L-2010-004, License Amendment Request (LAR 194) Re Control Room Habitability TSTF-448

License Amendment Request (LAR 194) Re Control Room Habitability TSTF-448

ML102010386
Person / Time
Site:	Turkey Point
Issue date:	07/16/2010
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2010-004, LAR 194, TAC ME0004, TAC ME0005, TSTF-448
Download: ML102010386 (25)

Text

OF JML16 Zulu IPL.

POWERING TODAY. L-2010-004 EMPOWERING TOMORROW.

10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request (LAR 194)

Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

Pursuant to 10 CFR 50.90, Florida Power and Light Company (FPL) hereby requests an amendment to Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4.

The proposed amendment would modify the Technical Specification (TS) requirements related to control room envelope habitability in accordance with Technical Specification Task Force (TSTF) Change Traveler TSTF-448 Revision 3, "Control Room Habitability." This submittal satisfies the commitment identified in FPL Letter L-2007-127, dated August 10, 2007, to adopt the applicable portions of TSTF-448. Additionally, it also updates the original submittal of LAR 194 made September 26, 2008, in response to an NRC Request for Additional Information (RAI)

(Attachment 5). The referenced RAI requested the proposed license amendment remove any reference to TSTF-508, and this has been done. provides a description of the proposed change, the requested confirmation of applicability, and plant specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides a summary of the regulatory commitments made in this submittal. Attachment 4 provides existing TS Bases pages marked up to show the proposed changes. Attachment 5 provides a copy of the NRC RAI on the original submittal of this license amendment request.

FPL requests approval and issuance of the proposed amendments by September 30, 2010 with implementation to be completed within 180 days of issuance.

The Turkey Point Plant Nuclear Safety Committee has reviewed the proposed license amendments. In accordance with 10 CFR 50.91 (b)(1), a copy of the proposed amendments is being forwarded to the State Designee for the State of Florida.

The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1), using the criteria in 10 CFR 50.92(c). FPL has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. FPL has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Turkey Point Units 3 and 4 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

an FPL Group company

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Page 2 of 3 License Amendment Request Control Room Habitability, TSTF-448 (TAC NOS. ME0004 AND MEOO5)

Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto, Licensing Manager, at (305) 246-7327.

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

Executed on July /4' ,2010.

Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant Attachments cc: Regional Administrator, Region II, USNRC USNRC Project Manager, Turkey Point Nuclear Plant Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant Mr. W. A. Passetti, Florida Department of Health

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Page 1 of 1 License Amendment Request Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

TABLE OF CONTENTS ATTACHMENTS

• Attachment 1 License Amendment Request 1.0 Description 2.0 Assessment 3.0 Regulatory Analysis 4.0 Environmental Evaluation

• Attachment 2 Technical Specification Change Markups

• Attachment 3 Regulatory Commitments

• Attachment 4 Technical Specification Bases Markups

• Attachment 5 NRC Request for Additional Information

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request Page 1 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005) 1.0 Description The proposed amendment would modify Technical Specification (TS) requirements related to control room envelope (CRE) habitability in TS 3/4.7.5, "Control Room Emergency Ventilation System (CREVS)," and TS Section 6.8, "Administrative Controls - Procedures and Programs."

The Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Improved Standard Technical Specification (ISTS) Change Traveler TSTF-448 Revision 3, "Control Room Habitability," is based on the ISTS content and format. Turkey Point has not adopted the ISTS of NUREG-143 1, "Standard Technical Specifications - Westinghouse Plants." Nevertheless, the TS changes proposed in this amendment are considered consistent with TSTF-448 Revision 3 given the necessary differences to account for (1) the non-standard TS language and format, (2) the plant-specific CRE and CREVS designs, and (3) current licensing basis of Turkey Point Units 3 and 4. The availability of this TS improvement was published in the Federal Register on January 17, 2007 (Volume 72, Number 10) as part of the consolidated line item improvement process (CLIIP).

2.0 Assessment 2.1 Applicability of Published Safety Evaluation Florida Power & Light (FPL) has reviewed the safety evaluation, dated January 17, 2007, provided as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-448. FPL has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Turkey Point Units 3 and 4, and adequately justify this proposed amendment and the incorporation of the changes into the Turkey Point TSs.

2.2 Description and Justification of the Proposed Changes The purpose of these proposed changes is to provide added confidence that the integrity of the CRE boundary is maintained to ensure that exposure of CRE occupants to a radiological, chemical, or smoke hazard will be within the assumptions in the licensing basis. Refer to for the TS markups corresponding to the changes described below:

The proposed TS changes are considered consistent with the NRC approved TSTF ISTS Change Traveler, TSTF-448 Revision 3.

The changes to TS 3.7.5 add the necessary conditions and required actions for MODES I thru 4 to distinguish between a CREVS inoperability caused by a degraded CRE boundary and a CREVS inoperability for other reasons. A note is added to TS 3.7.5 to allow for the opening of the CRE boundary intermittently under administrative control. The note is intended to provide additional operational flexibility by not having to enter the TS actions when performing certain

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request Page 2 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005) routine activities affecting the CRE boundary. The limitations and controls for applying this note are described in the TS Bases consistent with TSTF-448. The proposed changes to TS 3.7.5 address the situations when the CRE boundary cannot be restored to OPERABLE status within the required allowed outage times (AOTs) and when the CREVS is inoperable for reasons other than an inoperable CRE boundary. In these situations, action must be taken immediately to place the unit in a condition that minimizes the accident risk.

The proposed TS changes also add a new surveillance requirement to TS 4.7.5 which imposes a requirement for comprehensive testing of CRE unfiltered air inleakage in accordance with the Control Room Envelope Habitability Program. The requirements for this program are incorporated into a new Administrative Controls program, designated as TS 6.8.4.k. Consistent with TSTF-448, the program requirements include CRE positive pressure and tracer gas inleakage testing, and additional configuration controls and preventive maintenance to ensure the CRE boundary is maintained as per design. (Note that Turkey Point does not have an.

Administrative Controls TS requirement for a Ventilation Filter Testing Program (VFTP), so the TS 4.7.5.d test flow rate is specified in lieu of the VFTP.)

2.3 Optional Changes and Variations FPL is not proposing variations or deviations from the TS changes described in TSTF-448 Revision 3, or the applicable parts of the NRC staffs model safety evaluation dated January 17, 2007, except as needed to account for (1) the non-standard language and format of the Turkey Point TSs; (2) the plant-specific design differences of the CRE and CREVS; and (3) the continued adherence to the current licensing basis of Units 3 and 4 where appropriate.

Accordingly, the following adjustments have been incorporated into the proposed TS changes for Turkey Point.

Turkey Point Units 3 and 4 share a common CRE and a single CREVS filter train. The CRE and CREVS are described in Section 9.9 of the Updated Final Safety Analysis Report (UFSAR). It is proposed to slightly modify the TSTF-448 wording regarding verification that "mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits." This wording implies that there are quantitative limits for chemical and smoke hazards; however, these hazards do not have quantifiable limits. As stated in Section 2.6 of Regulatory Guide 1.196, Revision 1: "No regulatory limit exists on the amount of smoke allowed in the control room. Similarly, Turkey Point has no explicit limits on chemical hazards due to the absence of such hazards. The ability to manage chemical and smoke hazard assessments qualitatively is indicated in the proposed wording of Required Action B.2 as specified in the NRC model safety evaluation, Evaluation No. 2, and the associated model Bases. Accordingly, the wording for the Turkey Point TS Action 3.7.5.b (ACTION b) is proposed to read: "...verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants are protected from chemical and smoke hazards." This wording has been approved by the NRC for several plants, including Beaver Valley (ADAMS Accession No. ML080370178)

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request Page 3 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005) and Perry (ADAMS Accession No. ML080310794). Also concerning ACTION b, note that the TS Bases (refer to Attachment 4 for markups) have been revised to provide additional clarification regarding the mitigating action for chemical hazards required by ACTION b.

Specifically, the Bases information has been supplemented to include a statement indicating that the mitigating action for chemical hazards can be met by verifying that the chemical hazards analyses are current and require no toxic gas protection for the CRE occupants. This is acceptable because the existing analyses conclude that there is an absence of offsite and onsite chemical hazards that would require protection for the CRE occupants.

Consistent with the current action for an inoperable CREVS for Modes 1 thru 4, the proposed TS Action 3.7.5.a (ACTION a) for an inoperable CREVS due to an inoperable CRE boundary allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to reach MODE 3 (HOT STANDBY), instead of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as specified in ACTION C.1 of TSTF-448, when the action applies to both units simultaneously. The specified 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to reach MODE 3 is justified because of the additional operating flexibility required for a dual unit shutdown to prevent a severe transient on the Florida electrical grid. Accordingly, it is proposed that both units are allowed 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> to reach MODE 5 (COLD SHUTDOWN) if a dual unit shutdown is required.

In addition, the term "irradiated" has been included, as appropriate, to clarify that only irradiated fuel is applicable to the TS 3.7.5 Actions which call for the suspension of fuel movement. This conforming change is consistent with TSTF-448 and the associated ISTS APPLICABILITY.

The lead-in paragraph for the new Control Room Envelope Habitability Program (TS 6.8.4.k) is modified to include references to the control room radiological dose limits of General Design Criterion (GDC) 19 of 10 CFR Part 50, Appendix A, and 10 CFR Part 50.67. Specifically, the second sentence of the paragraph is proposed to read: "The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body or 5 rem total effective dose equivalent (TEDE), as applicable, for the duration of the accident." Thus, instead of referencing only one of the control room limits as bracketed in the TSTF-448 markup, both limits are proposed to be referenced. This is necessary because the current licensing basis for DBA control room dose uses the methodology and assumptions derived from Technical Information Document (TID)-

14844, "Calculation of Distance Factors for Power and Test Reactor Sites," as well as the alternative source term (AST) methodology of Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors,"

allowed by 10 CFR 50.67, "Accident source term." TID-14844 is the methodology of record for the control room dose analyses (e.g., DBA loss of coolant accident), except for the DBA fuel handling accident analysis, which uses a selective implementation of the AST methodology. As such, the Turkey Point UFSAR currently specifies control room radiological dose consequences in terms of the GDC 19 (5 rem whole body) limits, as well as the 10 CFR 50.67 (5 rem TEDE) limits.

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request Page 4 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

For line item c of the TS 6.8.4.k Control Room Envelope Habitability Program elements, TSTF-448 recognizes that there may be plant-specific exceptions to the generic guidance for performance of the unfiltered air inleakage test. FPL identified the need for such an exception for Turkey Point based on its review of Sections C. 1 and C.2 of Regulatory Guide 1.197, Revision 0, and the exception is included in the proposed amendment, which reads as follows:

"Appropriate application of ASTM E741 shall include the ability to take minor exceptions to the test methodology. These exceptions shall be documented in the test report."

This exception is needed because the required testing methodology, ASTM E741, was not originally intended for nuclear power plant CRE testing, and the ability to deviate from the specific details, but not the general methods and intent, may be necessary to account for variations in vendor testing methods. A similar exception has been approved for San Onofre Nuclear Generating Station, Units 2 and 3, in License Amendments dated October 31, 2007 (ADAMS Accession Nos. ML072890012 and ML072890015). Nuclear Energy Institute (NEI) 99-03, Revision 1, Appendix EE discusses exceptions typically taken by ASTM E741 test vendors. While not considered all-inclusive, the exceptions listed in Appendix EE provide examples of the types of exceptions that will be allowed by the proposed Control Room Envelope Habitability Program. Exceptions to the test methodology will be documented in the individual test reports.

In order to be consistent with line item c of the Control Room Envelope Habitability Program elements, the proposed wording in the last sentence of line item d for the TS 6.8.4.k program elements is changed slightly from the wording in TSTF-448. Currently, the last sentence reads:

"The results shall be trended and used as part of the [18] month assessment of the CRE boundary." The bracketed "18" months was an error since the normal interval for the periodic CRE assessment specified in Regulatory Guide 1.197, Section C.1, is 36 months. Therefore, the words "18 month" are proposed to be replaced with the word "periodic." Thus, the last sentence of line item d of the TS 6.8.4.k program elements is proposed to read: "The results shall be trended and used as part of the periodic assessment of the CRE boundary." This wording substitution resolves the inconsistency between the Control Room Envelope Habitability Program requirements in a manner consistent with the published regulatory guidance.

The definition of STAGGERED TEST BASIS contained in the Turkey Point TS definitions section differs from the definition contained in Section 1.1 of the NUREG-1431 ISTS and used in the TSTF-448 requirements in line item d of the Control Room Envelope Habitability Program elements. The Turkey Point CREVS includes redundant active components (e.g., two supply fans, two outside air isolation dampers). To achieve the desired 18-month frequency specified by TSTF-448, the test schedule for two redundant components is obtained from the Turkey Point TS definition of STAGGERED TEST BASIS by dividing the specified test interval into two equal subintervals and testing one of the components at the beginning of each subinterval. Thus,

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request Page 5 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005) specifying the test interval as 36 months and dividing this interval into two equal subintervals results in two 18-month subintervals (one subinterval per redundant component), which is equivalent to the TSTF-448 STAGGERED TEST BASIS frequency contained in line item d of the Control Room Envelope Habitability Program. Therefore, by specifying the STAGGERED TEST BASIS for line item d of the Control Room Habitability Program elements as 36 months, the component test frequency is 18 months consistent with TSTF-448. Periodic assessment of the CRE boundary will be performed at least every 36 months in accordance with the current program requirements as described in the December 9, 2003 letter response to Generic Letter 2003-01.

In TSTF-448, the requirements for line item f of the Control Room Envelope Habitability Program elements specify that: "The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability..." In SR 3.0.2 of the NUREG-1431 ISTS, it is stated that a surveillance requirement (SR) is met if the surveillance is performed within 1.25 times the specified interval. Turkey Point TS 4.0.2 states that a surveillance requirement shall be performed within the specified time interval with a maximum extension of the surveillance interval of 25%. The intent of line item f of the Control Room Envelope Habitability Program elements is to allow a 25% extension of the program-related testing frequencies. This is accomplished by the Turkey Point 25% surveillance interval extension provision in TS 4.0.2.

Accordingly, the proposed replacement of"SR 3.0.2" with "Specification 4.0.2" in line item f of the Control Room Envelope Habitability Program elements does not change the intent of the requirement, and is considered an equivalent conforming change.

The TS Bases changes (markups included in Attachment 4 for information only) have been prepared to reflect the applicable Bases statements from TSTF-448 Revision 3 and, where appropriate, also reflect the exceptions identified above. The Bases changes will be processed in accordance with the requirements of Administrative Controls TS 6.8.4.i, "Technical Specifications (TS) Bases Control Program," thereby providing assurance that FPL has adequate controls in place to properly develop and maintain the Bases.

2.4 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements FPL proposes the following as a license condition for Turkey Point Units 3 and 4 to support implementation of the proposed TS changes:

Upon implementation of Amendment No. X* for Unit 3 and Y* for Unit 4 adopting TSTF-448 Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.5f, in accordance with Technical Specification (TS) 6.8.4.k.c.(i), the assessment of CRE habitability as required by Specification 6.8.4.k.c.(ii), and the measurement of CRE pressure as required by Specification 6.8.4.k.d, shall be considered met. Following implementation: ,

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request Page 6 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

(a) The first performance of SR 4.7.5.f, in accordance with Specification 6.8.4.k.c.(i), shall be within the specified Frequency of 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.**

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.8.4.k.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.8.4.k.d, shall be within 36 months on a STAGGERED TEST BASIS, plus the 138 days allowed by SR 4.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days of license amendment implementation if not performed previously.

• Placeholdersforactual amendment numbers

• • The most recent tracergas test (July 31, 2009) was unsuccessful in that there was a measured 9 cfm control room inleakage: the acceptance criteriais 0 cfm. In accordance with Regulatory Guide (RG) 1.197 Rev. 0, a recalculationof the consequences to the control room operatorswas performed, and the results were acceptablefor continued CREVS operability. Consistentwith RG 1.197, afull test is to be conducted three years later to ascertainwhether the CRE's integrity has continued to degrade.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination FPL has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. FPL has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Turkey Point Units 3 and 4 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Commitments FPL commits to perform the following activities for Turkey Point Units 3 and 4 to comply with this Licensing Amendment Request:

Perform Control Room Envelope unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program, which will include the following requirements:

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request Page 7 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

1. Tracer Gas Testing.*** Determine the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

2. CRE Habitability Assessment.*** Assess CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

3. Control Room Differential Pressure Test. Measure the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation of the Control Room Ventilation Systems, at a Frequency of 36 months on a STAGGERED TEST BASIS.

Turkey Point takes exception to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. The exception is stated in the Control Room Envelope HabitabilityProgram requirementsas: "AppropriateapplicationofASTME741 shall include the ability to take minor exception to the test methodology. These exceptions shall be documented in the test report."

4.0 Environmental Evaluation FPL has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007 as part of the CLIIP. FPL has concluded that the staffs findings presented in that evaluation are applicable to Turkey Point Units 3 and 4 and the evaluation is hereby incorporated by reference for this application.

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 2 License Amendment Request Page 1 of 6 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

Technical Specification Change Markups Page 3/4 7-16 Page 3/4 7-17 Page 6-18b

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 2 License Amendment Request Page 2 of 6 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

PLANT SYSTEMS 314,7.5 CONTROL ROOM EMERENCY VENTILATION SYSTEM

,LIMITING CONDITION FOR OPERATION.

3,7.5 The, Control Room Emergency Ventilation System shall be OPERABLE]

APPLICABILITY.: Ali MODES.

ACTION.  !~r reasons othe~than an irtop rableCREb&und ty, 1mm di tel MODES 1,'2,13 and 4: d e ,

'a With the Control Room Emergency Ventilation System inoperabi suspend alleuel in the spent:fuel podi and restore theý inope-jr.e system to, OPERABLE status within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the fotlbwing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD I, ~ 1 SHUTDOWN.within the following 30 eurs.

MODES 5 and 6: ri With the Conrtro Roonm Ee.rgenIcy entiia*ton System inIopemrable, supend all o peratio.ns invom¢ng CORE ALTERAT!ONS, movementotfuel in the spent fuel pool, or positive. reactivity changes, This ACTION shall apply to both units simullaneously.

SURVFIELANCE REQUIREMENTS 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE; a- At leastIonce per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air tem perature is less than or equal

.to 120'F:

bh At least once per 31 days by initiatinhgfrom the control room, flow through the.HEPA fifters and

.charcoal adsorbers and verifying that the system operates for at least 15 minutes; C. At least once per 18 months or (1) after 720.hours ofsystem operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (3) following operational exposure of the filters to effluents from painting, fire, or chemical release in any ventilation zone communicating with the system, or (4) after complete or partial replacement of a filter bank by*

Con l Room EnLe~o e ('RE7 C;The b1un"'ry, rn b~:eiren trmitt lnly rnd amriistr ti'e Con roi,,*

TURKEY POINT - UNITS 3 &4 3144 7-16 TAMENDMENT NOS, 44,7 AND 422

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 2 License Amendment Request Page 3 of 6 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (ContinUad)

1) Verifying that the air cleanup system satisfies thp in-place penetration and bypass leakage testing acceptance critea of qgreater :than or equal to 99% DOP and halogenated hydrocarbon removal at a system flow rate of 1000 cfm +/-10%;

2) Verifying. Vwithin 31 days after removal, that a tnboratory analysis of a representative

• carbonsample obtained in accordance with Regulatory PostIbon Cý&b.of Regulatory Guide 1.52, Revision 2, March 1978, and analyzed per ASTM D3803 -1989 AT 30'WC and 95% relative humidity, meets the methyl jodide penetration criteria of less than 2.5% or the charcoal be replaced with charcoal that meets or exceeds the stated performance requirement. and

3) Verifying by a visual inspection the absence of foreign materials and gasket deterioration, d'. At least once per 12 months by Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge While operating the systemn at a flow rate of .1000 cfm +/-010%X 4

e. At least once per 18 months by Verifying that on a Containment Phase -A' Isolation test signal the system automatically switches,into the recirculation mode of operation,

[Control Room :EvI SBy. perrming e~lp.

reqire aH~atitaiiiy:Procxru~n r I It . .. .... ..

the TURKEY POINT .:-UNITS 3'& 4 3/4 7-17 AMENDMENT NOS, 206 AND I99 Note: Add'l TS 3/4.7.5 changes pending per 5/21/2010 FPL Letter L-2010-083 (Accession No. ML101450028)

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 2 License Amendment Request Page 4 of 6 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

.ADMtNISTRATIV CNR*

PROCEDURES AND PROGRAMS (Conlinued't

ýd. Provisions for SG tube inspections. Periodic SG tube inspectio*ns shall be Petro'ried; The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type(e~., ,§volumetric flaws, axial and circumferential cracks) that may be present along the length of theattube, the fromoutleIt.

tube the.

inlet to the lube-lo-tubesheel w*,eld tIjbelto-tubesheet weld al the tube and that may satisfy ihe applicable tube repair.citeria. For Unit 3 through Refueling Outage 25 and the next operating cycle, andfor Unit 4 during Refueting Outage 25 and the subsequent operating cycles untli the next scheduled inspectioon, the portion of the tube below 17,28 inches from the top of theitubesheet is excluded from inspection. The, tube-t-tIubesheet weld is not part of the tube, In additionto meeting the requirements of d, 1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until tne next SG inspection An assessment of degradation shall be performed to determine the type and location of flaws to which the tube may be susceptible and. based on this assessment,:to:

determine which inspection methods need to be employed and at what locations,

1. tInspect 100% of the tubes in each SG during the first refueling outage folowing SG replacement.

2. Inspect 100% of the tubes at sequential periods of 120 90, and, thereafter, 60 effective full power months. The first sequential period shall be,considered to begin after the first inservice inspection of the SGs, In addition, inspect 50% of the tubes by the mefueling outage nearest the midpoint of the period and the remaining 50% by the refueling outages nearest the end of the pericd.No SG shall operate for more than 48 effecdive full. power monlhsor two refuelinig outages (whichever is less) without being inspected.

3. It crack indications are found in any portion of a SG tube rnot excluded above, then the next inspection for each SG. for the degradation mechanism thatcaused the crack indication shall not exceed24 effective full power months or one refueling outage (whichever is less). Ifdefinitive information, such as from examination of a pulled tube, diagnostic non-destnuctive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s),

then the indication need not be treated as a crack..

e, Provisions for monitoring operational primary-secondary leakage, 6,8.5 DELETE[

TURKEY POINT - UNITS 3 &4 6-18b AMENDMENT NOS,-244, AND 226

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 2 License Amendment Request Page 5 of 6 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

INSERT I

b. With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary, immediately suspend all movement of irradiated fuel in the spent fuel pool, initiate action to implement mitigating actions, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants are protected from chemical and smoke hazards, and restore CRE boundary to OPERABLE status within 90 days, or:

1. With the requirements not met be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

2. - If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

INSERT 2

k. Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented'to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body or 5 rem total effective dose equivalent (TEDE), as applicable, for the duration of the accident.

The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

The following is an exception to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:

Appropriate application of ASTM E741 shall include the ability to take minor exceptions to the test methodology. These exceptions shall be documented in the test report.

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 2 License Amendment Request Page 6 of 6 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

d. Measurement, at designated locations, of the CRE pressure relative to external areas adjacent to the CRE boundary during the pressurization mode of operation of the CREVS, operating at the flow rate required by Surveillance Requirement 4.7.5.d, at a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the periodic assessment of the CRE boundary.

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of Specification 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 3 License Amendment Request Page 1 of 1 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

Regulatory Commitments The following table identifies those actions committed to by FPL in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENTS DUE DATE/EVENT Tracer Gas Testing The date for completion of this commitment is between July 31, 2012 and April 30, 2013 for both units. The date of the most recent tracer gas test was July 31, 2009.**

CRE Habitability Assessment The date for completion of this commitment will be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test. (July 31, 2012 to April 30, 2013)

Control Room Differential Pressure The dates for completion of these commitments is as Test follows:

0 Initial test within 138 days of implementation of the license amendment.

• Next test within 36 months from implementation of the license amendment on a STAGGERED TEST BASIS, plus the 138 days allowed by SR 4.0.2

• • The most recent tracergas test (July 31, 2009) was unsuccessful in that there was a measured 9 cfm control room inleakage: the acceptance criteriais 0 cfmi. In accordance with Regulatory Guide (RG) 1.197 Rev. 0, a recalculationof the consequences to the control room operatorswas performed, and the results were acceptablefor continued CREVS operability. Consistent with RG 1.197, afull test is to be conducted three years later to ascertainwhether the CRE's integrity has continued to degrade.

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 4 License Amendment Request Page 1 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

Technical Specification Bases Markups (Information Only)

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 4 License Amendment Request Page 2 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005) 0-AIDM-536 'TeclicalSpecification TBass Control Program 449,4/-9s AIfrACIME r 1i (Page 88 of 112)ý TECHINICAL SPECIFICATION BASES 3/47.4 Ultimate Heat Sink The limit on ultimate heat sink, 0i*HiS temperaiture in conjunction with .:.the SURVEII .ANCE RE QUIREMENTS of Technical Specification 3417.2 ,will ensure that suficicni coming caipacnv is available either:: (1) To provide normal cpoldown of.the facility or (2) TOniaiethe etetsofaccident conditions within acceptable limits.

FML has the option of monitoring the UHS temperature by monitoring the temperature in l ICW(2e sstemnpiping going to :the inlet of the'CCW heat .exch!aiters\Monitoring the UHS temperature ifter the ICW but prior to CCW heatl exieanger's is consideted to be:

equivalent to temperature monitoring belore ihe tCW pumps. The supply water letiving the JCW pumps will be mixed tint therefore. it will be representaitve of the bulk UHS temperature to the CCXW heat exchanger inlet. The effects of the pump heatint't on the supply water are negligible due to low ICW head and high water volume. Accordingly, monitoring the UHS temperature after the IMW pumps but prior to the CWC X heat exchangers proides art ejuivalentlcutlion for monitoring the UMIS temperature.

With the implementation Ifthe CCW.heat exehanger perfoirimance monitoringtprogram, thie, liniting 1I1S temperature can be treated as a variable with an absolute upper limit of 100lt) without comproinsing any nmrgin of salety. Demonstration of actual heat cxchanger peitormanqe capability supports, system, operation with postulated canal temperatiires§ greater'than 100'F, Therftre, an upper Techniical Specificationi limit 6f 100'F is coneervative.

3/4.7.5 Control Roonm Emer'-encv Ventilation Svsti.im envelone:(CRE .. .ga The OPERABIL o' roli Room Emerencv en lation System.nensures that:

(1) The ambient air. emperature does not exceed, het. allowable teimperature fir continuous-duty rati Wfor thel e~uipmn'e i.tn mid'iistfumeniotion*ooled by this system; and (2) The control room ill remain hahitabld for 11,MI1 rI111ft4 during and following

..l t .... *I iI-,he OPERA.BJLI IY ot this system in conjunction with tontrol room design pTrovtsionls based oni liniting the radiation exposure to perso)annl occupying the eonif, f 0kn;' z . 1 d i h i azardous chemioals, or smoke.

WaA)XUVWfnIVSICJS

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 4 License Amendment Request Page 3 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005) 0-.ADM-536 .l'echtical Specification Bases Control Program 4 ATTACIIMENT 1 (Page 89 of112)

TECHIINICAL SPECIFICATION BASES 3/4.7.5 Con'd) REVS The -y- - is considered io be OPFRA1BLE (Ref: JPN-PTIN-SENP-92-017) when I) Three air handling units (AHUs) (one of each (i thb .hrmc air conditioniin" units') are operable. 2).Two condensingl Units (1oiW.o*l.0ih'ec axaiiable condense-s) are operable. 3) One reciircul aiho filter unit is operabler 4) TwO recirculation fans opcrable, and 5) Associated dampers are operable. The reasonn thiee AHUs are required is "that in the event of a single lailure, only two AMUs would be available to supply air to the suction of the recirculation itte0r and fan. This is the configuration test ed to support Technical Specifi;cation olpeabity for flow through the ermergency charcoal filter., aking one AlIU out of service renders the system incapable of opelratii, In accordance wnh ith heJied config.'uriuo assumning ant accideii'and a sinigle failure (i.e. only one air handling unin availthle instead Of ihe two assumed by the analysis,) Any one. of the three condensing (air conditioning.) units is capable of maintaining the control room equipment within its environmental limits for temperature and humidity. Thus. one condensing unit can be. taken out of service without impacting the ability of the. ~lR,4114 14 I'- 3 r. . , at to acconiplish its ijtcinded funcion under single failure randions System componeints are not subjecit to rapid deterioration. having lifetimes of many years, evCn trid0r continuous flow condiiions. Visumi inspection and operatiing tests provide assurance o "s-stemn reliability and will ensure e.arly ditection of conditiolts which could cause the system to rail or operate.improperly.: The filters pirformance tests prove that filters have been propeily installed, tharino deteriorntion or daniage has occurred. and:that all components and subsystemls operate properly. The in-situ tests are pi.rlbrmcd in accordance with the methodology and intent of ANSI N510 (1975) and provide assurance that filter perfor-nanc. has not deteriorated below returne.d specification values due to aging, conamination, <rI other effects. Chlrcoal samples arc tcsted using ASTM

)3'i803-1989 in accordarncc Witlh Generic Utter 99-02. The: test conditions 30 and 95%

relative humidity) are as specified in the Generic Leiter. Table I of fhe. A-IM standard provides the tolerances that must be rmt during the testrbr each tesi parametr. The specified methyl iodide penetration value, is based on the assumptions uscd in the LOCA Analysis,

.3/4.7.6 snubbers_

All snibbers are required Olti RAI:I I to esure that thie structu al integriy of the R.*c ir Coolant system and all other safety-related systems is maintained during and miltowing a.

scismiecor other event initiating dynainic. loads.

The visual. inspcction. .tequency is. based upon maintaininp a constant lfecl oh snubber protection to each safity;-irlated sys*t.n during an earthquake or sevre truisnietnt.

Therefore, the icquired inspection interval, varis.. invcrscly with. the observed snubber failures and is determined by the. number of inoperable snubbers, found during an inspe..ction, Inspeiitions performied before that interval has elapsed may be used as-a new refereince point to determine the next inspection. However, the results of such early inspeciions perionned before the original requir.ed tiun. intervaltias elapsed (norminal timne less 25%) may not be used to lengthen the required imspectiot interyal. Any inspection whose results require a shorter inspection interval will override the previtous schedule.

Note: Add'l TS 3/4.7.5 Bases changes pending per 5/21/2010 FPL Letter L-2010-083 (Accession No. ML101450028)

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 4 License Amendment Request Page 4 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

INSERT 3 CRE to 5 rem whole body or its equivalent to any part of the body or 5 rem total effective dose equivalent (TEDE), as applicable, for the duration of the accident. These limits are consistent with the requirements of 10 CFR Part 50, Appendix A, General Design Criterion 19 and 10 CFR Part 50.67, respectively.

INSERT 4 Turkey Point Units 3 and 4 share a common CRE. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the units during normal and accident conditions. This area encompasses the control room, including the control room offices, rack area, kitchen and lavatory, and the mechanical equipment room (MER) located below the control room. The MER contains the CREVS equipment. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations, and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences, and that CRE occupants are protected from hazardous chemicals and smoke. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

The location of CREVS components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CREVS filter train provides airborne radiological protection for the CRE occupants, as demonstrated by occupant dose analyses for the most limiting design basis accident fission product release presented in the UFSAR, Chapter 14.

The CREVS provides protection from smoke and hazardous chemicals to the CRE occupants.

The analysis of hazardous chemical releases for NUREG-0737 Item III.D.3.4, "Control Room Habitability Requirement," and the subsequent reanalysis included in PC/M 06-004, "Addition of Unit 5 to the Turkey Point Site," for new chemical release hazards demonstrate that the toxicity limits are not exceeded in the CRE following a hazardous chemical release. Therefore, neither automatic nor manual actuation of the CREVS is required for an analyzed hazardous chemical release. The analysis of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactors either from the control room or from the alternate shutdown panels.

In order for the CREVS to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke. With respect to radiological emergencies, the

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 4 License Amendment Request Page 5 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

CREVS is designed as a single filtration train that is capable of automatically starting under accident conditions to initiate CRE pressurization and filtration, assuming the occurrence of a single active damper or supply fan failure. For other emergencies that could affect the CRE environment, the CREVS is capable of manual actuation.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels.

For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

The CREVS must be OPERABLE to ensure that the CRE will remain habitable to limit operator exposure during and following a DBA. Since the CREVS and CRE are common to both Turkey Point Units 3 and 4, the ACTION requirements are applicable to both units simultaneously, and must be applied according to each unit's operational MODE.

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem whole body or its equivalent to any part of the body or 5 rem total effective dose equivalent - TEDE, as applicable) or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days when in MODE 1, 2, 3, or 4.

During the period that the CRE boundary is considered inoperable in MODE 1, 2, 3, or 4, immediately initiate action to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. Previous surveys of offsite and onsite chemicals identified that no hazardous chemicals present a hazard to control room habitability.

Therefore, the mitigating action for chemical hazards may verify that the chemical hazards analyses are current and require no toxic gas protection for the CRE occupants. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowable outage time (AOT) is reasonable based on the low probability of a DBA occurring during this time period, and the use of

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 4 License Amendment Request Page 6 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005) mitigating actions. The 90 day AOT is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactors and maintain them in a safe shutdown condition in the event of a DBA. In addition, the 90 day AOT is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

In MODE 1, 2, 3, or 4, if the inoperable CREVS or the CRE boundary cannot be restored to OPERABLE status within the associated required AOT, the unit must be placed in a MODE that minimizes the accident risk. To achieve this status, the unit must be placed in at least MODE 3 (HOT STANDBY) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 (COLD SHUTDOWN) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. If the inoperability applies to both units simultaneously, be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and in MODE 5 within 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. The AOTs are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 5 or 6, with the CREVS inoperable for an inoperable CRE boundary or for other reasons, action must be taken immediately to suspend all operations that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

These ACTION requirements apply to both units simultaneously.

Surveillance Requirement (SR) 4.7.5.f verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body or its equivalent to any part of the body or 5 rem TEDE, as applicable, and the CRE occupants are protected from hazardous chemicals and smoke. SR 4.7.5.f verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, ACTION b must be entered (ACTION c must also be entered with a unit in MODE 5 or 6).

ACTION b allows time to restore the CRE boundary to OPERABLE status provided mitigating actions are taken while in MODES 1-4, that ensures that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, which endorses, with exceptions, NEI 99-03 (June 2001), Section 8.4 and Appendix F. These compensatory measures may also be used as mitigating actions as required by ACTION b. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY, as discussed in a letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 4 License Amendment Request Page 7 of 7 Control Room Habitability TSTF-448 (TAC NOS. ME0004 AND ME0005)

Habitability" (ADAMS Accession No. ML040300694). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

Turkey Point Units 3 and 4 L-2010-004 Docket Nos. 50-250 and 50-251 Attachment 5 License Amendment Request Control Room Habitability TSTF-448 (TAC NOS. ME004 AND ME005)

"Brenda Mozafari" To: "Hanek, Olga" <OIga.Hanek@fpLcom>, "BobTomonto@fpLcom"

<Brenda.Mozafari@nrc <BobTomonto@fpl.com>

.gov> cc:

Subject:

RAI on TSTF448 05/15/2009 02:22 PM I wanted to ensure you have this RAI:

REQUEST FOR ADDITIONAL INFORMATION - TURKEY POINT UNITS 3 AND 4 LICENSE AMENDMENT REQUEST (LAR 194)

"CONTROL ROOM HABITABILITY TSTF-448" (TAC NOS.ME0004 AND ME0005)

In your License Amendment Request (LAR) to adopt TSTF-448, the requested changes include changes in proposed TSTF-508. The NRC staff has not completed its review of proposed TSTF-508 and a schedule for a date for completion has not been established. Thestaff requests that the LAR be separated into two parts, one that proposes adoption of approved TSTF-448 and, if desired, a second LAR to be submitted after TSTF-508 has been approved. This will prevent delaying.review of your request to adopt TSTF-448 TS changes.

Brenda Mozafari Senior Project Manager Nuclear Regulatory Commission Saint Lucie 1 and 2; Turkey Point 3 and 4 301-415-2020