L-2024-118, Fleet License Amendment Request to Relocate Staff Qualifications from Technical Specifications to the Quality Assurance Topical Report (FPL-1)

Fleet License Amendment Request to Relocate Staff Qualifications from Technical Specifications to the Quality Assurance Topical Report (FPL-1)

ML24282A904
Person / Time
Site:	Saint Lucie, Point Beach, Turkey Point
Issue date:	10/08/2024
From:	Mack K Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2024-118
Download: ML24282A904 (1)

Text

October 8, 2024 L-2024-118 10 CFR 50.90

U.S. Nuclear Regulato1y Commission Attn: Document Control Desk Washington, DC 20555-0001

Re: Florida Power & Light Company St. Lucie Units 1 and 2, Docket Nos. 50-335, 50-389 Turkey Point Units 3 and 4, Docket Nos. 50-250, 50-251

NextEra Energy Point Beach, LLC Point Beach Units 1 and 2, Docket Nos. 50-266, 50-301

Subject:

Fleet License Amendment Request to Relocate Staff Qualifications from Technical Specifications to the Florida Power and Light and NextEra Energy Quality Assurance Topical Report (FPL-1)

Florida Power & Light Company (FPL), acting on behalf of itself and as agent for NextEra Energy Point Beach, LLC, is submitting a request for amendments to the Technical Specifications (TS) for Point Beach Nuclear Plant (PBNP) Units 1 and 2, St. Lucie (PSL) Units 1 and 2, and Turkey Point (PTN) Units 3 and 4.

The proposed amendment would modify PBNP Units 1 and 2 TS 5.3.1, PSL Unit 1 TS 5.3.1, PSL Unit 2 TS 5.3.1, and PTN Units 3 and 4 TS 5.3.1 by relocating requirements related to "Facility Staff Qualifications"/ "Unit Staff Qualifications" to the Florida Power and Light and NextEra Energy Quality Assurance Topical Rep01i (FPL-1) consistent with the guidance contained in NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls to Quality Assurance."

Enclosures 1 through 3 provide an evaluation of the proposed changes for each site, existing TS pages marked-up to show the proposed changes, and the revised (clean) TS pages.

FPL has determined that the proposed license amendment does not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and that there are no significant environmental impacts associated with the change. The PBNP, PSL, and PTN Onsite Review Groups (ORGs) have reviewed the enclosed amendment request.

FPL requests approval of the proposed amendment within one year ofNRC acceptance of this submittal. Once approved, the amendment shall be implemented within 120 days.

Florida Power & Light Company

15430 Endeavor Drive, Jupiter, FL 33478 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Florida and Wisconsin state officials.

If you should have any questions regarding this submittal, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.

I declare under penalty of pe1jury that the foregoing is true and correct.

Executed on the gth day of October 2024.

Sincerely,

Kenneth A. Mack Director, Regulatory Affairs

Enclosures:

1. Evaluation of Proposed Changes

2. Marked-up TS Pages

3. Revised TS Pages

cc: NRC Project Manager -Point Beach NRC Project Manager - St. Lucie NRC Project Manager - Turkey Point Regional Administrator - NRC Region 2 Regional Administrator - NRC Region 3 NRC Resident Inspector - Point Beach NRC Resident Inspector - St. Lucie NRC Resident Inspector - Turkey Point Public Service Commission of Wisconsin Mr. John Williamson, Florida Department of Health ENCLOSURE 1

Evaluation of the Proposed Changes

1.

SUMMARY

DESCRIPTION

Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL), acting on behalf of itself and as agent for NextEra Energy Point Beach, LLC, requests a license amendment to the Technical Specifications (TS) for Point Beach Nuclear Plant (PBNP) Units 1 and 2, St. Lucie (PSL) Units 1 and 2, and Turkey Point (PTN) Units 3 and 4 to relocate specific administrative controls in PBNP Units 1 and 2 TS 5.3.1, PSL Unit 1 TS 5.3.1, PSL Unit 2 TS 5.3.1, and PTN Units 3 and 4 TS 5.3.1 related to "Facility Staff Qualifications" / "Unit Staff Qualifications" to the Florida Power and Light and NextEra Energy Quality Assurance Topical Report (FPL-1) (Reference 6.1) consistent with the guidance contained in NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls to Quality Assurance." (Reference 6.2)

2. DETAILED DESCRIPTION

2.1 CmTent Requirements and Proposed Changes The specific TS changes for each station are also provided in Enclosure 2. For the purpose of general discussion, the proposed changes are as follows:

PBNP Units 1 and 2 PBNP TS 5.3 cunently states:

5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSIN18.1-1971, as supplemented by Regulatory Guide 1.8, Revision 1, September 1975, for comparable positions, except:

a) The education and experience eligibility requirements for license applicants, and changes thereto, shall be those previously reviewed by the NRC, specifically those referenced in NRC Safety Evaluation letter dated October 24, 2003.

b) The Operations Manager shall meet one of the following:

i) Hold a Senior Operator's license, or ii) Have held a Senior Operator's license on a similar unit (PWR), or iii) Have been certified for equivalent Senior Operator knowledge.

The proposed change will revise PBNP TS 5.3.1 to read as follows:

5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Florida Power and Light Company and NextEra Energy Quality Assurance Topical Rep01i (FPL-1).

PSL Unit 1 PSL Unit 1 TS 5.3 cmTently states:

5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS-3.1-1978 for comparable positions, except for the radiation protection manager. The radiation protection manager shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

The proposed change will revise PSL Unit 1 TS 5.3.1 to read as follows:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Florida Power and Light Company and NextEra Energy Quality Assurance Topical Report (FPL-1).

PSL Unit 2 PSL Unit 2 TS 5.3 currently states:

5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS-3.1-1978 for comparable positions, except for the radiation protection manager. The radiation protection manager shall meet or exceed the minimum qualifications of Regulatory Guide 1. 8, Revision 1, September 197 5.

The proposed change will revise PSL Unit 2 TS 5.3.1 to read as follows:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Florida Power and Light Company and NextEra Energy Quality Assurance Topical Repmi (FPL-1).

PTN Units 3 and 4

PTN Units 3 and 4 TS 5.3 cun-ently states:

5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI Nl 8.1-1971, except for the radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. The staff not covered by ANSI N18.l-1971 shall meet or exceed the minimum qualifications of Regulations, Regulatory Guides, or ANSI Standards acceptable to NRC staff.

The proposed change will revise PTN Units 3 and 4 TS 5.3.1 to read as follows:

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Florida Power and Light Company and NextEra Energy Quality Assurance Topical Report (FPL-1).

2.2 Reason for the Proposed Changes

FPL desires to eliminate discussions of referenced standards and documents and associated discussions for unit staff qualifications in the TS and use the current facility / unit staff qualifications specified in Reference 6.1. These TS changes will provide flexibility in adopting updated NRC-endorsed standards for facility / unit staff qualifications without the need to submit License Amendment Requests.

3.0 TECHNICAL EVALUATION

3.1 Condition Assessment

10 CFR 50.36(c)(5) requires TS to include administrative controls. These are provisions relating to organization and management, procedures, recordkeeping, review and audit, and repo1iing necessary to assure operation of the facility in a safe manner. Reference 6.2 states that many license amendments were being processed that involved relocating requirements that do not satisfy the criteria of 10 CFR 50.36 for inclusion as limiting conditions for operation and relocating requirements that are controlled directly by regulations and related licensee programs.

Reference 6.2 states:

Increasingly, licensees are requesting amendments to technical specifications that are located in the "administrative controls" section and are related to quality assurance programs.

Licensees have frequently requested amendments to these specifications because they contain detailed information that is affected by organizational changes without the need for a license amendment. Recent amendment requests related to quality assurance have also followed the trend for other technical specifications and have included moving requirements to licensee controlled documents and programs. The quality assurance program is a logical candidate for such relocations due to the controls imposed by such regulations as Appendix B to 10 CFR Part 50, the existence of U.S. Nuclear Regulatory Commission-approved quality assurance plans and commitments to indust1y quality assurance standards, and the established quality assurance program change control process in 10 CFR 50.54(a). The relocation of technical specification requirement in cases where adequate controls are provided by such other methods can reduce the resources spent by licensees and the U.S. Nuclear Regulatory Commission staff in preparing and reviewing license amendment requests.

The proposed changes are consistent with Reference 6.2. The facility / unit staff qualifications do not satisfy the criteria of 10 CFR 50.36 for inclusion in the TS as an Administrative Control.

Changes to Reference 6.1 are adequately controlled by other regulations; therefore, Reference 6.1 is an acceptable location for the facility / unit staff qualifications requirements. Specifically, consistent with Reference 6.2, future changes to Reference 6.1 facility / unit staff qualifications requirements will be evaluated under the 10 CFR 50.54(a) evaluation process.

3.2 Assessment Summary

The changes proposed by FPL do not change cmTent facility / unit staff qualifications requirements. The facility / unit staff qualifications requirements are identical between the cmTent plant's TS and Reference 6.1. Future changes to Reference 6.1 will be controlled via the 10 CFR 50.54(a) evaluation process.

4. REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/ Acceptance Criteria

The proposed changes have been evaluated to dete1mine whether applicable regulations and requirements continue to be met. The following NRC regulations and guidance documents were reviewed:

10 CFR 50.36

10 CFR 50.36, "Technical Specifications," Paragraph (c)(5), "Administrative Controls," requires the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner be included in the TS.

10 CFR 50.120

10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel," requires that each nuclear power plant licensee or applicant for an operator license establish, implement, and maintain the training and qualification programs that are derived from a systems approach to training as defined in 10 CFR 55.4.

10 CFR Part 55

10 CFR Part 55, "Operators' Licenses," Subpart D, "Applications," requires that operator license applications include information concerning an individual's education, experience, and other related matters to provide evidence and certification that the applicant has successfully completed the facility licensee's training program that is based on a systems approach to training.

NUREG-1021, Revision 12

NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 12, establishes the policies, procedures, and practices for examining licensees and applicants for reactor operator and senior reactor operator licenses at nuclear power reactor facilities under 10 CFR Part 55, "Operators' Licenses."

Regulatory Guide 1.8

Regulatory Guide (RG) 1.8, "Qualification and Training of Personnel for Nuclear Power Plants,"

describes a method that the NRC staff finds acceptable for complying with the NRC's regulations regarding training and qualification of nuclear power plant personnel. The proposed change would eliminate the unit staff qualification requirements from the TS and maintain the cmTent commitments to RG 1.8 along with any exceptions, alternatives, or clarifications as identified in Reference 6.1.

4.2 Precedent

On October 21, 2021, Dominion Energy submitted a LAR (ML21294A338) to revise TS 5.3, "Facility Staff Qualifications"/ "Unit Staff Qualifications," by deleting references to ANSI N18.l-1971, and ANSI 3.1 (12/79 Draft) and replacing them with reference to Dominion Energy Nuclear Facility Quality Assurance Program Description (QAPD). The LAR was applicable to Millstone, North Anna, and Suny. On July 11, 2022, the NRC approved the LAR from Dominion Energy (ML22095Al07). Duke Energy, Exelon, and the Tennessee Valley Authority have also received approval of similar amendments (ML20083F927, ML18206A282, and MLl 7034A360 respectively).

4.3 No Significant Hazards Consideration Analysis

Florida Power & Light Company (FPL), acting on behalf of itself and as agent for NextEra Energy Point Beach, LLC, requests approval of a proposed change to the Point Beach Nuclear Plant (PBNP) Units 1 and 2, St. Lucie (PSL) Units 1 and 2, and Turkey Point (PTN) Units 3 and 4 Technical Specifications (TS) TS 5.3.1, "Facility Staff Qualifications" / "Unit Staff Qualifications." The proposed change will relocate the TS Facility/Unit Staff Qualifications from either ANSI N18.l-1971, "American National Standard Selection and Training ofNuclear Power Plant Personnel," or ANSI/ANS-3.1-1978, "Selection and Training ofNuclear Power Plant Personnel," to the Florida Power and Light and NextEra Energy Quality Assurance Topical Report (FPL-1).

FPL has evaluated whether a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as described below:

(1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

The proposed changes are administrative in nature, do not make any physical changes to the plants, and do not alter accident analysis assumptions, add any initiators or affect the function of plant systems, or the manner in which systems are operated, maintained, tested, or inspected. The proposed changes do not require any plant modifications which affect the performance capability of the structures, systems and components relied upon to mitigate the consequences of postulated accidents. The facility/unit staff qualification requirements remain the same and are being relocated from the TS to the Florida Power and Light and NextEra Energy Quality Assurance Topical Report (FPL-1).

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

(2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No

The proposed changes do not involve changes to facility/unit staff selection, qualification, and training programs. The proposed changes are administrative in nature and do not impact the accident analyses. The proposed changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed changes do not introduce failure modes that could result in a new accident, and the changes do not alter assumptions made in the safety analysis. The proposed changes do not alter or prevent the ability of the operators to perform their intended actions to mitigate the consequences of an accident or event.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No

The proposed changes are administrative in nature. The proposed changes do not impact the performance or proficiency requirements for licensed operators or facility/unit staff because the qualification standards are not changing and are only being relocated from the TS to the Florida Power and Light and NextEra Energy Quality Assurance Topical Report (FPL-1 ). Margin of safety is associated with confidence in the ability of the fission product baiTiers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes do not impact operation of the plant or its response to transients or accidents.

The proposed changes do not result in plant operation in a configuration outside the design basis. Additionally, the proposed changes will not relax any criteria used to establish safety limits and will not relax any safety system settings. The safety analysis acceptance criteria are not affected by these changes. The proposed changes do not adversely affect systems that respond to safely shut down the plant and to maintain the plant in a safe shutdown condition.

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

Based upon the above analysis, FPL concludes that the proposed license amendment does not involve a significant hazards consideration, under the standards set fo1ih in 10 CFR 50.92, "Issuance of Amendment," and accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION The proposed amendments are confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22( c )(10). Therefore, pursuant to 10 CFR 51.22(b ),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

6. REFERENCES 6.1 Florida Power and Light and NextEra Energy Quality Assurance Topical Report (FPL-1 ),

Revision 31 Annual Submittal, dated July 10, 2024 (ADAMS Accession No.

ML24192A229) 6.2 NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls to Quality Assurance," dated December 12, 1995 (ADAMS Accession No.

ML031110271)

ENCL0SURE2

Marked-up TS Pages Unit Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Facility Staff Qualifications

5.3. 1 Each member of the facility staff shall meet or exceed the minimum qualifications refe r enced for comparab le positions, as specified in the F l or ida Power and Light Company and NextEra Energy Quality Assurance Topica l Report {FPL-1 ). of ANSI N18. 1 1971, as supplemented by Regulatory Guide 1.8, Revision 1, September 1975, for comparable positions, except:

a) The education and experience eligibility requirements for license applicants, and changes thereto, shall be those previously reviewed by the NRG, specifically those referenced in NRG Safety Evaluation letter dated October 24, 2003.

b) The Operations Manager shall meet one of the following :

i) Hold a Senior Operator's license, or

ii) Have held a Senior Operator ' s license on a similar unit (PWR), or

iii) Have been certified for equivalent Senior Operator knmvledge.

5. 3.2 For the purpose of 10 CFR 55.4, a licensed Senio r Reactor Operator (SRO) and a licensed reactor operator (RO) are those individuals who, in add ition to meeting the requirements of TS 5.3. 1, perform the functions described in 10 CFR 50. 54(m).

5. 3. 3 In the event the position of Health Physic i st is vacated and the proposed replacement does not meet all the qualifications of TS 5.3.1, but is determined to be otherwise well qualified, the concurrence of NRC shall be sought in approving the qualification of that individual.

Point Beach 5.3-1 Unit 1 - Amendment No. 248 Unit 2 - Amendment No. 252 Unit Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Unit Staff Qualifications

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications refe renced for compa rab le pos it io ns, as specified in the Florida Power and Li ght Company and NextE ra Ene rgy Q ual ity Assu rance Topical Report (FPL-1).ef ANSl,~<\\NS 3.1 1978 for comparable positions, except fo r the radiation protect ion manager. The radiation protection manager shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

5.3.2 For the purpose of 1 O CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

St. Lucie - Unit 1 5.3-1 Amendment ~

Unit Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Unit Staff Qualifications

5.3. 1 Each member of the unit staff shall meet or exceed the minimum qualifications refe renced for comparable posi t ions, as specified in the Florida Power and Light Company and NextEra Energy Qua lity A ssurance To p ica l Report (FPL-1). ef ANSI/ANS 3.1 1978 for comparable positions, except for the radiation protection manager. The radiation protection manager shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, Revision 1, September 1975.

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3. 1, perform the functions described in 10 CFR 50.54(m).

St. Lucie - Unit 2 5.3-1 Amendment wg Unit Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Unit Staff Qualifications

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications refe renced for comparable posit ions, as specified in the Florida Power and Light Company and NextE ra Energy Qual ity Assurance Topical Repo rt (FPL-1 ).---ef ANSI N18. 1 1971, except for the radiation protection manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. The staff not covered by ANSI N18. 1 1971 shall meet or exceed the minimum qualifications of Regulations, Regulatory Guides, or ANSI Standards acceptable to NRG staff.

5.3.2 For the purpose of 10 CFR 55.4, a licensed senior reactor operator (SRO) and a licensed reactor operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

Turkey Point Unit 3 and Unit 4 5.3-1 Amendment Nos. 297 and 290 ENCL0SURE3

Revised TS Pages Unit Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Facility Staff Qualifications

5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Florida Power and Light Company and NextEra Energy Quality Assurance Topical Report (FPL-1 ).

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed reactor operator (RO) are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

5.3.3 In the event the position of Health Physicist is vacated and the proposed replacement does not meet all the qualifications of TS 5.3.1, but is determined to be otherwise well qualified, the concurrence of NRC shall be sought in approving the qualification of that individual.

Point Beach 5.3-1 Unit 1 - Amendment No.

Unit 2 - Amendment No.

Unit Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Unit Staff Qualifications

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions. as specified in the Florida Power and Light Company and NextEra Energy Quality Assurance Topical Report (FPL-1).

5.3.2 For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

St. Lucie - Unit 1 5.3-1 Amendment Unit Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Unit Staff Qualifications

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions. as specified in the Florida Power and Light Company and NextEra Energy Quality Assurance Topical Report (FPL-1 ).

5.3.2 For the purpose of 1 O CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

St. Lucie - Unit 2 5.3-1 Amendment Unit Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS

5.3 Unit Staff Qualifications

5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions, as specified in the Florida Power and Light Company and NextEra Energy Quality Assurance Topical Report (FPL-1).

5.3.2 For the purpose of 1 O CFR 55.4, a licensed senior reactor operator (SRO) and a licensed reactor operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).

Turkey Point Unit 3 and Unit 4 5.3-1 Amendment Nos. and