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{{Adams
#REDIRECT [[L-2014-303, Turkey Point Units 3 & 4, Response to Request for Additional Information Re License Amendment Request No. 216 - Transition to 10CFR50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for LWR Electric Generating Plants]]
| number = ML14336A634
| issue date = 11/05/2014
| title = Turkey Point Units 3 & 4, Response to Request for Additional Information Re License Amendment Request No. 216 - Transition to 10CFR50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for LWR Electric Generating Plants
| author name = Kiley M
| author affiliation = Florida Power & Light Co
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000250, 05000251
| license number =
| contact person =
| case reference number = L-2014-303
| package number = ML14336A638
| document type = Letter
| page count = 7
}}
 
=Text=
{{#Wiki_filter:Florida Power & Light Company 9760 SW 344 St Homestead, FL 330350 November 5, 2014FPL. L-2014-303 10 CFR 2.39010 CFR 50.90U.S. Nuclear Regulatory Commission Document Control DeskWashington, D.C. 20555-0001 Re: Turkey Point Nuclear Generating Station Units 3 and 4Docket Nos. 50-250 and 50-251Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR 50.48(c)
-NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001Edition)
 
==References:==
: 1. Florida Power & Light Company letter L-2012-092, "Transition to 10 CFR 50.48(c)
-NFPA 805 Performance-Based Standard for Fire Protection for Light Water ReactorElectric Generating Plants (2001 Edition),"
June 28, 2012.2. Florida Power & Light Company letter L-2013-086, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR50.48(c)
-NFPA 805 Performance-Based Standard for Fire Protection for Light WaterReactor Electric Generating Plants (2001 Edition),"
March 18, 2013.3. Florida Power & Light Company letter L-2014-003, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR50.48(c)
-NFPA 805 Performance-Based Standard for Fire Protection for Light WaterReactor Electric Generating Plants (2001 Edition),"
January 4, 2014.4. Florida Power & Light Company letter L-2014-071, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR50.48(c)  
-NFPA 805 Performance-Based Standard for Fire Protection for Light WaterReactor Electric Generating Plants (2001 Edition)",
April 4, 2014.5. Florida Power & Light Company letter L-2014-197, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR50.48(c)
-NFPA 805 Performance-Based Standard for Fire Protection for Light WaterReactor Electric Generating Plants (2001 Edition),"
July 18, 2014.6. Florida Power & Light Company letter L-2014-256, "Response to Request for Additional Information Regarding License Amendment Request No. 216 -Transition to 10 CFR50.48(c)
-NFPA 805 Performance-Based Standard for Fire Protection for Light WaterReactor Electric Generating Plants (2001 Edition),"
September 12, 2014.By Florida Power & Light Company (FPL) letter L-2012-092 dated June 28, 2012, (Reference 1)in accordance with the provisions of 10 CFR 50.90, "Application of License or Construction Permit,"
FPL requested an amendment to the Renewed Facility Operating License (RFOL) forTurkey Point Nuclear Generating Station Units 3 and 4. The License Amendment Request(LAR) will enable FPL to adopt a new fire protection licensing basis which complies with therequirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide(RG) 1.205.Security-Related Information
-Withhold From Public Disclosure Under 10 CFR 2.390.Enclosure 1 to this letter contains security-related information.
Upon removal of Enclosure 1 this letter is uncontrolled.
L-2014-303 Page 2 of 3The final risk estimates provided to the NRC by FPL letter L-2014-256 (Reference
: 6) werebased on the methodology summarized in the RAI responses documented by FPL lettersL-2014-071 (Reference 4), L-2014-197 (Reference 5), and L-2014-256 (Reference 6).The final quantification resulted in deletion, revision and addition of plant modifications previously submitted to the NRC per Reference
: 1. Enclosure 1 provides a revision to LARAttachment S, Table S-2, Plant Modifications Committed, replacing it in its entirety.
The revisedTable S-2 updates the Problem Statement for items 11, 12, 13 and 14 incorporating clarifying notes previously submitted to the NRC per Reference
: 2. The revised Table S-2 also reflects thefollowing revisions previously submitted to the NRC per Reference 4: (1) plant modifications deleted (items 3, 4 and 24); and (2) one new plant modification (item 33).This submittal revises Table S-2 to reflect the following:
(1) plant modifications status; (2)addition of clarifying notes to items 16, 22, 29 and 32 to identify unit applicability for modification implementation for those items listed as applicable to both Units 3 and 4; (3) revision of item 20to document it is a calculation, not a physical plant modification; (4) revision of item 25 to addpanels 3C1 I and 4C1 1 to the modification; (5) revision of item 27 to reflect it is a Unit 3modification; and (6) deletion of item 26 as a result of the revision to item 25.Enclosure 1 also provides a revision to LAR Attachment S, Table S-3, Implementation Items,originally submitted to the NRC by Reference
: 1. The enclosed Table S-3 replaces the originalTable S-3 in its entirety.
Table S-3 has been updated to reflect revisions previously submitted tothe NRC by FPL letters L-2013-086 (Reference 2), L-2014-003 (Reference 3), L-2014-071 (Reference 4), and L-2014-197 (Reference 5), and to add clarifying information.
The following revisions to Table S-3 reflect changes previously submitted to the NRC: (1) thedescription of item 18 was revised to reflect changes submitted per References 2 and 4; (2)item 19 was revised to delete reference to Table S-2, items 3 and 4 since the modifications were deleted by Reference 4; (3) item 20 was added by Reference 3; (4) items 21 and 23 wereadded by Reference 4; (5) item 22 was added by Reference 4 and revised by Reference 5; and(6) item 24 was added by Reference 2.The clarifying information incorporated in Table S-3 includes:
(1) the note above Table S-3 wasrevised to add item 12 as one of the items that will be completed in accordance with themodification process; and to clarify that item 22 will be completed within 6 months of the NRCapproval of the Flowserve RCP Seal Topical Report; and (2) Item 12 added reference to TableS-2 item 22 to clarify linkage between the Table S-2 and S-3 items.Enclosure 1 to this letter contains sensitive security-related information; therefore, FPL requeststhat it be withheld from public disclosure in accordance with 10 CFR 2.390.Enclosure 2 to this letter provides a proposed revision to LAR Attachment M, License Condition, originally submitted to the NRC by Reference
: 1. The proposed License Condition revises twoSections:
: 1) Other Changes that May Be Made Without Prior NRC Approval, to add a statement specifying that this License Condition does not apply to any demonstration of equivalency underSection 1.7 of NFPA 805; and 2) Transition License Conditions, items 2 and 3. Item 2 wasrevised to specify that plant modifications will be completed by the end of the second refueling outage (for each unit) following issuance of the license amendment.
Item 3 was revised tospecify that: (1) implementation items 12, 18 and 19 are associated with plant modifications which will be completed in accordance with the plant modifications schedule; and (2)Security-Related Information
-Withhold From Public Disclosure Under 10 CFR 2.390.Enclosure 1 to this letter contains security-related information.
Upon removal of Enclosure 1 this letter is uncontrolled.
L-2014-303 Page 3 of 3implementation item 22 will be completed within 6 months of the NRC approval of the Flowserve RCP Seal Topical Report.The additional information provided in this letter does not impact the 10 CFR 50.92 evaluation of"No Significant Hazards Consideration" previously provided in FPL letter L-2012-092.
If you should have any questions regarding this application, please contact Robert Tomonto,Licensing
: Manager, at 305-246-7327.
I declare under penalty of perjury that the foregoing is true and correct.Executed on November t, 2014.Michael KileyVice President Turkey Point Nuclear Generating StationEnclosures cc: Regional Administrator, Region II, USNRCSenior Resident Inspector, USNRC, Turkey PointUSNRC Project Manager for Turkey PointMs. Cindy Becker, Florida Department of HealthSecurity-Related Information
-Withhold From Public Disclosure Under 10 CFR 2.390.Enclosure 1 to this letter contains security-related information.
Upon removal of Enclosure 1 this letter is uncontrolled.
Enclosure 2 to L-2014-303 Response to Request for Additional Information License Amendment Request No. 216Florida Power and Light CompanyTurkey Point Nuclear Generating Station Units 3 and 4Transition to 10 CFR 50.48(c)
-NFPA 805Performance-Based Standard for Fire Protection forLight Water Reactor Electric Generating Plants, 2001 EditionUpdated LAR Attachment M, License Condition Changes L-2014-303 Enclosure 2Florida Power & Light Attachment M -License Condition ChangesReplace the current FPL Turkey Point Nuclear Plant Unit 3 and Unit 4 fire protection LicenseConditions 3ID with the standard license condition based upon Regulatory Position 3.1 of RG1.205.Fire Protection ProgramFlorida Power and Light shall implement and maintain in effect all provisions of theapproved fire protection program that comply with 10 CFR 50.48(a) and10 CFR 50.48(c),
as specified in the licensee amendment request dated 6/28/12, (andsupplements dated 9/19/12, 3/18/13, 4/16/13, 5/15/13, 1/7/14, 4/4/14, 6/6/14, 7/18/14,09/12/14 and 11/05/14) and as approved in the safety evaluation dated XX/XX/XX.
Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c),
and provided no other regulation, technical specification, license condition orrequirement would require prior NRC approval, the licensee may make changes to thefire protection program without prior approval of the Commission if those changes satisfythe provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),
the change does notrequire a change to a technical specification or a license condition, and the criteria listedbelow are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC ApprovalA risk assessment of the change must demonstrate that the acceptance criteria beloware met. The risk assessment
: approach, methods, and data shall be acceptable to theNRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change mayinclude methods that have been used in the peer-reviewed fire PRA model, methodsthat have been approved by NRC through a plant-specific license amendment or NRCapproval of generic methods specifically for use in NFPA 805 risk assessments, ormethods that have been demonstrated to bound the risk impact.(a) Prior NRC review and approval is not required for changes that clearly result in adecrease in risk. The proposed change must also be consistent with thedefense-in-depth philosophy and must maintain sufficient safety margins.
Thechange may be implemented following completion of the plant changeevaluation.
(b) Prior NRC review and approval is not required for individual changes that resultin a risk increase less than 1 x 10-7/year (yr) for CDF and less than 1 X 10-8/yr forLERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.
The change may beimplemented following completion of the plant change evaluation.
Revision IPage M-2 L-2014-303 Enclosure 2Florida Power & Light Attachment M -License Condition ChangesOther Changes that May Be Made Without Prior NRC Approval1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection ProgramPrior NRC review and approval are not required for changes to the NFPA 805,Chapter 3, fundamental fire protection program elements and designrequirements for which an engineering evaluation demonstrates that thealternative to the Chapter 3 element is functionally equivalent or adequate for thehazard. The licensee may use an engineering evaluation to demonstrate that achange to an NFPA 805, Chapter 3, element is functionally equivalent to thecorresponding technical requirement.
A qualified fire protection engineer shallperform the engineering evaluation and conclude that the change has notaffected the functionality of the component, system, procedure, or physicalarrangement, using a relevant technical requirement or standard.
The licensee may use an engineering evaluation to demonstrate that changes tocertain NFPA 805, Chapter 3, elements are acceptable because the alternative is"adequate for the hazard."
Prior NRC review and approval would not be requiredfor alternatives to four specific sections of NFPA 805, Chapter 3, for which anengineering evaluation demonstrates that the alternative to the Chapter 3element is adequate for the hazard. A qualified fire protection engineer shallperform the engineering evaluation and conclude that the change has notaffected the functionality of the component, system, procedure, or physicalarrangement, using a relevant technical requirement or standard.
The fourspecific sections of NFPA 805, Chapter 3, are as follows:* "Fire Alarm and Detection Systems" (Section 3.8);* "Automatic and Manual Water-Based Fire Suppression Systems" (Section3.9);* "Gaseous Fire Suppression Systems" (Section 3.10); and* "Passive Fire Protection Features" (Section 3.11).This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.2. Fire Protection Program Changes that Have No More than Minimal Risk ImpactPrior NRC review and approval are not required for changes to the licensee's fireprotection program that have been demonstrated to have no more than a minimalrisk impact. The licensee may use its screening process as approved in the NRCsafety evaluation dated XX/XX/XX to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fireRevision 1Page M-3 L-2014-303 Enclosure 2Florida Power & Light Attachment M -License Condition Changesprotection defense-in-depth and safety margins are maintained when changesare made to the fire protection program.Transition License Conditions
: 1. Before achieving full compliance with 10 CFR 50.48(c),
as specified by 2. and 3.below, risk-informed changes to the licensee's fire protection program may notbe made without prior NRC review and approval unless the change has beendemonstrated to have no more than a minimal risk impact, as described in 2.above.2. The licensee shall implement the modifications to its facility, as described inEnclosure 1, Attachment S, Table S-2, "Plant Modifications Committed,"
of FPLletter L-2014-303, dated 11/05/2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the end of the second refueling outage (for each unit)following issuance of the license amendment.
The licensee shall maintainappropriate compensatory measures in place until completion of thesemodifications.
: 3. The licensee shall implement the items listed in Enclosure 1, Attachment S,Table S-3, "Implementation Items," of FPL letter L-2014-303, dated 11/05/2014, with the exception of items 12, 18 and 19, no later than 180 days after NRCapproval unless that falls within a scheduled outage window. Then this will occur60 days after startup from that scheduled outage. Items 12, 18 and 19 areassociated with modifications in Table S-2 and will be completed in accordance with Transition License Condition 2 above. Item 22 will be completed within 6months of the NRC approval of the Flowserve RCP Seal Topical Report.Revision 1Page M-4}}

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