proposed turkey point units 6 and 7 - response to nrc request … · l-2012-109 10 cfr 52.3 march...

0FPL.

L-2012-10910 CFR 52.3

March 19, 2012

U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D.C. 20555-0001

Re: Florida Power & Light CompanyProposed Turkey Point Units 6 and 7Docket Nos. 52-040 and 52-041Response 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 InformationLetter No. 051 Related to SRP Section 14.03 - Inspections, Tests, Analyses, andAcceptance Criteria for the Turkey Point Nuclear Plant Units 6 and 7 CombinedLicense Application

2. FPL Letter L-2012-058 to NRC, dated February 15, 2012, SupplementalResponse 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, itsresponses to the Nuclear Regulatory Commission's (NRC) requests for additionalinformation (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 changesthat will be made in a future revision of the Turkey Point Units 6 & 7 Combined LicenseApplication (if applicable). FPL provided the revised schedule for this response inReference 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 7Docket Nos. 52-040 and 52-041L-2012-109

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

Executed on March 19, 2012.

Sincerely,

William Maher

Senior Licensing Director - New Nuclear Projects

WDM/GRM

Attachment 1: FPL Response to NRC RAI No. 14.03-1 (eRAI 6290)

Attachment 2: FPL Response to NRC RAI No. 14.03-2 (eRAI 6290)

cc:PTN 6 & 7 Project Manager, AP1000 Projects Branch 1, USNRC DNRL/NRORegional Administrator, Region II, USNRCSenior Resident Inspector, USNRC, Turkey Point Plant 3 & 4

Proposed Turkey Point Units 6 and 7Docket Nos. 52-040 and 52-041FPL Response to NRC RAI No. 14.03-1 (eRAI 6290)L-2012-109 Attachment I 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 clarificationregarding (1) the 90-minute staff augmentation time in COLA Part 5 Table B-I b, and (2)the inclusion of "within 90 minutes" in three facility activation exercise ITAAC (i.e.,Acceptance Criteria 8.1.1.C.l.a, 8.1.1.D.1, and 8.1.1.D.l.a) in COLA Part 10 Table 3.8-1; including whether the two are related. In its August 29, 2011, response to RAI14.03.10-1 .i, the applicant stated that the two area are related, and that the response tothis question will be provided in response to NRC RAI 13.03-5 (e-RAI 5681). In itsSeptember 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, statingin part that the 60-minute response time (consistent with NUREG-0654) will replace the90-minute response time (in Table B-I b). The staff verified this change in COLARevision 3, Table B-lb.

The applicant did not, however, address the three exercise ITAAC (identified above) inits response to RAI 13.03-5, in regard to how they relate to the changed staffaugmentation time in Table B-lb 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 tochange "90 minutes" to "60 minutes," or explain why this change is not required. Ifapplicable, compare the ITAAC facility activation times with the existing emergency planfacility activation times in support of Units 3 and 4. The following provides suggestedrevisions, which include additional slight wording changes (see also, the comparableITAAC acceptance criteria from the Vogtle COLA):

8.1.1.C.l.a: "... and by the TSC within 60 minutes of TSC activation."

8.1.1 .D.I: "... and full functional operation of the TSC and EOF within 60 minutes ofactivation."

8.1 .. 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-shiftEmergency Response Organization (ERO) and to activate the emergency responsefacilities (EOF, TSC, and OSC). The augmentation personnel are unable to initiate aresponse to the emergency response facilities until they have received a call-out by theFPL ERO notification system. Upon notification, the on-call ERO personnel respond toand activate the facilities within 60 minutes. This information is included in COLA Part5, Section H.5.

COLA Part 10, Table 3.8-1 will be updated in a future COLA revision to reflect thechange from a 90-minute response time to a 60-minute response time for the activation

Proposed Turkey Point Units 6 and 7Docket Nos. 52-040 and 52-041FPL Response to NRC RAI No. 14.03-1 (eRAI 6290)L-2012-109 Attachment 1 Page 2 of 5

of the EOF, TSC, and OSC for Turkey Point Units 6 & 7 from notification of an Alert orhigher classification event. This update will result in changes to ITAAC acceptancecriteria 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 COLArevision:


Table 3.8-1 (Sheet 11 of 18)Emergency Plan Inspections, Tests, Analyses, and Acceptance Criteria

Planning Standard EP Program Elements Inspections, Tests, Analyses Acceptance Criteria

8.0 Exercises and Drills (cont)

B. Notifications (cont.)

a. Initiate notification of onsiteindividuals (via plant page ortelephone) using designatedchecklist

4. Demonstrate the capability of theAlert and Notification System(ANS) for the public, to operateproperly when required.

Standard Criteria:

a. >94% of the sirens operateproperly as indicated by the sirenfeedback system.

C. Emergency Response1. Demonstrate the capability to direct

and control emergency operations.

Standard Criteria:a. Command and control isdemonstrated in the control roomin the early phase of theemergency and by the TSC within90 60 minutes kam '-e.ntc•aesific.atcn. from notification ofan Alert or higher eventclassification.

2. Demonstrate the ability to transferemergency direction from thecontrol room (simulator) to theTSC.


Table 3.8-1 (Sheet 13 of 18)Emergency Plan Inspections, Tests, Analyses, and Acceptance Criteria

Planning Standard EP Program Elements Inspections, Tests, Analyses Acceptance Criteria

8.0 Exercises and Drills (cont)

D. Emergency Response Facilities1. Demonstrate activation of the

Operations Support Center (OSC)and full functional operation of theTSC and EOF within 90 60minutes Of •-•nt •c!2sifiatio-n.from notification of an Alert orhigher event classification.

Standard Criteria:

a. The TSC, EOF and OSC areactivated within 90 60 minutes oft-he initil rlarkificAtion Of an.A.e.* er. higher-from notificationof an Alert or higher eventclassification.

2. Demonstrate the adequacy ofequipment, security provisions,and habitability precautions for theTSC, OSC, EOF and EmergencyNews Center (ENC), asappropriate.

Standard Criteria:a. Evaluation of the adequacy of the

emergency equipment in theemergency response facilitiesincluding availability and generalconsistency with the EmergencyPlan Implementing Procedures(EPIPs).b. The Security Managerimplements and followsapplicable EPIPs.


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 theapplicant submit an appropriate exemption request that addresses a Tier 1 departurefrom AP1000 DCD Tier 1 Table 3.1-1, to the extent that COLA Part 10 Table 3.8-1ITAAC 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 departureand exemption request is not appropriate because the emergency planning ITAACprovided in COLA Part 10 Table 3.8-1 are not a replacement, but rather a supplement tothe ITAAC in DCD Tier 1 Table 3.1-1. In COLA Part 7 (Departures and ExemptionRequests), 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 addressthe following questions:

a. In COLA Part 7, Section A.1 (Departures That Can Be Implemented WithoutPrior NRC Approval), correct the Description entry for Departure Number PTNDEP 18.8-2 to read "Technical support center location," rather than "Operationssupport center location."

b. Provide an appropriate Tier 1 departure and exemption request that removes theITAAC in DCD Tier 1 Table 3.1-1 from the application. The Table 3.1-1 ITAACare directly related to the Technical Support Center's (TSC) location in theAP1 000 Annex Building (i.e., the control support area). In COLA Part 7Departure Number 18.8-2, the applicant moved the TSC from the control supportarea to the Turkey Point Nuclear Training Building, located outside of theProtected Areas between the control room for Units 3 & 4 and the control roomsfor Units 6 & 7. The removal (departure) of the TSC from the control supportarea necessitates the removal (departure) of the TSC-related ITAAC in Table3.1-1. While the requested Tier 1 departure and exemption request for DCDTable 3.1-1 represents a change in the staffs approach from what was acceptedfor the Vogtle and Summer combined license applications (COLAs) - which hadcomparable DCD TSC relocations (i.e., departures), without a Tier 1 departureand exemption request for DCD Table 3.1-1 - the change is needed for TurkeyPoint Units 6 & 7, in order to more accurately comply with the structure and intentof the 10 CFR Part 52 licensing paradigm. Whenever an applicant (for a COLthat references a certified design) takes a departure from a facility description inthe DCD, the applicant must also depart from the ITAAC for that portion of thefacility design.


FPL RESPONSE:

As described in response to RAI 13.03-17 Subpart a, FPL has revised its position withregards to its response to RAI 14.03.10-1 Subpart f and, therefore, has withdrawn itsAugust 29, 2011 response to Subpart f in RAI 14.03.10-1. Further detail of FPL's newposition on the Tier 1 Table 3.1-1 ITAAC departure and exemption request is providedin Subpart b of this RAI response.

a. Departure Number PTN DEP 18.8-2 addresses the location of the Technical SupportCenter (TSC). The Description entry for Departure Number PTN DEP 18.8-2 will berevised to read "Technical support center location" and moved to Section A.2 as a resultof Subpart b of this RAI response.

b. In Departure Number PTN DEP 18.8-2, FPL states that the TSC is not located in theControl Support Area (CSA) and, as described in the Emergency Plan, the TSC will belocated 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 severalaspects of the TSC Design Description and ITAAC - included in Tier 1 Section 3.1 andTable 3.1-1, respectively - are not directly applicable to Turkey Point Units 6 & 7. FPLwill 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-specificinformation located in COLA Part 2, Section 13.3. The ITAAC in Tier 1 Table 3.1-1 willbe 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 1exemption request.

Additionally, FPL will provide a more detailed description of the TSC habitability featuresin 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 NRCRequest for Additional Information Letter No. 033 (eRAI 5682), Standard ReviewPlan Section 14.03.10 Emergency Planning - Inspection, Tests, Analyses, andAcceptance Criteria.


ASSOCIATED COLA REVISIONS:

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

PTN DEP 18.8-1 The Operations Support Center (OSC) is 1.2.3being moved from the location identified in 9.4.2.2DCD Subsections 18.8.3.6, 12.5.2.2, and 9A12.5.3.2 and as identified on DCD figures in 12.3.1.2SubSections 1.2, 12.3, and Appendix 9A. 12.5.2.2There will be a single OSC for Units 6 & 7 12.5.3.2located as described in FSAR Section 13.3 13.3and the Emergency Plan. 18.8.3.6

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

COLA Part 2, Section 13.3 will be updated in a future COLA revision, with LMAs of PTNDEP 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 TechnicalSupport Center (TSC) and the Operations Support Center (OSC). The TSC isnot located in the control support area as identified in DCD Subsection18.8.3.5. The TSC is common for Turkey Point Units 3, 4, 6, and 7 and islocated on the second floor of the Units 6 & 7 Training Building outside theprotected areas (PA) of all units. The Operations Support Center (OSC) is notlocated 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 theMaintenance Support Building inside the PA. See DCD Section 9.4 for adescription of the HVAC systems for the main control room and seeSubsection 18.8.3.5 for a description of the TSC HVAC and habitabilitysystems. See Section 7.5 for identification of plant variables that are providedfor interface to the emergency planning areas.

Add the following paragraphs after the first paragraph of DCD Section 13.3.This information replaces DCD Tier I Section 3, Non-System Based DesignDescriptions & 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 andtechnical support is provided to main control room (MCR) personnel duringemergency conditions. The operations support center (OSC) provides anassembly area where operations support personnel report in an emergency.The TSC is located outside the protected area (PA), and procedures are inplace to enhance passage through security checkpoints expeditiously. Thereis an OSC located inside the PA in the Maintenance Support Building. TheTSC 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 40persons.

2. The TSC has voice communication equipment for communication with theMCR, emergency operations facility, OSC, and the U.S. Nuclear RegulatoryCommission (NRC).

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

4. The OSC has voice communication equipment for communication with theMCR 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, andassociated acceptance criteria for the Emergency Planning ITAAC. Table 3.8-1Item 3.0, Emergency Communications, provides the emergencycommunications ITAAC. Table 3.8-1 Item 5.1 provides the emergency facilitiesITAAC 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 theEmergency Plan.

Add the following paragraphs after the fifth paragraph of DCD Subsection18.8.3.5:

The TSC structure and ventilation system, a subsystem of the TrainingBuilding structure and ventilation system, is designed to ensure that the TSCpersonnel are protected from radiological hazards. The design of the TSCventilation system is modeled after Figure I 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 arebounding values used for the calculation of TSC dose from a Turkey PointUnits 3 & 4 releases. The boundary of the TSC envelope is designed andconstructed to minimize in-leakage. Unfiltered in-leakage is expected to beless than the assumed value described below. The filtered recirculation flowrate and filter efficiencies are anticipated to be greater than those providedbelow.

During normal operation the system functions as a normal ventilation systemproviding temperature control, filtration, and outside air make-up.

The TSC HVAC system is operated in accordance with emergency planimplementing procedures (EPIP) and is manually controlled in accordancewith the EPIP from the TSC. At the onset of the accident, the TSC is assumedto be in normal ventilation mode with the switch to the emergency modeoccurring manually based on high radiation readings. Portable radiationmonitors are available for personnel to transit from the TSC to other areas.Portable air breathing apparatus and anti-contamination clothing are providedin the TSC.

The TSC HVAC, lighting, and vital information systems are powered by reliableand redundant power supplies. The TSC redundant power includes batteryand diesel backed uninterruptible power supplies.

In the emergency mode of operation, outside air is drawn through highefficiency particulate air (HEPA) filters and an activated charcoal filterassembly before being discharged into TSC spaces. The system provides 99percent removal efficiency for particulates and 90 percent decontaminationefficiency for radioiodine. These efficiencies are consistent with thoseprovided in DCD Table 9.4-1 for the main control room and the control supportarea (CSA). Return air from within the TSC is mixed with the incoming outsideair and recirculated through the filter assembly to minimize airbornecontamination and provide for environmental conditioning. In the emergencymode 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 ofoutside air. This make-up flow of 1000 cfm provides sufficient ventilation(filtered fresh air) for 100 people. The charcoal adsorber and HEPA unit filteran additional 1000 cfm that is recirculated from the TSC. There is also anassumed unfiltered in-leakage of 500 cfm during emergency mode ofoperation. There is also an unfiltered recirculation rate of approximately15,000 cfm.

The HVAC system is designed as a non-seismic system and is not providedwith redundant fans or filters, as permitted by the NUREG-0696recommendations for the TSC. Each TSC entrance is provided with avestibule that functions similar to an airlock to minimize air in-leakage due topersonnel ingress and egress.

When the TSC HVAC is required for the emergency mode of operation, theTraining Building HVAC system is isolated from the TSC HVAC system using


power-operated dampers. In addition, the Training Building ventilation for thefirst and third floors is secured.

The Training Building HVAC system components necessary to support theemergency mode of operation are controlled from inside the TSC. Controlsmay be located within mechanical equipment spaces, but the followingcontrols 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 shownbelow:

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

Departure Number PTN DEP 18.8-2 will be removed from Part 7, Section A.1, page 7-1and 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 DescriptionSTD DEP 1.1-1 Administrative departure for organization and

numbering for the FSARsections and subsections

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

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

limiting featuresPTN DEP 9.3-1 Plant gas system - hydrogen gas portionPTN DEP 18.8-1 Operations support center locationPTN DEP 18.8 2 TeVhniIa!I supprt center Iocation

PTN DEP 19.58-1 Severe winds and tornadoes

A.2 Departures That Require NRC Approval Prior to Implementation

Departure Number DescriptionPTN DEP 2.0-1 Operating basis wind speedPTN DEP 2.0-3 Maximum safety wet bulb (noncoincident) air

temperaturePTN 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 futureCOLA revision, as shown below:

B. Turkey Point Units 6 & 7 Exemption Requests

Exemption DescriptionNumber

B.1 Combined License (COL) Application organization andnumbering

B.2 Maximum safety wet bulb (noncoincident) airtemperature

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

Accounting Program DescriptionB.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 removedfrom Part 7, Section A.1, page 7-2 and added to Part 7, Section A.2, page 7-23 in afuture COLA revision, as shown below:

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

Departure Number DescriptionSTD 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) airtemperature

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

limiting featuresPTN DEP 9.3-1 Plant gas system - hydrogen gas portionPTN DEP 18.8-1 Operations support center locationPT-N DEP 18A.8-2 Operations support c-enterf lon-atiopPTN DEP 19.58-1 Severe winds and tornadoes

A.2 Departures That Require NRC Approval Prior to Implementation

Departure Number DescriptionPTN DEP 2.0-1 Operating basis wind speedPTN 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 DEP18.8-1 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 inPart 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 inDCD Subsections 18.8.3.6, 12.5.2.2, and 12.5.3.2 and as identified on DCD figuresin 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 inPart 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 islocated off the main corridor immediately beyond the main entry to the annexbuilding," and indicates that the OSC location is identified on Figure 1.2-18. ForUnits 6 & 7, the OSC is being moved, as described in FSAR Section 13.3 and theEmergency Plan, and one OSC will serve both Units 6 & 7 to optimize use of spaceand operational resources.

The "AFFECTED DCD/FSAR SECTIONS:" section of Departure Number PTN DEP18.8-2 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 inPart 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 asidentified in DCD Subsection 18.8.3.5. The TSC is common for Turkey Point Units3, 4, 6, and 7 and is located as described in FSAR Section 13.3 and the EmergencyPlan.

The "DEPARTURE JUSTIFICATION:" section of Departure Number PTN DEP 18.8-2 inPart 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 locationas identified in FSAR Section 13.3 and the Emergency Plan, such that a single TSCcan 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 becausethe TSC location is Tier 2 information. However, the change requires adeparture from DCD Tier 1, Section 3, Non-System Based Design Descriptions& ITAAC, Section 3.1, Emergency Response Facilities. Therefore, anexemption is requested in Part B of this COL Application part for NRCapproval of that Tier I departure.


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

B.5) DEPARTURE FROM DCD TIER 1, SECTION 3, NON-SYSTEM BASEDDESIGN DESCRIPTIONS & ITAAC, SECTION 3.1, EMERGENCYRESPONSE FACILITIES

Applicable Regulation(s): 10 CFR Part 52, Appendix D, Section VIII.A.4; DCDTier 1, Section 3, Non-System Based Design Descriptions & ITAAC, Section3.1, 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 managementand 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 personnelreport in an emergency. The control support area (CSA) is an areanearby 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 minimumof 25 persons.

2. The TSC has voice communication equipment for communicationwith 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 inventorytable, in subsection 2.5.4, Data Display and Processing System(DDS), with a "Yes" in the "Display" column, can be retrieved in theTSC.

4. The OSC has voice communication equipment for communicationwith the MCR and 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 acceptancecriteria for the emergency response facilities.

Table 3.1-1 Inspections. Tests. Analvses. and Accentance Criteria

Design Commitment Inspections, Tests, Analyses Acceptance Criteria1. The TSC has floor space of An inspection will be performed The TSC has at least 1875 ft2

at least 75 ft2 per person for a of the TSC floor space. of floor space.minimum of 25 persons.2. The TSC has voice An inspection and test will be Communications equipment iscommunication equipment for performed of the TSC voice installed, and voicecommunication with the MCR, communication equipment. transmission and receptionemergency operations facility, are accomplished.OSC, and the NRC.3. The plant parameters listed An inspection will be performed The plant parameters listed inin Table 2.5.4-1, minimum for retrievability of the plant Table 2.5.4-1, minimuminventory table, in subsection parameters in the TSC. inventory table, in subsection2.5.4, DDS, with a "Yes" in the 2.5.4, DDS, with a "Yes" in the"Display" column, can be "Display" column, can beretrieved in the TSC. retrieved in the TSC.4. The OSC has voice Inspection will be performed of Communications equipment iscommunication equipment for the OSC voice communication installed, and voicecommunication with the MCR equipment. transmission and receptionand TSC. are accomplished.5. The TSC and OSC are in An inspection will be performed The TSC and OSC are indifferent locations, of the location of the TSC and different locations.

OSC.6. The CSA provides a See Tier I Material, Table See Tier I Material, Tablehabitable workspace 2.7.14, items 1, 8a), 8c), 12, 2.7.1-4, items 1, 8a), 8c), 12,environment, and 13, Nuclear Island and 13, Nuclear Island

Nonradioactive Ventilation Nonradioactive VentilationI System. System.

Pursuant to 10 CFR 52, Appendix D, Section VIII.A.4, which incorporates the exemptionstandards from 10 CFR 52.63(b)(1), FPL requests an exemption from these Tier Iprovisions in order to provide a new plant-specific Design Description for EmergencyResponse Facilities in FSAR Section 13.3 and to provide corresponding plant-specificITAAC in COLA Part 10 Section 3.8, "Emergency Response Facilities ITAAC." Together,these two plant-specific provisions replace DCD Tier 1 Section 3.1, "EmergencyResponse Facilities" in its entirety.

Discussion:

The location of the TSC at Turkey Point (PTN) Units 6 & 7 is the subject of DepartureNumber 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 forTurkey Points Units 6 & 7 as well as the existing Turkey Point Units 3 & 4. TheEmergency 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 locatedbetween the Turkey Point Units 3 & 4 control room and the Turkey Point Units 6 & 7MCRs.


The Emergency Response Facilities Design Description and corresponding ITAAC in TierI 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 notdirectly applicable to Turkey Point Units 6 & 7, because the Table 3.1-1 ITAAC are directlyrelated to the TSC location in the CSA. This exemption is necessary in order to ensurethat the Design Description and ITAAC applicable to the TSC are consistent with thedesign of the shared TSC, as identified in Departure Number PTN DEP 18.8-2 and theEmergency Plan.

The relocated TSC meets the guidance of NUREG-0696, Functional Criteria forEmergency Response Facilities, and RG 1.206, Combined License Applications forNuclear Power Plants, regarding structure, habitability, size, communications,instrumentation, data system equipment, power supplies, technical data, recordsavailability, 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 withNUREG-0696 and meet the functional intent of the Design Description in Tier I Section3.1, with minor differences to account for the different locations as identified below.

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

* Design Description Item I is changed from Tier 1, Section 3.1-1, Item I to requirethe TSC to have floor space of 75 ft2 per person for a minimum of 40 people. Thisis due to the increased number of people in the combined TSC, and is consistentwith 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 MonitoringSystem, and FSAR Table 7.5-201, Post-Accident Monitoring System, can beretrieved in the TSC." These tables provide listings of the post-accidentmonitoring parameters that the TSC can use to receive, store, process, anddisplay plant and environmental information. FSAR Table 7.5-201 supplementsDCD Table 7.5-1 and provides the site-specific information to address the notesin the remarks column of DCD Tier 2 Table 7.5-1. DCD Table 7.5.1 and FSARTable 7.5-201 contain the plant parameters required by Section VI.2.a ofAppendix E to 10 CFR Part 50, including plant equipment status and parameterinformation for reactor core and coolant system conditions, reactor containmentconditions, radioactivity release conditions, and plant meteorologicalconditions.

" Design Description Item 6 is changed from Tier 1, Section 3.1-1, Item 6 to replacethe reference to the CSA with a reference to the TSC in order to reflect the factthe 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 sizeof the TSC. Criterion 5.1.1 will confirm the TSC is at least 3,000 square feet, tocorrespond to the Design Description requirement of 75 ft2 per person for aminimum of 40 people.

Acceptance Criteria 3.2 and 5.1.3 apply to Design Description Item 2, regardingvoice communication equipment. Criterion 3.2 will confirm the installation ofcommunications equipment between the NRC and the main control room, TSCand EOF. Criterion 5.1.3 will confirm the installation of communicationsequipment between the main control room, the OSC, and the emergencyoperations facility (EOF).

" Acceptance Criterion 5.1.5 applies to Design Description Item 3, regarding theretrievability of the minimum inventory plant parameters. Criterion 5.1.5 willconfirm that the TSC has the means to receive, store, and display plant andenvironmental 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, regardingcommunication between the OSC, the TSC, and the MCR. Criterion 5.1.8 willconfirm the installation of equipment for communication between the OSC andOSC teams, the TSC, and the main control room.

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

" Acceptance Criterion 5.1.4 applies to Design Description Item 6, regarding CSAworkspace habitability. Criterion 5.1.4 identifies attributes of the TSC ventilationsystem that will provide a habitable workspace, including high-efficiencyparticulate air (HEPA) filter, charcoal filter, and radiation monitors, as well ascontrols and displays within the TSC to control and monitor the TSC ventilationsystem. Criterion 5.1.4 will confirm the installation of the TSC ventilation systemwith these attributes.

Evaluation:

In accordance with 10 CFR Part 52, Appendix D, Section VIII.A.4, this exemption requestis evaluated under, 10 CFR 52.63(b)(1). Section 52.63(b)(1) incorporates the requirementsof 10 CFR 52.7, which incorporates the requirements of 10 CFR 50.12. Section 50.12allows 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 thecommon defense and security, and 4) special circumstances are present as specified in10 CFR 50.12(a)(2). Section 52.63(b)(1) also requires the Commission to considerwhether the special circumstances required to be present outweigh any decrease insafety 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 I exemptionrequest if it determines that the design change will result in a significant decrease in thelevel of safety of the design.


In summary, the NRC regulations require an exemption from Tier I information to showthat: 1) the change will not result in a significant decrease in the level of safety otherwiseprovided by the design; 2) the exemption is authorized by law, will not present an unduerisk to the public health and safety, and is consistent with the common defense andsecurity; 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 thereduction in standardization caused by the exemption. As shown below, each of thesefour criteria are satisfied.

(1) As described above, the exemption will not result in a significant decrease in thelevel of safety otherwise provided by the design. The plant design has been changed byDeparture Number PTN DEP 18.8-2. The DCD includes ITAAC to provide the NRC with amechanism to confirm that the as-built facility meets the requirements of the licenseddesign. Because the Turkey Point Units 6 & 7 licensed design will have a different TSClocation, different ITAAC are necessary in order to meet this regulatory purpose. Thisexemption provides plant-specific emergency planning ITAAC that are consistent withthe modified plant design, by which the NRC can confirm that the as-built TSC has thecapabilities identified in NUREG-0696. This exemption will not result in any decrease inthe level of safety otherwise provided by the design.(2) The exemption is not inconsistent with the Atomic Energy Act or any other statuteand therefore is authorized by law. As discussed above, the exemption does not have anadverse impact on the level of safety provided by the AP1000 Standard Plant design andtherefore will not present an undue risk to the public health and safety. The exemptiondoes 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 I Section 3.1 Design Description and ITAAC parameterswould not serve the underlying purpose of the rules. The Design Description and ITAACwere included in the DCD in order to provide a legally enforceable mechanism to confirmthat the as-built facility matches the licensed design. Where a COL applicant departsfrom the certified design, an ITAAC based on that design would not serve this underlyingpurpose. Instead, new plant-specific ITAAC are appropriate. Consequently, granting achange from the design description and ITAAC in Tier I Section 3.1 of the DCD wouldensure that the ITAAC correspond to the plant-specific licensed design, which is theunderlying purpose of the rule.

(4) The special circumstances outweigh any decrease in safety that may result fromthe reduction in standardization caused by the exemption. As stated above, there is nodecrease in safety associated with this exemption.

Conclusion:

As demonstrated above, this exemption request complies with the requirements inSection VIII.A.4 of the design certification rule for the AP1000 and the regulationsincorporated 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 standarddesign are included in the referenced DCD Tier 1 SubSection 3.1 as inc-rporated by refeFrencabeve. The site-specific emergency planning ITAAC that ,upplement or •ar ou.tside the .copeef completely replace the Westinghouse AP1000 standard design in DCD Tier 1 gubSection3.1 are provided in the attached Table 3.8-1. Include these ITAAC after DCD Tier 1 Section 3.7.

Enclosures:

None

proposed turkey point units 6 and 7 - response to nrc request … · l-2012-109 10 cfr 52.3 march...

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