2012/04/05 turkey point col hearing - fw: tsc exemption · proposed turkey point units 6 and 7...

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PMTurkeyCOLPEm Resource

From: Comar, MannySent: Thursday, April 05, 2012 1:03 PMTo: TurkeyCOL ResourceSubject: FW: TSC ExemptionAttachments: L-2012-109 Signed 03-19-2012eRAI 6290 Response.pdf

From: Madden, George [mailto:[email protected]] Sent: Wednesday, March 28, 2012 3:09 PM To: Comar, Manny Subject: TSC Exemption

Hearing Identifier: TurkeyPoint_COL_Public Email Number: 595 Mail Envelope Properties (377CB97DD54F0F4FAAC7E9FD88BCA6D080735BE2F9) Subject: FW: TSC Exemption Sent Date: 4/5/2012 1:02:36 PM Received Date: 4/5/2012 1:02:38 PM From: Comar, Manny Created By: [email protected] Recipients: "TurkeyCOL Resource" <[email protected]> Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 157 4/5/2012 1:02:38 PM L-2012-109 Signed 03-19-2012eRAI 6290 Response.pdf 441157 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

L-2012-109 10 CFR 52.3

March 19, 2012

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

Re: Florida Power & Light Company Proposed Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 Response to NRC Request for Additional Information Letter No. 051 (eRAI 6290) SRP Section 14.03 – Inspections, Tests, Analyses, and Acceptance Criteria

Reference: 1. NRC Letter to FPL dated February 1, 2012, Request for Additional Information

Letter No. 051 Related to SRP Section 14.03 – Inspections, Tests, Analyses, and Acceptance Criteria for the Turkey Point Nuclear Plant Units 6 and 7 Combined License Application

2. FPL Letter L-2012-058 to NRC, dated February 15, 2012, Supplemental Response Schedule for NRC Request for Additional Information Letter No. 042 (eRAI 5997) Standard Review Plan Section 13.03 – Emergency Planning

Florida Power & Light Company (FPL) provides, as attachments to this letter, its responses to the Nuclear Regulatory Commission’s (NRC) requests for additional information (RAI) 14.03-1 (RAI 14.03.10-1.i (Supplement 1)) and 14.03-2 (RAI 14.03.10-1.f (Supplement 1)) provided in the referenced letter. The attachments identify changes that will be made in a future revision of the Turkey Point Units 6 & 7 Combined License Application (if applicable). FPL provided the revised schedule for this response in Reference 2. If you have any questions, or need additional information, please contact me at 561-691-7490.

Florida Power & Light Company 700 Universe Boulevard, Juno Beach, FL 33408

Proposed Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 FPL Response to NRC RAI No. 14.03-1 (eRAI 6290) L-2012-109 Attachment 1 Page 1 of 5

NRC RAI Letter No. PTN-RAI-LTR-051 SRP Section: 14.03 - Inspections, Tests, Analyses, and Acceptance Criteria Question from NRC Licensing and Inspection Branch (EP) NRC RAI Number: 14.03-1 (eRAI 6290) RAI 14.03.10-1.i (Supplement 1) In RAI 14.03.10-i (August 1, 2011, Letter No. 033), the NRC requested clarification regarding (1) the 90-minute staff augmentation time in COLA Part 5 Table B-1b, and (2) the inclusion of "within 90 minutes" in three facility activation exercise ITAAC (i.e., Acceptance Criteria 8.1.1.C.1.a, 8.1.1.D.1, and 8.1.1.D.1.a) in COLA Part 10 Table 3.8-1; including whether the two are related. In its August 29, 2011, response to RAI 14.03.10-1.i, the applicant stated that the two area are related, and that the response to this question will be provided in response to NRC RAI 13.03-5 (e-RAI 5681). In its September 30, 2011, response to RAI 13.03-5, the applicant addressed (in RAI B-6, B-7, B-8, B-9, B-11, and B-12) the 90-minute response (staff augmentation) time, stating in part that the 60-minute response time (consistent with NUREG-0654) will replace the 90-minute response time (in Table B-1b). The staff verified this change in COLA Revision 3, Table B-1b. The applicant did not, however, address the three exercise ITAAC (identified above) in its response to RAI 13.03-5, in regard to how they relate to the changed staff augmentation time in Table B-1b from 90 minutes to 60 minutes. In COLA Revision 3, the three exercise ITAAC in Part 10 remained at 90 minutes. Please revise ITAAC acceptance criteria 8.1.1.C.1.a, 8.1.1.D.1, and 8.1.1.D.1.a to change "90 minutes" to "60 minutes," or explain why this change is not required. If applicable, compare the ITAAC facility activation times with the existing emergency plan facility activation times in support of Units 3 and 4. The following provides suggested revisions, which include additional slight wording changes (see also, the comparable ITAAC acceptance criteria from the Vogtle COLA): 8.1.1.C.1.a: ". . . and by the TSC within 60 minutes of TSC activation." 8.1.1.D.1: ". . . and full functional operation of the TSC and EOF within 60 minutes of activation." 8.1.1.D.1.a: ". . . within 60 minutes of the initial classification of an Alert or higher." FPL RESPONSE: FPL is committing to a 60-minute response for on-call personnel to augment the on-shift Emergency Response Organization (ERO) and to activate the emergency response facilities (EOF, TSC, and OSC). The augmentation personnel are unable to initiate a response to the emergency response facilities until they have received a call-out by the FPL ERO notification system. Upon notification, the on-call ERO personnel respond to and activate the facilities within 60 minutes. This information is included in COLA Part 5, Section H.5. COLA Part 10, Table 3.8-1 will be updated in a future COLA revision to reflect the change from a 90-minute response time to a 60-minute response time for the activation


of the EOF, TSC, and OSC for Turkey Point Units 6 & 7 from notification of an Alert or higher classification event. This update will result in changes to ITAAC acceptance criteria 8.1.1.C.1.a, 8.1.1.D.1, and 8.1.1.D.1.a. This response is PLANT SPECIFIC. References: None ASSOCIATED COLA REVISIONS: The following sheets of COLA Part 10, Table 3.8-1 will be updated in a future COLA revision:

Pro

pose

d Tu

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Poi

nt U

nits

6 a

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D

ocke

t Nos

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and

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41

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pons

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AI N

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Tabl

e 3.

8-1

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Em

erge

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Plan

Insp

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ests

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lyse

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riter

ia

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Sta

ndar

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Pro

gram

Ele

men

ts

Insp

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ests

, Ana

lyse

s A

ccep

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riter

ia

8.0

Exer

cise

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d D

rills

(con

t.)

B

. N

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catio

ns (c

ont.)

a.

Initi

ate

notif

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of o

nsite

in

divi

dual

s (v

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lant

pag

e or

te

leph

one)

usi

ng d

esig

nate

d ch

eckl

ist.

4.

Dem

onst

rate

the

capa

bilit

y of

the

Ale

rt an

d N

otifi

catio

n S

yste

m

(AN

S) f

or th

e pu

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, to

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ate

prop

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whe

n re

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d.

Sta

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riter

ia:

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he s

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ope

rate

pr

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ly a

s in

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ted

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ren

feed

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tem

.

C.

Em

erge

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D

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pabi

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to d

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an

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atio

ns.

Sta

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a. C

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and

and

cont

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s de

mon

stra

ted

in th

e co

ntro

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m

in th

e ea

rly p

hase

of t

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the

TSC

with

in

90 6

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ficat

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from

not

ifica

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of

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clas

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Dem

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the

abili

ty to

tran

sfer

em

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ncy

dire

ctio

n fro

m th

e co

ntro

l roo

m (s

imul

ator

) to

the

TSC

.

Pro

pose

d Tu

rkey

Poi

nt U

nits

6 a

nd 7

D

ocke

t Nos

. 52-

040

and

52-0

41

FPL

Res

pons

e to

NR

C R

AI N

o. 1

4.03

-1 (e

RA

I 629

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09 A

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(She

et 1

3 of

18)

Em

erge

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Plan

Insp

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ests

, Ana

lyse

s, a

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ccep

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riter

ia

Plan

ning

Sta

ndar

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Pro

gram

Ele

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ts

Insp

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ns, T

ests

, Ana

lyse

s A

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ia

8.0

Exer

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D

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Res

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Sup

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ter (

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C)

and

full

func

tiona

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ratio

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the

TSC

and

EO

F w

ithin

90

60

min

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of e

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cla

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from

not

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F an

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re

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0 60

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of

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initi

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m n

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secu

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tabi

lity

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autio

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TS

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SC

, EO

F an

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mer

genc

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ter (

EN

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as

appr

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valu

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the

adeq

uacy

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he

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uipm

ent i

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erge

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resp

onse

faci

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avai

labi

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and

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ral

cons

iste

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with

the

Em

erge

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Pla

n Im

plem

entin

g P

roce

dure

s (E

PIP

s).

b. T

he S

ecur

ity M

anag

er

impl

emen

ts a

nd fo

llow

s ap

plic

able

EP

IPs.


ASSOCIATED ENCLOSURES: None


NRC RAI Letter No. PTN-RAI-LTR-051 SRP Section: 14.03 - Inspections, Tests, Analyses, and Acceptance Criteria Question from NRC Licensing and Inspection Branch (EP) NRC RAI Number: 14.03-2 (eRAI 6290) RAI 14.03.10-1.f (Supplement 1) In RAI 14.03.10-1.f (August 1, 2011, Letter No. 033), the NRC requested that the applicant submit an appropriate exemption request that addresses a Tier 1 departure from AP1000 DCD Tier 1 Table 3.1-1, to the extent that COLA Part 10 Table 3.8-1 ITAAC represent a replacement of the comparable Table 3.1-1 ITAAC. In its August 29, 2011, response to RAI 14.03.10-1.f, the applicant stated in part that a Tier 1 departure and exemption request is not appropriate because the emergency planning ITAAC provided in COLA Part 10 Table 3.8-1 are not a replacement, but rather a supplement to the ITAAC in DCD Tier 1 Table 3.1-1. In COLA Part 7 (Departures and Exemption Requests), Revision 3, the applicant did not include an exemption request in Section B (Turkey Point 6 & 7 Exemption Requests) to address DCD Table 3.1-1. Please address the following questions: a. In COLA Part 7, Section A.1 (Departures That Can Be Implemented Without

Prior NRC Approval), correct the Description entry for Departure Number PTN DEP 18.8-2 to read "Technical support center location," rather than "Operations support center location."

b. Provide an appropriate Tier 1 departure and exemption request that removes the ITAAC in DCD Tier 1 Table 3.1-1 from the application. The Table 3.1-1 ITAAC are directly related to the Technical Support Center's (TSC) location in the AP1000 Annex Building (i.e., the control support area). In COLA Part 7 Departure Number 18.8-2, the applicant moved the TSC from the control support area to the Turkey Point Nuclear Training Building, located outside of the Protected Areas between the control room for Units 3 & 4 and the control rooms for Units 6 & 7. The removal (departure) of the TSC from the control support area necessitates the removal (departure) of the TSC-related ITAAC in Table 3.1-1. While the requested Tier 1 departure and exemption request for DCD Table 3.1-1 represents a change in the staff's approach from what was accepted for the Vogtle and Summer combined license applications (COLAs) - which had comparable DCD TSC relocations (i.e., departures), without a Tier 1 departure and exemption request for DCD Table 3.1-1 - the change is needed for Turkey Point Units 6 & 7, in order to more accurately comply with the structure and intent of the 10 CFR Part 52 licensing paradigm. Whenever an applicant (for a COL that references a certified design) takes a departure from a facility description in the DCD, the applicant must also depart from the ITAAC for that portion of the facility design.


FPL RESPONSE: As described in response to RAI 13.03-17 Subpart a, FPL has revised its position with regards to its response to RAI 14.03.10-1 Subpart f and, therefore, has withdrawn its August 29, 2011 response to Subpart f in RAI 14.03.10-1. Further detail of FPL’s new position on the Tier 1 Table 3.1-1 ITAAC departure and exemption request is provided in Subpart b of this RAI response. a. Departure Number PTN DEP 18.8-2 addresses the location of the Technical Support Center (TSC). The Description entry for Departure Number PTN DEP 18.8-2 will be revised to read “Technical support center location” and moved to Section A.2 as a result of Subpart b of this RAI response. b. In Departure Number PTN DEP 18.8-2, FPL states that the TSC is not located in the Control Support Area (CSA) and, as described in the Emergency Plan, the TSC will be located in the Turkey Point Units 6 & 7 Training Building, outside of the protected area. This location differs from the location described in the DCD and therefore several aspects of the TSC Design Description and ITAAC - included in Tier 1 Section 3.1 and Table 3.1-1, respectively - are not directly applicable to Turkey Point Units 6 & 7. FPL will provide an exemption request to remove the Tier 1 Section 3.1 and Tier 1 Table 3.1-1 from the application. The Tier 1 Section 3.1 will be replaced with plant-specific information located in COLA Part 2, Section 13.3. The ITAAC in Tier 1 Table 3.1-1 will be replaced with certain specific ITAAC provided in Table 3.8-1 of COLA Part 10. Departure Number PTN DEP 18.8-2 will also be revised to reference the Tier 1 exemption request. Additionally, FPL will provide a more detailed description of the TSC habitability features in COLA Part 2, Section 18.8. This response is PLANT SPECIFIC. References:

1. FPL Letter L-2011-356 to NRC dated August 29, 2011, Response to NRC Request for Additional Information Letter No. 033 (eRAI 5682), Standard Review Plan Section 14.03.10 Emergency Planning – Inspection, Tests, Analyses, and Acceptance Criteria.


ASSOCIATED COLA REVISIONS: Departure Number PTN DEP 18.8-1 and 18.8-2 in COLA Part 2, Table 1.8-201 will be updated in a future COLA revision, as shown below:

PTN DEP 18.8-1 The Operations Support Center (OSC) is being moved from the location identified in DCD Subsections 18.8.3.6, 12.5.2.2, and 12.5.3.2 and as identified on DCD figures in SubSections 1.2, 12.3, and Appendix 9A. There will be a single OSC for Units 6 & 7 located as described in FSAR Section 13.3 and the Emergency Plan.

1.2.3 9.4.2.2 9A 12.3.1.2 12.5.2.2 12.5.3.2 13.3 18.8.3.6

PTN DEP 18.8-2 The Technical Support Center (TSC) is not located in the control support area as identified in DCD Subsection 18.8.3.5. The TSC is common for Turkey Point Units 3, 4, 6, and 7 and is located as described in FSAR Section 13.3 and the Emergency Plan.

13.3 18.8.3.5

COLA Part 2, Section 13.3 will be updated in a future COLA revision, with LMAs of PTN DEP 18.8-1 and PTN DEP 18.8-2, as shown below:

Replace the first paragraph of DCD Section 13.3 with the following: See DCD Section 18.8 for the high level requirements for the Technical Support Center (TSC) and the Operations Support Center (OSC). The TSC is not located in the control support area as identified in DCD Subsection 18.8.3.5. The TSC is common for Turkey Point Units 3, 4, 6, and 7 and is located on the second floor of the Units 6 & 7 Training Building outside the protected areas (PA) of all units. The Operations Support Center (OSC) is not located in the ALARA briefing room as identified in DCD Subsections 18.8.3.6, 12.5.2.2, and 12.5.3.2, and as identified on DCD figures in Sections 1.2, 12.3, and Appendix 9A. There is a single OSC for Units 6 & 7 located in the Maintenance Support Building inside the PA. See DCD Section 9.4 for a description of the HVAC systems for the main control room and see Subsection 18.8.3.5 for a description of the TSC HVAC and habitability systems. See Section 7.5 for identification of plant variables that are provided for interface to the emergency planning areas. Add the following paragraphs after the first paragraph of DCD Section 13.3. This information replaces DCD Tier 1 Section 3, Non-System Based Design Descriptions & ITAAC, Section 3.1, Emergency Response Facilities.


Emergency Response Facilities Design Description and ITAAC Emergency Response Facilities Design Description The technical support center (TSC) is a facility from which management and technical support is provided to main control room (MCR) personnel during emergency conditions. The operations support center (OSC) provides an assembly area where operations support personnel report in an emergency. The TSC is located outside the protected area (PA), and procedures are in place to enhance passage through security checkpoints expeditiously. There is an OSC located inside the PA in the Maintenance Support Building. The TSC and OSC are separate from the main control room. 1. The TSC has floor space of at least 75 ft2 per person for a minimum of 40

persons. 2. The TSC has voice communication equipment for communication with the

MCR, emergency operations facility, OSC, and the U.S. Nuclear Regulatory Commission (NRC).

3. The plant parameters listed in DCD Table 7.5-1, Post-Accident Monitoring System, and FSAR Table 7.5-201, Post-Accident Monitoring System, can be retrieved in the TSC.

4. The OSC has voice communication equipment for communication with the MCR and TSC.

5. The TSC and OSC are in different locations. 6. The TSC provides a habitable workspace environment. Inspections, Test, Analyses, and Acceptance Criteria COLA Part 10 Table 3.8-1 specifies the inspection, tests, analyses, and associated acceptance criteria for the Emergency Planning ITAAC. Table 3.8-1 Item 3.0, Emergency Communications, provides the emergency communications ITAAC. Table 3.8-1 Item 5.1 provides the emergency facilities ITAAC for the TSC and OSC.

COLA Part 2, Subsection 18.8.3.5 will be updated in a future COLA, as shown below: The Technical Support Center (TSC) location is described in Section 13.3 and the Emergency Plan. Add the following paragraphs after the fifth paragraph of DCD Subsection 18.8.3.5: The TSC structure and ventilation system, a subsystem of the Training Building structure and ventilation system, is designed to ensure that the TSC personnel are protected from radiological hazards. The design of the TSC ventilation system is modeled after Figure 1 of Regulatory Guide 1.52, Revision 3, June 2001, with the exception of installation of moisture


separators and heaters in the charcoal unit. The flow rates provided are bounding values used for the calculation of TSC dose from a Turkey Point Units 3 & 4 releases. The boundary of the TSC envelope is designed and constructed to minimize in-leakage. Unfiltered in-leakage is expected to be less than the assumed value described below. The filtered recirculation flow rate and filter efficiencies are anticipated to be greater than those provided below. During normal operation the system functions as a normal ventilation system providing temperature control, filtration, and outside air make-up. The TSC HVAC system is operated in accordance with emergency plan implementing procedures (EPIP) and is manually controlled in accordance with the EPIP from the TSC. At the onset of the accident, the TSC is assumed to be in normal ventilation mode with the switch to the emergency mode occurring manually based on high radiation readings. Portable radiation monitors are available for personnel to transit from the TSC to other areas. Portable air breathing apparatus and anti-contamination clothing are provided in the TSC. The TSC HVAC, lighting, and vital information systems are powered by reliable and redundant power supplies. The TSC redundant power includes battery and diesel backed uninterruptible power supplies. In the emergency mode of operation, outside air is drawn through high efficiency particulate air (HEPA) filters and an activated charcoal filter assembly before being discharged into TSC spaces. The system provides 99 percent removal efficiency for particulates and 90 percent decontamination efficiency for radioiodine. These efficiencies are consistent with those provided in DCD Table 9.4-1 for the main control room and the control support area (CSA). Return air from within the TSC is mixed with the incoming outside air and recirculated through the filter assembly to minimize airborne contamination and provide for environmental conditioning. In the emergency mode of TSC HVAC operation, the system maintains a 1/8-inch (water gauge) positive pressure in the TSC relative to outside by admitting 1000 cfm of outside air. This make-up flow of 1000 cfm provides sufficient ventilation (filtered fresh air) for 100 people. The charcoal adsorber and HEPA unit filter an additional 1000 cfm that is recirculated from the TSC. There is also an assumed unfiltered in-leakage of 500 cfm during emergency mode of operation. There is also an unfiltered recirculation rate of approximately 15,000 cfm. The HVAC system is designed as a non-seismic system and is not provided with redundant fans or filters, as permitted by the NUREG-0696 recommendations for the TSC. Each TSC entrance is provided with a vestibule that functions similar to an airlock to minimize air in-leakage due to personnel ingress and egress. When the TSC HVAC is required for the emergency mode of operation, the Training Building HVAC system is isolated from the TSC HVAC system using


power-operated dampers. In addition, the Training Building ventilation for the first and third floors is secured. The Training Building HVAC system components necessary to support the emergency mode of operation are controlled from inside the TSC. Controls may be located within mechanical equipment spaces, but the following controls and indications, as a minimum, are provided in the TSC: 1. Charcoal adsorber temperature 2. Manual filter deluge actuation 3. Radiation monitors

COLA Part 2, Subsection 18.8.3.6 will be updated in a future COLA revision, as shown below:

The Operations Support Center (OSC) location is described in Section 13.3 and the Emergency Plan.

Departure Number PTN DEP 18.8-2 will be removed from Part 7, Section A.1, page 7-1 and added to Part 7, Section A.2, page 7-1 in a future COLA revision, as shown below:

A.1 Departures That Can Be Implemented Without Prior NRC Approval Departure Number Description

STD DEP 1.1-1 Administrative departure for organization and numbering for the FSAR sections and subsections

PTN DEP 2.0-2 Maximum normal wet bulb (noncoincident) air temperature

PTN DEP 2.0-4 Population distribution exclusion area (site) PTN DEP 2.5-1 DELETED STD DEP 8.3-1 Class 1E voltage regulating transformer current

limiting features PTN DEP 9.3-1 Plant gas system – hydrogen gas portion PTN DEP 18.8-1 Operations support center location PTN DEP 18.8-2 Technical support center location PTN DEP 19.58-1 Severe winds and tornadoes

A.2 Departures That Require NRC Approval Prior to Implementation Departure Number Description PTN DEP 2.0-1 Operating basis wind speed PTN DEP 2.0-3 Maximum safety wet bulb (noncoincident) air

temperature PTN DEP 18.8-2 Technical support center location


Exemption Number B.5 will be added to Part 7, Section B, page 7-1 and 7-29 in a future COLA revision, as shown below:

B. Turkey Point Units 6 & 7 Exemption Requests Exemption

Number Description

B.1 Combined License (COL) Application organization and numbering

B.2 Maximum safety wet bulb (noncoincident) air temperature

B.3 DELETED B.4 Special Nuclear Material (SNM) Material Control and

Accounting Program Description B.5 Departure from DCD Tier 1, Section 3, Non-System

Based Design Descriptions & ITAAC, Section 3.1, Emergency Response Facilities


Departure Number PTN DEP 18.8-2 Description entry will be corrected and removed from Part 7, Section A.1, page 7-2 and added to Part 7, Section A.2, page 7-23 in a future COLA revision, as shown below:

A.1 Departures That Can Be Implemented Without Prior NRC Approval Departure Number Description

STD DEP 1.1-1 Administrative departure for organization and numbering for the FSAR sections and subsections

PTN DEP 2.0-2 Maximum normal wet bulb (noncoincident) air temperature

PTN DEP 2.0-4 Population distribution exclusion area (site) PTN DEP 2.5-1 DELETED STD DEP 8.3-1 Class 1E voltage regulating transformer current

limiting features PTN DEP 9.3-1 Plant gas system – hydrogen gas portion PTN DEP 18.8-1 Operations support center location PTN DEP 18.8-2 Operations support center location PTN DEP 19.58-1 Severe winds and tornadoes

A.2 Departures That Require NRC Approval Prior to Implementation Departure Number Description PTN DEP 2.0-1 Operating basis wind speed PTN DEP 2.0-3 Maximum safety wet bulb (noncoincident) air

temperature PTN DEP 18.8-2 Technical support center location

The “AFFECTED DCD/FSAR SECTIONS:” section of Departure Number PTN DEP 18.8-1 in Part 7, Section A will be updated in a future COLA revision, as shown below:

AFFECTED DCD/FSAR SECTIONS: 1.2.3; 9.4.2.2; 9A; 12.3.1.2; 12.5.2.2; 12.5.3.2; 13.3; 18.8.3.6

The “SUMMARY OF DEPARTURE:” section of Departure Number PTN DEP 18.8-1 in Part 7, Section A will be updated in a future COLA revision, as shown below:

The Operations Support Center (OSC) is being moved from the location identified in DCD Subsections 18.8.3.6, 12.5.2.2, and 12.5.3.2 and as identified on DCD figures in SubSections 1.2, 12.3, and Appendix 9A. There will be a single OSC for Units 6 & 7 located as described in FSAR Section 13.3 and the Emergency Plan.


The “DEPARTURE JUSTIFICATION:” section of Departure Number PTN DEP 18.8-1 in Part 7, Section A will be updated in a future COLA revision, as shown below:

The referenced DCD states, "The ALARA briefing and operations support center is located off the main corridor immediately beyond the main entry to the annex building," and indicates that the OSC location is identified on Figure 1.2-18. For Units 6 & 7, the OSC is being moved, as described in FSAR Section 13.3 and the Emergency Plan, and one OSC will serve both Units 6 & 7 to optimize use of space and operational resources.

The “AFFECTED DCD/FSAR SECTIONS:” section of Departure Number PTN DEP 18.8-2 in Part 7, Section A will be updated in a future COLA revision, as shown below:

AFFECTED DCD/FSAR SECTIONS: 13.3; 18.8.3.5

The “SUMMARY OF DEPARTURE:” section of Departure Number PTN DEP 18.8-2 in Part 7, Section A will be updated in a future COLA revision, as shown below:

SUMMARY OF DEPARTURE: The Technical Support Center (TSC) is not located in the control support area as identified in DCD Subsection 18.8.3.5. The TSC is common for Turkey Point Units 3, 4, 6, and 7 and is located as described in FSAR Section 13.3 and the Emergency Plan.

The “DEPARTURE JUSTIFICATION:” section of Departure Number PTN DEP 18.8-2 in Part 7, Section A will be updated in a future COLA revision, as shown below:

DEPARTURE JUSTIFICATION: The referenced DCD states, "The TSC is located in the control support area (CSA)." This is not the case for Units 6 & 7. The TSC location is moved to a central location as identified in FSAR Section 13.3 and the Emergency Plan, such that a single TSC can serve Units 3, 4, 6, and 7 to optimize use of space and operational resources.

The “NRC APPROVAL REQUIREMENT:” section of Departure Number PTN DEP 18.8-2 in Part 7, Section A will be updated in a future COLA revision, as shown below:

NRC APPROVAL REQUIREMENT: This departure does not require prior NRC approval pursuant to 10 CFR Part 52, Appendix D, Section VIII.B.5, as it pertains to the relocation of the TSC because the TSC location is Tier 2 information. However, the change requires a departure from DCD Tier 1, Section 3, Non-System Based Design Descriptions & ITAAC, Section 3.1, Emergency Response Facilities. Therefore, an exemption is requested in Part B of this COL Application part for NRC approval of that Tier 1 departure.


Exemption Number B.5 will be added to Part 7, Section B in a future COLA revision, as shown below:

B.5) DEPARTURE FROM DCD TIER 1, SECTION 3, NON-SYSTEM BASED DESIGN DESCRIPTIONS & ITAAC, SECTION 3.1, EMERGENCY RESPONSE FACILITIES

Applicable Regulation(s): 10 CFR Part 52, Appendix D, Section VIII.A.4; DCD Tier 1, Section 3, Non-System Based Design Descriptions & ITAAC, Section 3.1, Emergency Response Facilities Specific wording from which exemption is requested:

DCD Tier 1, Section 3, Non-System Based Design Descriptions & ITAAC, Section 3.1, Emergency Response Facilities 3.1 Emergency Response Facilities Design Description The technical support center (TSC) is a facility from which management and technical support is provided to main control room (MCR) personnel during emergency conditions. The operations support center (OSC) provides an assembly area where operations support personnel report in an emergency. The control support area (CSA) is an area nearby the MCR from which support can be provided to the MCR. 1. The TSC has floor space of at least 75 ft2 per person for a minimum

of 25 persons. 2. The TSC has voice communication equipment for communication

with the MCR, emergency operations facility, OSC, and the U.S. Nuclear Regulatory Commission (NRC).

3. The plant parameters listed in Table 2.5.4-1, minimum inventory table, in subsection 2.5.4, Data Display and Processing System (DDS), with a "Yes" in the "Display" column, can be retrieved in the TSC.


5. The TSC and OSC are in different locations. 6. The CSA provides a habitable workspace environment.


Inspections, Tests, Analyses, and Acceptance Criteria Table 3.1-1 specifies the inspections, tests, analyses, and associated acceptance criteria for the emergency response facilities.

Table 3.1-1 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria

1. The TSC has floor space of at least 75 ft2 per person for a minimum of 25 persons.

An inspection will be performed of the TSC floor space.

The TSC has at least 1875 ft2 of floor space.

2. The TSC has voice communication equipment for communication with the MCR, emergency operations facility, OSC, and the NRC.

An inspection and test will be performed of the TSC voice communication equipment.

Communications equipment is installed, and voice transmission and reception are accomplished.

3. The plant parameters listed in Table 2.5.4-1, minimum inventory table, in subsection 2.5.4, DDS, with a "Yes" in the "Display" column, can be retrieved in the TSC.

An inspection will be performed for retrievability of the plant parameters in the TSC.

The plant parameters listed in Table 2.5.4-1, minimum inventory table, in subsection 2.5.4, DDS, with a "Yes" in the "Display" column, can be retrieved in the TSC.


Inspection will be performed of the OSC voice communication equipment.

Communications equipment is installed, and voice transmission and reception are accomplished.

5. The TSC and OSC are in different locations.

An inspection will be performed of the location of the TSC and OSC.

The TSC and OSC are in different locations.

6. The CSA provides a habitable workspace environment.

See Tier 1 Material, Table 2.7.1-4, items 1, 8a), 8c), 12, and 13, Nuclear Island Nonradioactive Ventilation System.

See Tier 1 Material, Table 2.7.1-4, items 1, 8a), 8c), 12, and 13, Nuclear Island Nonradioactive Ventilation System.

Pursuant to 10 CFR 52, Appendix D, Section VIII.A.4, which incorporates the exemption standards from 10 CFR 52.63(b)(1), FPL requests an exemption from these Tier 1 provisions in order to provide a new plant-specific Design Description for Emergency Response Facilities in FSAR Section 13.3 and to provide corresponding plant-specific ITAAC in COLA Part 10 Section 3.8, “Emergency Response Facilities ITAAC.” Together, these two plant-specific provisions replace DCD Tier 1 Section 3.1, “Emergency Response Facilities” in its entirety. Discussion: The location of the TSC at Turkey Point (PTN) Units 6 & 7 is the subject of Departure Number PTN DEP 18.8-2. In that departure, FPL states that it will have a combined TSC, as described in FSAR Section 13.3 and the Emergency Plan, which will be used both for Turkey Points Units 6 & 7 as well as the existing Turkey Point Units 3 & 4. The Emergency Plan states that the combined TSC will be located in the Turkey Point Units 6 & 7 training building, outside the protected area. The combined TSC will be located between the Turkey Point Units 3 & 4 control room and the Turkey Point Units 6 & 7 MCRs.


The Emergency Response Facilities Design Description and corresponding ITAAC in Tier 1 Section 3.1 of the AP1000 DCD assume that the TSC is located as identified in the DCD. As FPL has taken a departure regarding the location of the Turkey Point Units 6 & 7 TSC, several aspects of the Design Description and ITAAC in Tier 1, Section 3.1 are not directly applicable to Turkey Point Units 6 & 7, because the Table 3.1-1 ITAAC are directly related to the TSC location in the CSA. This exemption is necessary in order to ensure that the Design Description and ITAAC applicable to the TSC are consistent with the design of the shared TSC, as identified in Departure Number PTN DEP 18.8-2 and the Emergency Plan. The relocated TSC meets the guidance of NUREG-0696, Functional Criteria for Emergency Response Facilities, and RG 1.206, Combined License Applications for Nuclear Power Plants, regarding structure, habitability, size, communications, instrumentation, data system equipment, power supplies, technical data, records availability, and management. The TSC does not meet the guidance of NUREG-0696, Functional Criteria for Emergency Response Facilities, regarding location of the TSC. The justification of the Turkey Point TSC location is provided in DCD Tier 2 Departure, PTN DEP 18.8-2. Design Description Changes in FSAR Section 13.3 The six Emergency Planning Design Description items in FSAR Section 13.3 comply with NUREG-0696 and meet the functional intent of the Design Description in Tier 1 Section 3.1, with minor differences to account for the different locations as identified below.

• Turkey Point Units 6 & 7 Emergency Response Facilities Design Description Items 2, 4, and 5 are unchanged from Tier 1 Section 3.1-1.

• Design Description Item 1 is changed from Tier 1, Section 3.1-1, Item 1 to require the TSC to have floor space of 75 ft2 per person for a minimum of 40 people. This is due to the increased number of people in the combined TSC, and is consistent with the square-footage-per-person guidance provided in NUREG-0696.

• Design Description Item 3 is changed from Tier 1, Section 3.1-1, Item 3 to state: “The plant parameters listed in DCD Table 7.5-1, Post-Accident Monitoring System, and FSAR Table 7.5-201, Post-Accident Monitoring System, can be retrieved in the TSC.” These tables provide listings of the post-accident monitoring parameters that the TSC can use to receive, store, process, and display plant and environmental information. FSAR Table 7.5-201 supplements DCD Table 7.5-1 and provides the site-specific information to address the notes in the remarks column of DCD Tier 2 Table 7.5-1. DCD Table 7.5.1 and FSAR Table 7.5-201 contain the plant parameters required by Section VI.2.a of Appendix E to 10 CFR Part 50, including plant equipment status and parameter information for reactor core and coolant system conditions, reactor containment conditions, radioactivity release conditions, and plant meteorological conditions.

• Design Description Item 6 is changed from Tier 1, Section 3.1-1, Item 6 to replace the reference to the CSA with a reference to the TSC in order to reflect the fact the Turkey Point Units 6 & 7 TSC will not be located in the CSA.


ITAAC Acceptance Criteria Changes in COLA Part 10, Table 3.8-1

• Acceptance Criterion 5.1.1 applies to Design Description Item 1, regarding the size of the TSC. Criterion 5.1.1 will confirm the TSC is at least 3,000 square feet, to correspond to the Design Description requirement of 75 ft2 per person for a minimum of 40 people.

• Acceptance Criteria 3.2 and 5.1.3 apply to Design Description Item 2, regarding voice communication equipment. Criterion 3.2 will confirm the installation of communications equipment between the NRC and the main control room, TSC and EOF. Criterion 5.1.3 will confirm the installation of communications equipment between the main control room, the OSC, and the emergency operations facility (EOF).

• Acceptance Criterion 5.1.5 applies to Design Description Item 3, regarding the retrievability of the minimum inventory plant parameters. Criterion 5.1.5 will confirm that the TSC has the means to receive, store, and display plant and environmental information listed in DCD Table 7.5-1 and FSAR Table 7.5-201.

• Acceptance Criterion 5.1.8 applies to Design Description Item 4, regarding communication between the OSC, the TSC, and the MCR. Criterion 5.1.8 will confirm the installation of equipment for communication between the OSC and OSC teams, the TSC, and the main control room.

• Acceptance Criteria 5.1.2 and 5.1.7 apply to Design Description Item 5, which requires the OSC and TSC to be in different locations. Criterion 5.1.2 will confirm that the TSC is located outside the protected area. Criterion 5.1.7 will confirm that the OSC is located inside the protected area. Together, these criteria will confirm that the TSC and OSC are in different locations.

• Acceptance Criterion 5.1.4 applies to Design Description Item 6, regarding CSA workspace habitability. Criterion 5.1.4 identifies attributes of the TSC ventilation system that will provide a habitable workspace, including high-efficiency particulate air (HEPA) filter, charcoal filter, and radiation monitors, as well as controls and displays within the TSC to control and monitor the TSC ventilation system. Criterion 5.1.4 will confirm the installation of the TSC ventilation system with these attributes.

Evaluation: In accordance with 10 CFR Part 52, Appendix D, Section VIII.A.4, this exemption request is evaluated under, 10 CFR 52.63(b)(1). Section 52.63(b)(1) incorporates the requirements of 10 CFR 52.7, which incorporates the requirements of 10 CFR 50.12. Section 50.12 allows the Commission to grant an exemption if 1) the exemption is authorized by law, 2) will not present an undue risk to the public health and safety, 3) is consistent with the common defense and security, and 4) special circumstances are present as specified in 10 CFR 50.12(a)(2). Section 52.63(b)(1) also requires the Commission to consider whether the special circumstances required to be present outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption. Further, Appendix D, VIII.A.4 states that the Commission will deny a Tier 1 exemption request if it determines that the design change will result in a significant decrease in the level of safety of the design.


In summary, the NRC regulations require an exemption from Tier 1 information to show that: 1) the change will not result in a significant decrease in the level of safety otherwise provided by the design; 2) the exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security; 3) special circumstances are present as specified in 10 CFR 50.12(a)(2); and 4) the special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption. As shown below, each of these four criteria are satisfied. (1) As described above, the exemption will not result in a significant decrease in the level of safety otherwise provided by the design. The plant design has been changed by Departure Number PTN DEP 18.8-2. The DCD includes ITAAC to provide the NRC with a mechanism to confirm that the as-built facility meets the requirements of the licensed design. Because the Turkey Point Units 6 & 7 licensed design will have a different TSC location, different ITAAC are necessary in order to meet this regulatory purpose. This exemption provides plant-specific emergency planning ITAAC that are consistent with the modified plant design, by which the NRC can confirm that the as-built TSC has the capabilities identified in NUREG-0696. This exemption will not result in any decrease in the level of safety otherwise provided by the design. (2) The exemption is not inconsistent with the Atomic Energy Act or any other statute and therefore is authorized by law. As discussed above, the exemption does not have an adverse impact on the level of safety provided by the AP1000 Standard Plant design and therefore will not present an undue risk to the public health and safety. The exemption does not present any concerns regarding the common defense and security. (3) Special circumstances are present as specified in 10 CFR 50.12(a)(2). Specifically, application of the DCD Tier 1 Section 3.1 Design Description and ITAAC parameters would not serve the underlying purpose of the rules. The Design Description and ITAAC were included in the DCD in order to provide a legally enforceable mechanism to confirm that the as-built facility matches the licensed design. Where a COL applicant departs from the certified design, an ITAAC based on that design would not serve this underlying purpose. Instead, new plant-specific ITAAC are appropriate. Consequently, granting a change from the design description and ITAAC in Tier 1 Section 3.1 of the DCD would ensure that the ITAAC correspond to the plant-specific licensed design, which is the underlying purpose of the rule.

(4) The special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption. As stated above, there is no decrease in safety associated with this exemption. Conclusion: As demonstrated above, this exemption request complies with the requirements in Section VIII.A.4 of the design certification rule for the AP1000 and the regulations incorporated therein.


COLA Part 10, Appendix B will be updated in a future COLA revision, as shown below:

EMERGENCY PLANNING ITAAC The emergency planning ITAAC that are in the scope of the Westinghouse AP1000 standard design are included in the referenced DCD Tier 1 SubSection 3.1 as incorporated by reference above. The site-specific emergency planning ITAAC that supplement or are outside the scope of completely replace the Westinghouse AP1000 standard design in DCD Tier 1 SubSection 3.1 are provided in the attached Table 3.8-1. Include these ITAAC after DCD Tier 1 Section 3.7. Enclosures: None

2012/04/05 turkey point col hearing - fw: tsc exemption · proposed turkey point units 6 and 7...

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