Guidelines,"

for the control of heavy loads are satisfied. The probability of a cask drop accident using the new single-failure-proof spent fuel cask crane, as compared to the existing non-single-failure-proof crane, is therefore not increased. The increase of the consequences of an accident previously evaluated is also not increased because the potential for a cask drop by the new upgraded spent fuel cask handling crane is considered to be extremely small.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 11 of 14 Further, operational limits, interlocks, procedural and administrative controls, that restrict the handling of heavy loads over fuel stored in the spent fuel pool, provide additional defense-in depth to ensure that a load could not be dropped that would result in dose consequences greater than previously evaluated.

It is concluded that facility operation in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Would operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No Operation of the spent fuel cask handling crane after the upgrade to a single-failure-proof design will remain the same as the operation of the existing spent fuel cask handling crane. The distinction is the load that will be lifted.

The new spent fuel cask is a multiple assembly cask, in contrast to a single assembly cask as currently specified for use. The current spent fuel cask handling crane is designed to lift a single element spent fuel cask. The upgraded capacity of the new spent fuel cask handling crane will allow for lifting a cask designed to hold a maximum of 32 spent fuel assemblies. Current operating and administrative procedures that restrict the movement of heavy loads over fuel stored in the spent fuel pool remain in place. The new spent fuel cask handling crane is designed, fabricated and tested to single-failure-proof requirements (NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants" and NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems") and will be operated within the procedural and administrative framework as the currently installed spent fuel cask handling crane. Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created from the removal of TS 3/4.9.12.

Therefore, it can be concluded that the operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Would operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 12 of 14 Response: No The existing spent fuel cask handling crane is not designed as single-failure-proof in accordance with NUREG-0612. The new spent fuel cask handling crane is designed, and will be fabricated, installed and tested to the single-failure-proof requirements as outlined in NUREG-0612, Section 5.1.6, "Single Failure Proof Handling Systems." The use of the defense-in-depth approach for the control and handling of heavy loads as cited in Section 5.1 of NUREG-0612, "Recommended Guidelines," provides assurance that there is a sufficient margin of safety in the handling of heavy loads. Thereby, the removal of TS 3/4.9.12 will not involve a significant reduction in the margin of safety.

Defense-in-depth measures include operational limits, interlocks, procedural and administrative controls, rigging, load paths, testing, training, maintenance and other related considerations. These measures provide assurance that the margin of safety is not reduced in the operation of the facility by meeting all the requirements of NUREG-0612 and NUREG-0554. The specific requirements and FPL compliance with them is documented in the NUREG-0554 Compliance Matrix [Attachment 3 to this application].

The design for the upgrade of the spent fuel cask handling crane is to increase the capacity to 130/25 tons (main/auxiliary hook). The spent fuel cask handling crane has a Main Hoist and Auxiliary Hoist Cable Safety Factor of a minimum 10:1 on nominal breaking strength at 130 tons and 25 tons respectively and is fully compliant with ASME NOG-1 Section 5425.1. The Main Hoist Hook and Auxiliary Hoist Hook Safety Factor have a 10:1 minimum on ultimate strength at 130 tons and 25 tons, respectively.

Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.

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

7.0 ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION 10 CFR 51.22(c)(9) provides criteria for identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facilityrequires no environmental

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Attachment I Page 13 of 14 assessment if operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant hazards consideration, (ii) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) result in a significant increase in individual or cumulative occupational radiation exposure.

FPL has reviewed the proposed amendment to remove two TS, which restrict movements of loads over the spent fuel pool, from the Turkey Point Nuclear Plant Unit 3 and 4 Operating Licenses. It has been concluded that the proposed amendment involves no significant increase in the amounts, with no significant change in the types, of any effluents that may be released offsite since existing effluent pathways are not impacted by the proposed change and new pathways are not created. There is no significant increase in individual or cumulative occupational radiation exposure since the activities supported by the load handling systems involved in the proposed amendment are not changed. The proposed amendment also involves no significant hazards consideration as discussed in Section 6.0 of this evaluation and meets the criteria for categorical exclusion set forth in 10 CFR 51.22(b). An environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.

8.0 PRECEDENT Licensing precedents for similar changes to remove spent fuel-related heavy load limitations include:

Oyster Creek received a license amendment on January 23, 2002 [Reference 4] which deleted Oyster Creek TS 5.3.1.B and 5.3.1 .C. These TS restricted the handling of heavy loads over irradiated fuel stored in the spent fuel pool. The basis for deleting these TS was the upgrade of the reactor building crane and associated handling systems to a single-failure-proof system. In comparison, from a spent fuel handling point of view, the Oyster Creek reactor building crane is equivalent to the Spent Fuel Cask Crane at Turkey Point Units 3 and 4.

St. Lucie Units 1 and 2 received license amendments on April 28, 2004 [Reference 5] for the relocation of Spent Fuel Crane TS requirements by applying the 10 CFR 50.36 criteria. The basis for the relocation of the TS was the certification that the replacement

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

9.0 REFERENCES

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

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

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.9 REFUELING OPERATIONS 3/4.9.1 BO RO N CO NCENTRATIO N......................................................................... 3/4 9-1 3/4.9.2 INSTR UMENTAT IO N.................................................................................... 3/4 9-2 3/4 .9.3 D E C AY T IME ................................................................................................ 3/4 9-3 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS .............................................. 3/4 9-4 3/4.9.5 C O MMUNIC A T IO NS ..................................................................................... 3/4 9-5 3/4.9.6 MA NIPULATO R C RA NE ............................................................................... 3/4 9-6

/-DELETED 3/4.9.7 RANETRAVE - SPENT F L STORAGE AREAS .................. 3/4 9-7 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION High W ater Level .......................................................................................... 3/4 9-8 Low W ater Level ........................................................................................... 3/4 9-9 TURKEY POINT - UNITS 3 & 4 xii AMENDMENT NOS.A-1"ANDA-8n

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.9.9 CONTAINMENT VENTILATION ISOLATION SYSTEM ............................................... 3/4 9-10 3/4.9.10 REFUELING CAVITY W ATER LEVEL ......................................................................... 3/4 9-11 3/4.9.11 WATER LEVEL - STORAGE POOL .............................................................................

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

REFUELING OPERATIONS 3/4.9.7 J .. NE TRAVEL - SPENT FUEL. STORACE AREAS

'-DE LETED "LMITING CONDITION FOR OPERATION 3.9. od 'exes of 2000 pounds shall be prohibited from travel over fuel assemblies ntstrg ool. A APPLICABILITY: Witl asemblies in the storage pool.

ACTION:

a. With the requirements oe above specification not s ied, place the crane load in a safe condition.
b. The provisions of Specification 3.0. n applicable.

SUREL sai "ET 4.9.. nor to crane operation over fuel assemblies in the spent fuel storage pool, verify that each load is 20 nds or less.

TURKEY POINT - UNITS 3 & 4 3/4 9-7 AMENDMENT NOS.,2,4AND,249

REFUELING OPERATIONS 3/4.9.12 j -D LeF SPEN'T TAED~LIqe FULEL CGASK "I&IMITING CONDITION FOR OPERATION 3.91 eadling of spent fuel cask shall be limited to the following conditions:

1) "he spent fuel cask shall not be moved into the spent fuel pit until all the spen ffel in the pit has ayed for a minimum of one thousand five hundred twenty-five (1,525) h rs.
2) Only a gle element cask may be moved into the spent fuel pit.
3) A fuel assem shall not be removed from the spent fuel pit in hipping cask until it has' decayed for a mmum of one hundred twenty (120) days.

APPLICABILITY: During movement o"pent fuel cask in the spent fu torage area.

ACTION:

With the requirement of the above specification no atisfie , suspend all movement of the spent fuel cask within the spent fuel storage area.

4.9.12.1 The following required decay time of the spent fuel a mblies shall be determined prior to the movement of a spent fuel cask by verific i n of date and time the s nt fuel assemblies were placed into the spent fuel pit:

a. 1525 hours0.0177 days <br />0.424 hours <br />0.00252 weeks <br />5.802625e-4 months <br /> of d ay of all spent fuel assemblies in the spen uel pit for movement of a spent fuel cask into the ent fuel pit.
b. 120 da of decay of the spent fuel assembly in the spent fuel cask pi r to removal of the spent fuel sk from the spent fuel pit.

4.9.12.2 Prior t any operations involving spent fuel cask movement into the spent fuel pit, veri only a single element ca will be moved into the spent fuel pit.

4.9.1 The spent fuel cask crane interlock shall be demonstrated OPERABLE within 7 days of crane o ration an t least once per 7 days (7 days is maximum time between tests; specification 4.0.2 does not apply he en the crane is being used to maneuver the spent fuel cask.

TURKEY POINT - UNITS 3 & 4 3/4 9-13 AMENDMENT NOS. ,144AND;1$4"

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

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 1 of 42 Table of Contents NUREG-0554 Compliance Matrix Pages 2-42 NOTES:

1. NUREG-0612 incorporates NUREG-0554 as the referenced document for single-failure-proof cranes. Compliance with NUREG-0554 stated herein also ensures compliance with NUREG-0612.
2. The crane including main and auxiliary hoists, trolley and bridge are designed, manufactured and tested in accordance with the specific requirements of ASME NOG-I -

2004 for a Type I Crane (i.e. single-failure-proof crane). The ASME committee has prepared a matrix comparing the requirements of ASME NOG-1 Type I vs. NUREG-0554.

This matrix indicates that a design compliant with ASME NOG-l for a Type 1 Crane meets or exceeds the intent of NUREG-0554. The intent for the body of this document is to address specific requirements of NUREG-0554, unless otherwise indicated.

3. NRC REGULATORY ISSUE

SUMMARY

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

4. This document applies to the new components supplied as part of FPL'S vendor's scope for the new crane including the new bridge, trolley, main hoist, auxiliary hoist and electrical controls.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 2 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS 2.1. The replacement crane system including trolley and bridge was not utilized in the construction of the plant Construction Design criteria for construction phase nor for any construction lifts. The usage of the No exceptions And operation. replacement crane system is limited to operational load noted.

Operating handling. The replacement crane system did not have a Periods separate construction specification.

The existing crane system is being replaced with a new crane system; hence the new crane design is in Allowable design stress limits of Table accordance with the latest revision of CMAA 3.3.3.1.3-1 of CMAA Specification #70- Specification #70. The replacement crane system meets 1975. the applicable allowable stress limits for plant operation as indicated in section 3.4 of CMAA Specification #70-2004.

The replacement crane system including main hoist, nreflects the appropriate duty cycle in auxiliary hoist, trolley and bridge is being designed and Design rmanufactured in accordance with CMAA #70-2004 for CMAA Specification #70. Class C service, minimum. This service class is consistent with the anticipated crane usage.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 3 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Structural analysis for various load combinations is used to maintain allowable design margins.

Sum total of simultaneously applied loads The replacement crane system including main hoist, (static and dynamic) should not result in stress auxiliary hoist, trolley and bridge is designed for the levels causing permanent deformation, other applicable loading combinations from ASME NOG-1, than localized strain concentration, in any part CMAA Specification #70-2004 and NUREG-0554 of the handling system. design basis accident conditions (broken rope, two-blocking and load hang-up) and OBE (Operating Basis Earthquake) and SSE (Safe Shutdown Earthquake) 4.

combinations.

The main and auxiliary hoist motions employ flux vector variable frequency drives while the trolley and bridge Effects of cyclic loading induced by jogging motions employ scalar frequency drives to provide or plugging .... included in the design smooth slow speed positioning and gradual acceleration specifications.

and deceleration, eliminating the effects of cyclic loadings induced by jogging and plugging.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 4 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL I _EXCEPTIONS The main hoist, trolley and bridge is designed for the specified maximum critical load (MCL) of 130 tons.

Single-failure-proof crane should be designed The auxiliary hoist is designed for the specified MCL of to handle the maximum critical load (MCL) 25 tons.

Wearing components in the main and auxiliary hoists Increase of approximately 15% of the design including hooks, brakes, reducers and bearings are load (MCL) for component parts subjected to designed with at least a 15% increase above their 2.2 degradation due to wear and exposure. respective MCL ratings to account for degradation due to wear and exposure. No exceptions Maximum The MCL and DRL (Design Rated Load) ratings of 130 noted.

Critical The MCL rating should be clearly marked on tons and 25 tons will be clearly marked on the trolley, Load the crane. crane bridge and on both sides of the main and auxiliary hoist lower blocks.

The DRL is the same as the MCL at 130 tons for the Certain single-failure-proof cranes may be main hoist.

required to handle non-critical loads of The DRL is the same as the MCL at 25 tons for the magnitude greater than the MCL during plant auxiliary hoist. Therefore, this requirement is not maintenance period. applicable to the new crane.

The MCL and DRL ratings of 130 tons and 25 tons will The DRL rating marked on the crane be clearly marked on the trolley, crane bridge and on separately from the MCL marking.

both sides of the blocks.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 5 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS 28OF to 11 0°F, 100% maximum relative humidity, atmosphere pressure, and no emergency corrosive or hazardous conditions are specified as design criteria.

Operating environment ... specified for the The main and auxiliary hoist lower blocks are of an open crane and lifting fixtures. design to permit drainage and supplied with lubricants compatible with the spent fuel pool chemistry. FPL 2.3 does not intend to submerse the lower blocks in the spent fuel pool. No exceptions Operating The crane is located outdoors and outside of noted.

Environment Closed boxed sections of the crane structure containment. The crane is not subject to pressurization vented to avoid collapse during containment from tests or plant operational loads; therefore box pressurization. sections are closed and not vented. The crane is not exposed to containment spray.

Drainage should be provided to avoid The design of the crane includes design features to standing water in the crane structure. prevent accumulation of water on the trolley or crane structure.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 6 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Already fabricated crane structural All structural members essential to structural integrity of 2.4 components should be tested by subjecting the the new replacement crane will be subjected to impact No exceptions crane to a test lift at the lowest anticipated testing utilizing the Charpy V-notch testing method per Material noted.

operating temperature (i.e. cold proof load ASTM A-370. As such, the alternative of a cold proof Properties test). load test was not utilized and not required. .9 I

Impact testing is not required for material with Structural members (exceeding /2 inch) nominal All structural members essential to structural integrity of essential to structural integrity tested in thickness of 5/8 the new replacement crane will be subjected to impact accordance with the following impact test inch or less per testing utilizing the Charpy V-notch testing method per requirements. Either drop weight test per ASME NOG-1 ASTM A-370.

ASTM E-208 or Charpy test per ASTM A- and ASME 370 may be used for impact testing. Section III, NC-2300 and ND-2300, as applicable.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 7 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The replacement trolley and bridge structure are Toughness recommendations were developed fabricated from plates and structural shapes rolled from Toughnessarecommendationtinswere deveped carbon steel with thicknesses ranging from 1/4/4 in. to 1 1/2/2 typical material section thickness for crane in. For the structural members essential to the structural girders ... (2 in.). Later information indicates integrity of the replacement trolley and bridge structure, No exceptions that material thickness of (4 in.) or more ... the required energy values of Table NOG-4212-1 are noted.

The rules of ASME Code Class 3 Charpy satisfied. The required energy values from Table NOG-testing do not make adjustments for thickness 42a12-1 are extracted from Table ND-23 1-(a)-I of greater than (2 1/2 in)... Section III, Division 1 of the ASME Boiler and Pressure Vessel Code.

All structural members essential to structural integrity of the new replacement crane are subjected to impact testing utilizing the Charpy V-notch testing method per ASTM A-370.

2.4 As an alternative, cold proof testing The minimum operating temperature for the replacement Material consisting of a single dummy test load equal crane is specified at 28'F. Charpy impact testing is No exceptions Properties to 1.25 times the MCL shall be used to crform ed at 28°F. Chare impactFtestin is noted.

(continued) establish the minimum operating temperature. performed at a test tem specified minimum tempuretemperature operating of 30iF lessinthan the accordance with ASME NOG-1.

As such, the alternative of a cold proof load test is not utilized and not required.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 8 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The alternative of a cold proof load test is not utilized The cold proof test should be followed by a and not required. Welds on the replacement trolley and non-destructive examination of welds whose bridge structure whose failure could result in the drop of failure could result in the drop of the critical the critical load, will be nondestructively tested during load. The nondestructive examination of initial fabrication. As such, nondestructive testing critical areas should be repeated at 4 year subsequent to site load testing of the replacement crane intervals or less. and thereafter is not required.

The main hoist lower block side plates are the only components of the new replacement trolley or bridge Exception to cold Cranes and lifting fixtures made of low-alloy structure fabricated from ASTM A514 steel. Charpy proof testing of steel such as ASTM A514 should be impact testing is performed in accordance with ASTM A514, but A370 at a test temperature of 30 degrees less than the justified by subjected to the cold-proof test in any case. specified minimum operating temperature in accordance performing with ASME NOG-1. This approach is satisfactory to impact testing.

I preclude brittle fracture of materials. I Cast iron should not be used for load-bearing components such as rope drums. Cast iron Cast iron is not used for any load bearing components on may be used for electric motor frames and the replacement trolley or bridge structure.

brake drums. No exceptions

-U noted.

Alternative methods of fracture analysis that achieve an equivalent margin of safety against Not applicable for supplied equipment.

fracture ...

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 9 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS 2.5 The crane is designed to retain control of the 130 ton MCL (Main Hoist) and 25 ton MCL (Auxiliary Hoist)

Crane designed to retain control of and hold No exceptions Seismic for all load combinations including broken rope, two-the load. noted.

Design blocking, load hang-up, and OBE and SSE seismic events.

The seismic and structural analysis of the crane determined that there is no appreciable trolley or bridge Bridge and trolley designed to remain in place uplift for all applied loading combinations. The during a seismic event with their wheels replacement trolley and bridge structure will be provided prevented from leaving the tracks.

with seismic restraints to ensure the bridge and trolley remain on the respective rails.

Analysis determined that the bridge would remain on the Bridge remains on the runway with brakes runway and the trolley will remain on the bridge with applied, and the trolley remains on the crane brakes applied during an OBE or SSE event. All crane girders with brakes applied during a SSE brakes will be set when the crane is not being operated event.

or power is removed.

4 The crane's design satisfies regulatory position 2 of Crane designed and constructed in accordance Regulatory Guide 1.29. The crane is designed to remain with regulatory position 2 of Regulatory in place and hold the load during and after an OBE or Guide 1.29.

SSE event.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 10 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The MCL plus operational and seismically The crane mathematical model appropriately considers induced pendulum and swinging load effects seismically induced pendulum and swinging load

... considered in the trolley design and they effects. The pendulum effect due to horizontal seismic should be added to the trolley weight for the input and swinging load effects is evaluated and bridge design. determined to be insignificant.

Lamellar tearing is predominant in highly restrained joints such as connections utilizing thick plates and full penetration welds. The structural components of the replacement trolley and bridge structures are fabricated primarily from thin plate sections and welded together 2.6 Examine the (weld) joints by radiography or via primary structural fillet welds eliminating the ultrasonic inspection ... to ensure the absence concern of lamellar tearing. No.exceptions Lamellar of lamellar tearing in the base metal and Additionally, non-destructive examinations of critical noted.

Tearing soundness in the weld metal. welds on the replacement trolley and bridge structure are performed in accordance with ASME NOG-1.

Hoist drum shell and hub full penetration butt weld integrity are verified by radiography or ultrasonic inspection.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 11 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Non-destructive examinations of critical welds on the replacement trolley and bridge structure are performed Weld joints whose failure could result in the in accordance with ASME NOG- 1.

drop of a critical load should be Lamellar tearing is predominant in highly restrained nondestructively examined. If these weld joints such as connections utilizing thick plates and full lamellar tearing, the base metal at the joint penetration welds. The structural components of the slamellardtearing b e aost eymetaltine, replacement trolley and bridge structures are fabricated should be nondestructively examined. primarily from thin plate sections and welded together via primary structural fillet welds eliminating the concern of lamellar tearing.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 12 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Historical data, as well as projected crane usage indicates far less than 20,000 cycles will be applied to Fatigue analysis should be considered for the the replacement trolley and bridge structure. Therefore, critical load-bearing structures and additional fatigue analysis is not needed for any components of the crane handling system components on the trolley or bridge structure, as CMAA Specification #70 used 20,000 cycles, minimum, as its 2.7 design basis.

The structural fatigue usage factors from CMAA No exceptions Structural Specification #70-2004, Table 3.4.7-1 are used in the noted.

Fatigue design of the replacement trolley and bridge structure.

Cumulative fatigue usage factors should The design of the mechanical components of the reflect effects of the cyclic loading from both replacement trolley and bridge considered the allowable stresses from CMAA Specification #70-2004 for the construction and operating periods. appropriate service class (Class C). The replacement trolley and bridge structure are not used for construction.

The cumulative usage factor appropriately reflects the operating period for the crane.

Preheat temperatures for all weldments All welding procedures for the replacement trolley and bridge structure specify preheat temperatures where 2.8 specified in the weld procedures. required by AWS D .1.

Post weld heat treatment for all weldments No exceptions Welding specified in the weld procedures. To include All welding procedures for the replacement trolley and noted.

Procedures Section 2.6 welds, which shall be post-weld bridge structure specify post-weld heat treatment where heat treated in accordance with Sub Article required by AWS D1. 1, 2006. This is in accordance 3.9 ofAWS DI-1. with Sub Article 3.9 of AWS DI.1, 1976.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 13 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Primary or principal load-bearing 3.1 components, equipment, and subsystems such The quality inspections and checks for the primary or as driving equipment, drum, rope reeving principle load bearing components of the replacement No exceptions General system, hooks, blocks, control systems, and trolley and bridge structure are consistent with Table noted.

braking system should receive special 7200-1 of ASME NOG-1.

attention.

Auxiliary hoisting systems of the main crane The new single-failure-proof trolley includes a 25 ton 3.2 handling system ... single-failure-proof. single-failure-proof auxiliary hoist.

No exceptions Auxiliary Auxiliary systems or dual components for the Dual systems are provided on the main and auxiliary noted.

Systems main hoisting mechanism ... immobile safe hoists ensuring the load will be retained upon a position. component or subsystem failure.

Special features are provided in the design to sense over travel (control and power), overweight, overspeed, mis-spooling and unbalanced reeving. The electrical design 3.3 Automatic controls and limiting devices addresses the effects of phase reversal or phase loss in designed ... disorders due to inadvertent the hoist power supply (USNRC letter GL 83-042 dated No exceptions Electric operator action, component malfunction ... Aug. 26, 1983) as well as undervoltage, overvoltage, and noted.

Control will not prevent the handling system from overcurrent protection. Detection of any of the above Systems stopping and holding the load. faults removes power from the hoists, placing them in a safe condition. Bridge and trolley motions are limited by travel limit switches, which de-energize the motor at ends of travel.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 14 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Emergency stop buttons, are provided on the radio Emergency stop button added to the control transmitter and back-up pendant station. These buttons station to stop all motion. will remove power from all crane motors and set all brakes when actuated.

A crane that has been immobilized because of The main and auxiliary hoists are provided with malfunction or failure of controls or redundant brakes to allow portions of the hoist drive components while holding a critical load train to be repaired while retaining the load. The should be able to hold the load or set the load hydraulic drum brakes on the main and auxiliary hoists down while repairs or adjustments are made. can be manually modulated to lower a load in the event of hoisting equipment failure.

The hydraulic drum brakes on the main and auxiliary hoists can be manually modulated to lower a load in the 3.4 Manual operation of the hoisting system and event of hoisting equipment failure. A hand pump is the bridge and trolley transfer mechanisms to provided to allow for manual operation of the hydraulic No exceptions Emergency a safe laydown area. system without electric power. The bridge and trolley noted.

Repairs are provided with attachment points for manual operation.

Crane design and operating area include provisions ... cause release of radioactivity Provisions (i.e. attachment points) are made to allow the during corrective repairs, replacements or adjustments are being made to place the crane trolley and bridge to be moved to a safe area for handling system back into service after component repair or replacement with a suspended load.

component failure(s).

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 15 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS 4.1 The Operating and Maintenance Manual provided, Protection against excessive wire rope wear includes instructions for scheduled inspection and No exceptions

... through scheduled inspection and Reeving maintenance of the wire ropes consistent with OSHA noted.

maintenance.

System 1910.179.

Design of the rope reeving systems(s) should The design of the main and auxiliary hoist reeving be dual with each system providing separately systems are dual with each system providing the load balance ... configuration of ropes and independent load balance on the head and load blocks rope equalizer(s). through configuration of ropes and rope equalizers.

Selection of the hoisting rope or running rope The selection of the wire ropes for the main and

.to maintain efficient working of the auxiliary hoist reeving system is consistent with the wire individual wire strands ... during the hoisting rope manufacturer's application recommendations for operation. their wire rope.

Impact and dynamic loadings, including acceleration, The effects of impact loadings, acceleration emergency stops, broken rope, two-blocking, load hang-and emergency stops should be included in up and seismic are considered in sizing the main and selecting rope reeving systems. auxiliary hoist wire ropes and reeving system

_ components.

Maximum load, including static and inertia The maximum load, including the static and inertia forces, on each individual wire rope in the forces on each individual wire rope in the dual reeving dual reeving system with the MCL attached system with the design MCL attached, does not exceed should not exceed 10% of the manufacturer's 10% of the wire rope manufacturer's published breaking 4.

published breakinz strength.

- - A strength for both the main and auxiliary hoists.

-

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 16 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The wire rope selection criteria used is based upon the Consider the wire rope yield strength, as well ultimate strength of the rope. The transferred load under as ultimate strength, when specifying wire a broken rope scenario is limited to 40% of the ultimate aseutimatenstrength, whensprecaing wirope strength of the rope in accordance with the requirements rope to ensure the desired margin on rope of ASME NOG-1 to ensure satisfactory safety margins strength. are maintained, thereby minimizing rope yield strength concerns.

Maximum fleet angle from drum to lead sheave in the load block or between The hoist systems are designed such that the maximum individual sheaves should not exceed 3 1/20 at fleet angle in each hoist system does not exceed 3 1/2'.

any one point during hoisting except that for the last three (3) feet of maximum lift elevation the fleet angle may increase slightly.

4.1 Reverse bends for running wire ropes should The use of reverse bends is limited by the design. The be limited, and the use of larger sheaves design utilizes larger sheaves with running sheave to Reeving System considered in wire ropewhere fatiguea disproportional reduction life would be expectedi wire rope diameters of at least 20:1 for the main and No exceptions noexptions irerop n ftige lfewoud b epeced Sysem auxiliary hoists, thereby minimizing the stochastic noted.

(continued) from the use of standard sheave diameters for affects of fatigue.

reverse bends.

Equalizer for stretch and load on the rope The design of the main hoist equalizer is a combination reeving ... beam or sheave type or of sheave and rocker beam. The design of the auxiliary combinations thereof. hoist equalizer is of the rocker beam type.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 17 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Dual rope reeving system with individual attaching points and means for balancing or The main hoist design employs an equalizer rocker beam distributing the load between the two and hydraulic shock absorbers to balance and distribute operating rope reeving systems will permit the forces associated with load transfer. The auxiliary either rope system to hold the critical load and hoist utilizes an equalizer rocker beam to balance and transfer the critical load without excessive distribute forces associated with the load transfer.

shock in case of failure of the other rope system.

Pitch diameter of running sheaves and drums The pitch diameter of the drums and running sheaves is

... in accordance with recommendations of greater than 20 times the wire rope diameter as required CMAA Spec. #70. by Tables 4.5.2-1 and 4.6.4-1, respectively, of CMAA Specification. #70-2004 for class C service and 6 x 37 class rope.

Dual reeving system may be a single rope The main hoist design uses two drums with two ropes, from each end of a drum terminating at one of with a balanced dual reeving system with each rope the blocks or equalizer with provisions .. terminating on the drum it originated on. The auxiliary designed for total load. Alternatively, a 2-rope hoist uses one drum with two ropes with a balanced dual system may be used from each drum or reeving system with each rope terminating at the separate drums using a sheave equalizer or equalizer assembly. Each rope of the main and auxiliary beam equalizer or any other combination that hoist is capable of carrying the respective rated load with provides two separate and complete reeving a factor of safety of 5:1 against the manufacturer's systems. published breaking strength.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 18 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS 4.2 Load hoisting drum ... structural and The drum retaining devices are steel structures, which mechanical safety devices to limit the drop of ensure that a shaft or bearing failure will not allow the No exceptions Drum the drum ... from disengaging from its main or auxiliary hoist drums to disengage from the noted.

Supports holding brake system. brakes.

Head and load blocks should be designed to The main and auxiliary hoist head and load blocks are 4.3 designed to use a dual reeving design to maintain a maintain a vertical load balance about the No exceptions center of lift ... reeving system of dual vertical load balanced about the center of the lift. The noted.

Head and den . balanced dual reeving system eliminates tilt of the load Load Blocks design. block.

Load-block assembly should be provided with The designa provides providing an path single load equivalent marginpoint)

(attachment of safety with by a Design consistent two load-attaching points, ... each ... able to with NUREG-support a load of three times the load (static 10:1 factor of safety on ultimate strength consistent with 0612 Appendix C supportamic) lod othutie thel (att NUREG-0612 Appendix C and ASME NOG-1. The and ASME and dynamic) ... without permanent main hoist hook MCL is 130 tons and the auxiliary hoist Nd 1.

hook MCL is 25 tons. NOG-1.

Individual component parts of the hoist systems are designed to support a static load of 200% of the MCL of Individual component parts of the vertical 130 tons for the main hoist and 25 tons for the auxiliary Design consistent hoisting system ... head block, rope reeving hoist. The single failure point components of the main with NUREG-system, load block ... dual-load attaching and auxiliary hoist load and head blocks are designed to 0612 Appendix C device ... designed to support a static load of support static loads equivalent to their respective MCLs and ASME 200% of the MCL. based upon a 10:1 factor of safety on the average NOG- 1.

ultimate strength of the material consistent with I NUREG-0612 Appendix C and ASME NOG-1.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 19 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL

____

___ ___

____ ___ ___

___ ___ ___ ___ ____ ___ ___ ___ ___ ___ EXCEPTIONS the main hoist sister hook All load attaching points of are statically load tested at a minimum of 260 tons (i.e. 2 200% static load test performed for hook. times the MCL of 130 tons). The auxiliary hoist hook is statically load tested at a minimum of 50 tons (i.e. 2 No exceptions times the MCL of 25 tons). noted.

Measurements of the geometric configuration All main and auxiliary hoist hook critical dimensions are of the hooks ... before and after the load test. measured before and after the load test.

Hook volumetric nondestructive exam, to As required by Table 7200-1 of ASME NOG- 1, an verify soundness and integrity, before and ultrasonic examination is performed on the main and after load test. Hook surface examination, to auxiliary hoist hooks before the proof load test and a 4.3 verify soundness and integrity, before and magnetic particle test is performed on the hooks after the after load test. proof load test. No exceptions Head and Load block should be non-destructively The main and auxiliary hoist load block hook, hook nut noted.

Load Blocks examined by surface and volumetric and crosshead components are non-destructively (continued) techniques. examined by surface and volumetric inspections.

Results of examinations documented and All test reports are provided to FPL in a quality control recorded. document package.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 20 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The maximum main hoist speed for critical load handling is 5 FPM, as given in CMAA Spec. #70-1975, Fig. 70.6 for slow speed and Table 533 1.1-1 of ASME Maximum hoisting speed for the critical load NOG-1-2004.

4.4 ... limited to "slow" column of CMAA Spec.

  1. 70. The maximum auxiliary hoist speed for critical load No exceptions Hoisting handling is 15 FPM, as given in CMAA Spec. #70-1975, noted.

Speed Fig. 70.6 for slow speed and Table 5331.1-1 of ASME NOG- 1-2004.

Conservative industry practice limits the rope By design, the maximum line speed of the main hoist line speed to 50 FPM at the drum. wire ropes is less than 50 FPM at the drums.

The design of the main and auxiliary hoists employ The reeving system designed to prevent the redundant limit switches to prevent two-blocking and for cutting or crushing of the wire rope if a two- defense in depth purposes, the reeving system is blocking incident were to occur. designed to not cut or crush the wire ropes during a two-4.5 blocking event.

The mechanical and structural components of The mechanical and structural components of the main Design the complete hoisting system .... required and auxiliary hoisting systems are designed to withstand No exceptions Against strength to resist failure ... for two-blocking a two-block and load hang-up event without permanent noted.

Two- and load hang-up. deformation or damage and hence failure.

Blocking Means provided within the reeving system A mechanical slip clutch is provided in the main and located on the head or on the load-block Amcaia lpcuc spoie ntemi n combinations to absorb or control the kinetic auxiliary hoist drive trains to absorb the kinetic energy cnergyombin tations tomab o erb uriontthekof the rotating machinery during a two-blocking or load energy of rotating machinery during the hang-up event.

_____ _____ incident of two-blocking. ________________________ _______

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 21 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS As an alternative, the protective control The design uses the alternative method, as well as the 4.5 system to prevent the hoisting from two- capability to withstand a two-block event for both the blocking should include, as a minimum, two main and auxiliary hoist. Primary rotary limit switch on Design independent travel-limit devices of different the drum shaft senses both the upper and lower positions No exceptions Against noted.

designs, and activated by separate mechanical of load block travel and stops the motion by de-Two-means. These devices de-energize the hoist energizing the hoist controls. The secondary lever-Blocking (continued) drive motor and the main power supply to operated power limit switch is tripped by the lower prevent the hoist from two-blocking. block and directly breaks power to the hoist motor.

The hoist frequency drive is programmed to only provide a margin of torque above what is required to lift the load, thereby limiting input energy into the system.

Torque demand above this value faults the drive and sets The protective control system for load hang- the brake. Additionally, overload switches are installed up should consist of load cell systems in the in the main and auxiliary hoist reeving systems. The drive train or motor current sensing devices or overload switches sense overloads that result from two-mechanical load-limiting devices. blocking or load hang-up and de-energize the hoist control in the up motion. The above systems are in addition to a mechanical slip clutch installed in the hoist drive trains to absorb the energy associated with two-blocking and load hang-up.

Location of the mechanical holding brakes The main and auxiliary hoists use two shoe-type holding and their controls should provide positive, brakes on the high speed shafting to hold the load during reliable and capable means to stop and hold normal operation. The hydraulic drum caliper brakes the hoisting drum. provide single-failure-proof braking for the design.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 22 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS This should include capability to withstand The maximum torque of the driving motor is limited by the maximum torque of the driving motor if a the flux vector frequency drive. The main and auxiliary malfunction occurs and power to the driving hoist drive trains are designed to absorb this motor cannot be shutoff. corresponding maximum motor torque. The hoist holding brakes are designed to stop and hold the load under all specified loading conditions.

The auxiliary hoist, if supplied, should be The auxiliary hoist design uses the alternative method of equipped with two independent travel-limit providing two independent travel-limit switches to switches to prevent two-blocking, prevent two-blocking, as well as the capability to withstand a two-block event.

Lifting devices attached to the load block 4.6 such as ... designed with a dual or auxiliary Lifting devices and interfacing lift points used for device or combinations thereof. Each handling heavy loads will meet the associated guidance No exceptions Lifting designed or selected to support a load of 3Xs in NUREG-0612, Section 5.1.6 and the requirements of noted.

Devices the load (static and dynamic) being handled the FPL site heavy loads program.

without permanent deformation.

The main and auxiliary hoists are equipped with unbalanced load limits. When the unbalanced load 4.7 If side loads cannot be avoided, the reeving limits are reached it will trip and the hoisting motion system should be equipped with a guard that will be stopped. The main and auxiliary hoists are also No exceptions Wire Rope would keep the wire rope properly located in equipped with drum wire rope level wind limit switches noted.

Protection the grooves on the drum. that would trip when the limits are reached and stop the hoisting motion if the wire rope did not spool properly into the drum grooves.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 23 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL

______________________________EXCEPTIONS The proper functioning of the hoisting Component parts and the welds or bolting are designed machinery during load handling ensured by in accordance with CMAA Spec. #70-2004 and ASME providing adequate support strength of the NOG-1-2004. Deflection calculations are performed 4.8 individual component parts and the welds or under load to confirm frame deflection does not affect bolting that bind them together. machinery alignment. No exceptions Machinery The main and auxiliary hoist designs employ gear trains noted.

Alignment Where gear trains are interposed between the between the holding brakes and hoisting drums, but holdn brakes anould the hoistinge- drumee- f a additionally employ hydraulic drum brakes to provide gear trains should be single-failure-proof and single-failure-proof operation. The gear trains are dual should be of dual design. and single-failure-proof.

Each holding brake of the main and auxiliary hoist is 4.9 provided with adequate capacity to stop and hold the Each holding brake should have more than respective full load, but not excessive to cause damage full load stopping capacity but should not to hoisting machinery. Main and auxiliary hoisting No exceptions Braking have excessive capacity that could cause machinery is evaluated for applied brake torques for all noted.

System damage to the hoisting machinery, specified loading scenarios including normal operation, load hang-up, broken rope, two-blocking and seismic conditions.

Each holding brake of the main and auxiliary hoist is Each holding brake should have a torque designed with a minimum capacity of 125% of the rating not less than 125% of the full-load deindwtamnmucpctyo12%fth torque developed during the hoisting operation at the hoisting torque at the point of application. point of brake application.

Minimum hoisting braking system should The main and auxiliary hoist control systems are include one power control braking system provided with dynamic braking through the flux vector (not mechanical or drag brake type)... drive.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 24 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Minimum hoisting braking system should Two (2) shoe or disc type high speed holding brakes are include provided on the high speed shafting for each of the main

... two holding brakes. and auxiliary hoist.

The holding brakes in the main and auxiliary hoisting The holding brakes should be applied when systems are applied when power is off or when a drum power is off and should be automatically overspeed occurs. The braking systems are fail-safe, i.e.

applied on overspeed to the full holding automatically activated when electrical power is position if a malfunction occurs.

removed.

No exceptions noted. A clarification is provided as Minimum number of braking systems that follows:

should be operable for emergency lowering The main and auxiliary hoist emergency hydraulic drum Only the after a single brake failure should be two brake systems are provided to allow emergency lowering Emergency holding brakes for stopping and controlling of a main and auxiliary hoist critical load, respectively. Drum Brake drum rotation. system is required to safely lower the load for the main and auxiliary hoists.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 25 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS 4.9 The main and auxiliary hoist designs employ gear trains Holding brake system should be single-between the holding brakes and hoisting drums, but failure-proof; any component or gear train No exceptions Hoist additionally employ hydraulic drum brakes to provide should be dual if interposed between the noted.

Braking single-failure-proof operation. The gear trains are dual holding brakes and hoist drum.

System 4

and single-failure-proof.

-~ -

(continued) Component parts, welds, and bolting are designed in accordance with CMAA Spec. #70-2004 and ASME-Dynamic and static alignment of all hoisting NOG-1-2004, including seismic design in accordance machinery components ... range of lifted RG 1.92 and 1.61 to assure machinery alignment during loads ... positioned and anchored on the dynamic and static conditions. Deflection calculations trolley platform.

are performed under load to confirm frame deflection does not affect machinery alignment.

Provisions for manual operation of the The main and auxiliary hoist drum emergency hydraulic hoisting brakes during an emergency brakes can each be manually modulated for emergency condition. lowering.

Adequate heat dissipation from the brakes to The main and auxiliary hoist hydraulic brake systems preclude damage from excessive lowering are capable of continuous lowering of the rated load at velocity. minimum speed without exceeding the brake velocity,_ _ temperature limits.

The main and auxiliary hoist drums are supplied with remotely powered speed indicators to ensure lowering Portable instruments to indicate the lowering speeds are not excessive. The speed indicators are speed during emergency operations.

located in an area visible from where manual lowering will be performed.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 26 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Only the main and auxiliary hoist emergency hydraulic Malfunction of a holding brake during drum brakes are required to safely control the main and emergency lowering of the load ... restore auxiliary hoist loads, respectively during emergency brake to working condition before any lowering operations. Should a malfunction of the lowering is started. braking system occur, it could be restored to operation before lowering is started.

Bridge and trolley drives provided with The bridge and trolley scalar frequency drives provide control and holding braking systems ... controlled braking. Holding brakes located on each applied when power off. motor are automatically applied when power is off Bridge and trolley drives provided with The bridge and trolley motor brakes will automatically control and holding braking systems ... set when an overload condition is detected by the applied on overload, frequency drive.

Bridge and trolley drives provided with The bridge and trolley motor brakes will automatically 5.1 control and holding braking systems ... set in the event of a drive failure.

applied on failure in the drive system. No exceptions Braking Maximum torque capability of the driving The maximum torque capacity of the driving motor and noted.

Capacity motor and gear reducer ... not exceed the gear reducer for bridge and trolley motions is selected to capability of the gear train and brakes to stop not exceed the capacity of the gear train and brakes to the trolley and bridge from the maximum stop the motion from the maximum speed with the speed with DRL attached. design rated load attached.

Incremental or fractional inch movements should be provided by such items as variable Subject provision is provided for bridge and trolley via speed controls or inching motor drives, use of scalar frequency drive controls.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 27 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS 5.1 The bridge and trolley control and holding brakes are Control and holding brakes rated at 100% of No exceptions capable of applying a counter torque that is 100% of maximum torque that can be developed at the noted.

Braking maximum drive torque that can be developed at the point point of application.

Capacity of application.

(continued) The trolley is provided with the A-4 drive arrangement per CMAA Spec. #70-2004. One mechanical brake is If two mechanical brakes, one for control and provided for each drive (i.e. 2 total).

one for holding ... adjusted with one brake leading ... The bridge is provided with the A-4 drive arrangement per CMAA Spec. #70-2004. One mechanical brake is provided for each drive (i.e. 2 total).

The bridge and trolley motors are provided with spring Brakes mechanically tripped to the on or set, electrically released holding brakes that are holding position in the event of power supply automatically applied when power is interrupted. For an malfunction or an overspeed condition. overspeed situation, the frequency drives would sense an over voltage condition and the traverse brakes would set and prevent further travel.

Provisions made for manual emergency The bridge and trolley brakes include a manual release operation of the brakes. lever to permit manual emergency operation.

Holding brake should be designed so that it Design of the bridge and trolley holding brakes is such cannot be used as a foot-operated slowdown that they cannot be used as a foot-operated slowdown brake. brake.

Drag brakes should not be used. Drag brakes are not used for the bridge or trolley drives.

L I -

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 28 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The opposite drive wheels of the bridge and trolley are Oposmatched and identical diameterso inspected and found to be within the tolerance of +/- 0.010 inch.

The bridge and trolley speeds are in compliance with the Trolley and bridge slow speed limits of slow operating speeds given in CMAA Specification

  1. 70-1975 and Tables 5332.1-1The and 5333.1-1 of ASME NOG-1 for 130 ton capacity. bridge speed is 50 FPM and the trolley speed is 40 FPM.

Mechanical limiting devices provided to Positive mechanical end stops will be installed on the control or prevent over travel and overspeed runway for limiting bridge travel and on the bridge of the trolley and bridge. girders for limiting trolley travel.

Travel limit switches are provided for the bridge and Electrical limiting devices provided to control trolley to prevent over travel. For an overspeed or prevent over travel and overspeed of the situation, the frequency drives would sense an over trolley and bridge. voltage condition and the traverse brakes would set and 5.2 prevent further travel. No exceptions Buffers for bridge and trolley travel should be Compression bumpers, attached to the trolley and noted.

Safety Stops the and olle rails, bridge, are included for buffering contact with end of included at the end of the rails. travel stops.

Safety devices such as limit-type switches provided for malfunction ... should be in Trolley and bridge limit switches are provided as safety addition to and separate from the limiting devices, in addition to the end stops and bumpers. The means or control devices provided for switches are not intended for control of the trolley and operation. bridge during normal crane operations.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 29 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The design of the individual components of the main and auxiliary hoisting systems are based on the maximum Horsepower rating of the hoist driving motor torque capability (when hoisting the respective MCL at Horsmatched with the calculated ... design load maximum acceleration and rated speed) of the hoist and acceleration to the design hoisting speed. motor. The main and auxiliary hoist acceleration rates are controlled via the flux vector drive. Control of 6.1 acceleration limits strain on the machinery and load-carrying devices. No exceptions Driver To preclude excessive motor torque, the The maximum motor torque is limited by the flux vector noted.

Selection maximum torque capability of the electric frequency drive, preventing excessive motor torque motor drive for hoisting should not exceed the build-up. This rated motor torque is less than the torque rating or capability of the individual capacity of the individual hoist components under all components of the hoisting system required to normal operating conditions, ensuring the motor does hoist the MCL at the maximum design hoist not overpower the hoist components. The main and speed. Over power and overspeed conditions auxiliary hoists have an overspeed switch, which causes should be considered an operating hazard. all brakes to set when tripped.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 30 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The hoisting motion for the main and auxiliary hoist can each be stopped within 3 inches with the respective maximum critical load at maximum design hoist speed 6.1 with all brakes operating.

Controls capable of stopping the hoisting No exceptions Driver movement ... maximum hoisting movement Additionally, the defense-in-depth design of the main noted.

Selection of 3 inches an acceptable stopping distance. and auxiliary hoist braking systems provides the (continued) capability of stopping the maximum critical load at maximum design hoist speed within 5 inches, with each of the three (3) individual brakes, being the two (2) holding brakes and one (1) emergency brake system.

The main and auxiliary hoists are designed to stop and Prudent to include safety devices in the safely hold the load following any of the following fault control system ... to ensure the controls will conditions: overload, overspeed, over travel, wire rope return to or maintain a safe holding position in mis-spooling, and unbalanced load. Electrical design case of malfunction. Electrical circuit design includes provisions for the effects of overvoltage, undervoltage, phase reversal, or phase loss in the hoist I power supply.

Emergency stop buttons that will remove power from all For elaborate control systems, radio control motors and set all brakes are provided on the radio

... an "emergency stop button" placed at transmitter and on the back-up pendant station.

ground level to remove power from the crane Additionally, a floor mounted conductor bar disconnect independent of the crane controls.

switch is provided to remove all crane power.

a.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 31 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL

___

___ ___ ____ ___

_ ___ ___

___ ___ __ ___ ___ ___ ___ ___ ___ ___ ___ __ EXCEPTIONS For cranes with a DRL rating much higher The DRL and MCL for the main hoist are the same at than the MCL rating ... electrical or 130 tons. The DRL and MCL for the auxiliary hoist are mechanical resetting of the overload sensing the same at 25 tons. The trip points or set points for the device, away from the operator cab and main and auxiliary hoist overload sensing devices are included in an administrative program. based on 130 tons and 25 tons, respectively.

Control system provided should include Hoisting (raising and lowering) of all loads, including consideration of the hoisting (raising and the rated load, is considered in the design of the control lowering) of all loads, including the rated systems for the single-failure-proof crane.

load.

Control system(s) provided should include The effects of the inertia of the rotating hoisting 6.2 consideration of... the effects of the inertia of machinery such as motor armature, shafting and the rotating hoisting machinery, ... and drum. coupling, gear reducer, and drum are considered in the No exceptions Driver therotatnghoistngmachinry,_..._nddrum.design of the main and auxiliary hoist control systems.

The crane will not be used to move individual spent fuel noted.

Control Systems Control system adaptable to include interlocks elements. The main hoist will be used predominately to lift spent fuel casks and cask components. The design that will prevent trolley and bridge movements while spent fuel elements are auxiliary ahoist includes provision to prevent operation duringbridge, trolley main hoist and operation.

a reactor vessel or storage axlayhitoeaindrn anhitoeain rack. lifted free of being An operator controlled selector switch is provided on the remote radio transmitter and cab to allow the subject feature.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 32 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The main and auxiliary hoist designs employ sensors in Means provided in the motor control circuits the motor control circuits to detect and respond to to sense and respond to such items as excessive electrical current, excessive motor temperature excessive electric current, excessive motor via thermostats embedded in the motor windings, over temperature, overspeed, overload, and over travel via the hoisting limit switches, overspeed via the 6.3 travel. drum overspeed limit, and overload via the weight sensing switch. No exceptions Malfunction The main and auxiliary hoist dynamic braking systems noted.

Protection Controls should be provided to absorb the are designed to absorb the kinetic energy of the rotating kinetic energy of the rotating machinery and machinery and stop the hoisting motion should one rope kintop...ic energy eorone of the rotat macfail.

ing These forces are also designed to be absorbed via systems should fail. the mechanical holding brake systems. The kinetic energy released during rope failure will be absorbed in the equalizer system.

The main hoist speed is variable from 0.25 FPM to 5 6.4 FPM for handling a critical load via the flux vector Increment drives for hoisting may be provided frequency drive. No exceptions Slow Speed Drives by step less controls or inching motor drive. The auxiliary hoist speed is vable Teaxlayhitsedi aibefo from 0.25 FPM to

.5FMt noted.

15 FPM for handling a critical load via the flux vector frequency drive.

If jogging or plugging is to be used, the The frequency drives provided for crane motions control control circuit should include features to the acceleration and deceleration of the motor and prevent abrupt change in motion. eliminate abrupt motion changes.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 33 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Drift point in the electric power system for Drift points are not provided in the electrical power bridge or trolley movement should be system for bridge or trolley motion.

provided only for the lowest speeds.

Bridge and trolley travel limit switches, both slow-down Safety devices such as limit-tde switches and end of travel, are provided as safety devices, in 6.5 provided for malfunction, inadvertent addition to the end stops and bumpers. The switches are No exception operty atordtion o , r fpaiue shoud be liing not intended for control of the bridge and trolley during Safety addition to and separate from the limiting normal crane operations. Main and auxiliary hoist limit noted.

Devices means or control devices provided fornomlcaeprtis.Mnadaulayhitlmt switches are provided as safety devices and are not to be operation. tripped during normal hoisting operations.

6.6 The complete operating control system and A complete control system is provided with the remote provisions for emergency controls for the radio transmitter. A back-up cab station located on theexceptions Control overhead crane handling system should noted.

Stations preferably be located in a cab on the bridge. bridge is utilized for emergency controls.

When additional operator stations are The back-up cab station is provided with controls similar considered, they should have control systems to those on the remote radio transmitter.

similar to the main station.

Manual controls for hoisting and trolley The manual lowering controls for the main and auxiliary movement provided on the trolley, and for the hoist are located on the trolley.

bridge provided on the bridge.

Remote control for any of these motions The main hoist, auxiliary hoist, trolley and bridge should be identical to those on the bridge cab motions are variable (analog) control from the remote control panel. Iradio transmitter and the back-up cab station.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 34 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS control station Cranes that use more than one should be provided with electrical interlocks An electrical interlock is provided between the remote that permit only one control station to be radio transmitter and cab control stations.

operable at any one time Main and auxiliary hoist manual control is available on the trolley. Manual movement of the bridge and trolley In the design of control systems, provision for is possible from the runway and bridge endties, and locations of devices for control during respectively. Emergency stop buttons are available on emergency conditions should be provided, the remote radio transmitter and back-up cab station. A floor mounted conductor bar disconnect switch is provided to remove all crane power.

Installation instructions are provided by the crane Installation instructions should be provided by vendor, will be included in the site installation work the manufacturer. order package and utilized by the vendor for the 7.1 installation of the new crane system.

Include a full explanation of the crane Gncdlingsystem, a its colntrlniiations ofThe operation and maintenance manual provided No exceptions includes a full description of the crane control system. noted.

for the system.

Instructions should cover ... Requirements for The factory and site test procedures cover all testing installation, testing, and preparations for requirements while the operation and maintenance operation. manual provided contains crane operating instructions.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 35 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS When the permanent plant crane is used for The replacement crane system including trolley and construction and the requirements for bridge will not be utilized in the construction of the plant construction are more severe than those for nor for any construction lifts. The usage of the permanent plant service, the construction replacement crane system is limited to operational load 7.2 requirements should be defined separately. handling. The replacement crane system does not have a At the end of the construction period, the separate construction specification.

Construction crane shall be modified as needed for No exceptions and permanent plant service. noted.

Operating During and after installation of the crane, the After functional testing of the crane system and load Periods proper assembly of electrical and structural testing of the trolley and hoists at the factory, the crane components should be verified. The integrity is shipped to the Turkey Point. After installation, the new of all control, operating and safety systems crane system is inspected and tested to verify the integrity should be verified as to satisfaction of of all control, operating and safety systems.

installation and design requirement. _ _III

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 36 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS In order to verify the crane's mechanical and electrical systems are properly installed, the requirements of NOG 7500 "Qualification for Permanent Plant Service," as they apply to the new crane, are used. These A complete check ... Crane's mechanical and requirements include Section 7520 "Inspection Prior to electrical systems to verify the proper Performance Testing," NOG 7521.2 "Mechanical installation and to prepare the crane for Inspection," NOG 7521.3 "Electrical Inspection (Visual) testing. While Crane is Immobile," and NOG 7530 which invokes the requirements of NOG 7420 "Pre-operational Testing and Inspection" and NOG 7421 "No Load Test".

These requirements exceed those required in ASME 8.1 B30.2. No exceptions noted.

General Information concerning proof testing on components and subsystems ... performed at A complete functional and load test report is supplied the manufacturer's plant ... available for the after testing is complete.

checking and testing performed at the place of installation.

& I A

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 37 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS Exception - Site Load Testing at 125% of MCL including the transport The replacement trolley, main hoist and auxiliary hoist positions of are load tested to 125% of their respective MCL/DRL at trolley and bridge the factory to verify proper operation.

producing maximum strain 8.2 The crane system should be static load tested Load testing of the fully assembled crane is completed in the bridge and at 125% of MCL, ... including all positions on site to verify proper operation and structural integrity trolley structures Static and generating maximum strain in the bridge and of replacement bridge and runway support structure, are performed to Dynamic trolley structures and positions recommended respectively. Site load testing is performed at 125% of the extent Load Tests by the designer and manufacturer the crane MCL/DRL. The hoist, trolley and bridge are practical based positioned during the 125% site load test to the extent on the operating possible based on the physical arrangement of the constraints of the buildings including roof openings and qualification of plant. This is in supporting floors and structures.

accordance with the practicality clauses of ASME NOG-1 and NUREG-0612.

A .1

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 38 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL

___________________________________ EXCEPTIONS and load tests Complete 100% and 125% performance are performed at the manufacturer's facility for the After making required adjustments resulting replacement trolley, main hoist and auxiliary hoist. The from 125% static load test, 100% MCL 100% and 125% performance and load tests of the fully No exceptions performance test for all speeds and motions assembled crane are also performed on site to the extent noted.

for which designed. All safety and limiting practical based on the physical arrangement of the control devices will be verified, building including roof openings and qualification of supporting floors and structures. All limits possible are verified during site testing.

Emergency lowering of the MCL for the main hoist and Emergency manual lowering of the load and auxiliary hoist is demonstrated during factory load No exceptions manual movement of the bridge and trolley testing. Manual release of trolley and bridge brakes is noted.

should be tested with the MCL attached. demonstrated during factory functional testing and site functional testing.

When equipped with an energy-controlling device between load and head blocks the complete hoisting machinery is allowed to two-block (load block limit and safety devices A two-block test of the main hoist and auxiliary hoist bypassed). Test, at slow speed and no load, to was performed during factory functional testing at slow No exceptions Two-Block provide assurance of design, controls and speed without load on the respective hooks to verify noted.

Test overload protective devices. Demonstrate that proper operation of the energy controlling device and the maximum torque developed by the driving controls.

system, including inertia of the rotating parts at the over torque condition, will be absorbed or controlled.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 39 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The complete hoisting machinery tested for ability to sustain a load hang-up condition ...

load block attaching points are secure to a The overweight limits on the main hoist and auxiliary fixed anchor or an excessive load. Crane hoist are set and tested during factory load testing.

manufacturer ... ensure proper functioning of protective overload devices.

The crane systems are operated to verify the proper Operational tests of crane systems performed functionality of all limit switches and other safety to verify the proper functioning of limit devices in accordance with the requirements of NOG sw4abiitce and otherf safey devines. a7421 "No Load Test," as well as the additional 8.4 ability to perform as designed, requirements contained in NOG 7421.1. No exceptions Operational Special arrangements may have to be made to The main and auxiliary hoist overload sensors are tested noted.

Test test overload and overspeed sensing devices, during the 125% load tests. The overspeed sensing devices are tested by reprogramming the frequency drive to cause the motor to overspeed. Actuation of the overspeed detection circuit is verified to occur at 130%

of the critical load rated speed.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 40 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The manufacturer includes inspection and maintenance procedures in the operation and maintenance manual.

The inspections encompass the requirements necessary With good maintenance practice, degradation to assure degradation of the critical wearing components is not expected to exceed 15% of the design does not affect the crane's MCL rating.

load rating, and periodic inspection coupled with a maintenance program should ensure FPL's design change process assures that applicable that the crane is restored to the design procedures and documents including inspection and condition if such degradation is found.

maintenance procedures comply with the implemented design change and manufacturer specified inspections and maintenance.

8.5 4 No exceptions noted.

Maintenance The MCL rating of the crane should be Wearing components in the main and auxiliary hoists established as the rated load capacity, and the including hooks, brakes, reducers and bearings are design rating for the degradable portion of the designed with at least a 15% increase above their handling system should be identified to obtain respective MCL ratings to account for degradation due the margin available. to wear and exposure.

-4 The MCL should be plainly marked on each The MCL rating will be marked on the bridge and each side of the crane for each hoisting unit. side of the main and auxiliary hoist lower blocks.

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 41 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS The manufacturer provides a manual of information to use for checking, testing, and operating the crane.

Crane designer and manufacturer should Information obtained during testing is also provided in provide a manual of information and the manual. The manual also describes a preventive procedures for use in checking, testing and maintenance program based upon the requirements of operating the crane. Manual to describe a OSHA 1910.179, ASME B30.2 and ASME NOG-l.

preventive maintenance program based on the The preventive maintenance program provides the approved test results and information obtained information required to service, repair, and replace all during testing. Include such items as ... major trolley and hoist components. Additionally, 9 Operating requirements for all travel where applicable, visual examinations, equipment movements ... Clearly defined... diagnostics, and nondestructive examinations are No exceptions Operating described in the manual. The manual also describes noted.

Manual operating features and limitations.

The allowed rope degradation margin is in accordance with ASME B30.2.

The designer should establish the MCL rating The allowed hook degradation margin is in accordance and the margin for degradation of wear with ASME B30.10.

susceptible component parts.

The allowed brake degradation is in accordance with the brake manufacturer's recommendations, included with the maintenance manual.

a L I

Turkey Point Units 3 and 4 L-2010-022 License Amendment Request No. 202 Changes to the Technical Specifications Regarding Heavy Loads over the Spent Fuel Pools Page 42 of 42 SEC # NUREG-0554 GUIDANCE TURKEY POINT CRANE COMPLIANCE FPL EXCEPTIONS A quality assurance program should be FPL approved the crane manufacturer's quality plan which established to include the recommendations of establishes the requirements and responsibilities for this report for the design, fabrication, control of the design, fabrication, installation and testing installation, testing and operation of crane of the replacement crane. FPL's 10 CFR 50, Appendix B handling systems for safe handling of critical program addresses these requirements as well as testing load. and operation at the site.

Applicable procurement documents should require the crane manufacturer to provide a The crane manufacturer's quality program was accepted 10 quality assurance program consistent with the by FPL and met the applicable requirements of 10 CFR pertinent provisions of Regulatory Guide 50, Appendix B. The applicable requirements are No exceptions Quality 1.28, to the extent necessary. Program to invoked in the procurement documents. noted.

Assurance address NUREG-0554.

Program should address all recommendations The quality assurance plan addresses all areas of concern in this report. including the critical components of the crane system.

General qualification requirements for crane operators, including the requirements of ASME B30.2, are Include qualification requirements for crane included in the operation and maintenance manual to operators. assist FPL in developing operator standards.

Additionally, operator and maintenance training Is provided by the crane manufacturer on-site.