2015/01/05 Turkey Point COL Hearing - FW: Supplemental ... · 1 PMTurkeyCOLPEm Resource From:...

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PMTurkeyCOLPEm Resource

From: Comar, MannySent: Monday, January 05, 2015 12:28 PMTo: TurkeyCOL ResourceSubject: FW: Supplemental Response Letter L-2013-0303 for eRAI 6434- concerning AP1000 Spent

Fuel Pool Instrumentation EMAIL 3 OF 3Attachments: L-2013-0303_Spent Fuel Pool Level,_Enclosures 1 & 2 & 3 Combined-sized.pdf;

L-2013-0303_Spent Fuel Pool Level,_Proprietary & Non_ Response_Cover Letter.pdf

From: Franzone, Steve [mailto:[email protected]] Sent: Monday, December 15, 2014 9:41 PM To: Comar, Manny Cc: CHILDRESS, ELWOOD Subject: FW: Supplemental Response Letter L-2013-0303 for eRAI 6434- concerning AP1000 Spent Fuel Pool Instrumentation EMAIL 3 OF 3 Manny Here is the supplement to RAI 1.05-3 which addresses some DCD issues and is proprietary. Thanks Steve Franzone NNP Licensing Manager - COLA "Words may show a man's wit, but actions his meaning.” ~ Benjamin Franklin 561.694.3209 (office) 754.204.5996 (cell) “This transmission is intended to be delivered only to the named addressee(s) and may contain information that is confidential and /or legally privileged. If this information is received by anyone other than the named addressee(s), the recipient should immediately notify the sender by E-MAIL and by telephone (561.694.3209) and permanently delete the original and any copy, including printout of the information. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone other than the named addressee(s), except with the express consent of the sender or the named addressee(s).

From: CHILDRESS, ELWOOD Sent: Monday, October 28, 2013 4:02 PM To: 'Alicia Wiliamson ([email protected])'; 'David Matthews ([email protected])'; Maher, William; 'Manny M. Comar ([email protected])'; 'Tim Hoeg ([email protected])'; 'Victor Mccree ([email protected])' Subject: Supplemental Response Letter L-2013-0303 for eRAI 6434- concerning AP1000 Spent Fuel Pool Instrumentation

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 Supplemental Response to NRC Request for Additional Information Letter No. 58 (eRAI 6434) - Concerning Implementation of Fukushima Near-Term Task Force Recommendations

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References:

1. FPL Letter L-2012-268 to NRC dated June 29, 2012, Response to NRC Request for Additional Information Letter No. 58 (eRAI 6434) - Concerning Implementation of Fukushima Near-Term Task Force Recommendations

2. FPL Letter L-2012-236 to NRC dated May 31, 2012, Schedule for Response to NRC Request for Additional Information Letter No. 58 (eRAI 6434) - Concerning Implementation of Fukushima Near-Term Task Force Recommendations

3. NRC Letter to FPL dated May 1, 2012, Request for Additional Information Letter No. 58 - Concerning Implementation of Fukushima Near-Term Task Force Recommendations for the Turkey Point Units 6 and 7 Combined License Application

Florida Power & Light Company (FPL) provided its response in a letter (Reference 1) to the Nuclear Regulatory Commission’s (NRC) request for additional information (RAI) No. 01.05-3 (eRAI 6434) provided in Reference 3. FPL provided the schedule (Reference 2) for providing the response to NRC RAI Letter No. 58.

FPL provides, as Enclosure 2 to this letter, its supplemental response to RAI 01.05-3. The Enclosure identifies changes that will be made in a future revision of the Turkey Point Units 6 and 7 Combined License Application (if applicable).

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Included in this supplemental response is a report that provides a description of how compliance with the requirements of the proposed license condition for Reliable Spent Fuel Pool Level Instrumentation described in Enclosure 2 will be achieved. This report was developed in conjunction with Westinghouse Electric Company, LLC (Westinghouse) for the AP1000. Enclosure 4 (proprietary) is the Westinghouse report, APP-SFS-M3R-003, Response to NRC Orders EA-12-051 and EA-12-063, and Background Information for Future Licensees on AP1000 Spent Fuel Pool Instrumentation, Rev A. Enclosure 3 contains the redacted version of Enclosure 4, Westinghouse report, APP-SFS-M3R-004, Response to NRC Orders EA-12-051 and EA-12-063, and Background Information for Future Licensees on AP1000 Spent Fuel Pool Instrumentation, Rev A , Redacted. This is a redacted version and is therefore non-proprietary. Except for utility specific correspondence and COLA specific License Condition numbering changes, this response follows the technical content, including future COLA changes, submitted for the AP1000 lead plant - Levy Nuclear Plant, Units 1 and 2, Docket Numbers 52-029 and 52-030 in letters: Letter from Christopher Fallon (PEF) to Nuclear Regulatory Commission (NRC), dated September 25, 2013, Supplement 8 to Response to NRC RAI Letter 108 - Implementation of Fukushima Near-Term Task Force Recommendations. Serial: NPD-NRC-2013-041 . Letter from Christopher Fallon (PEF) to Nuclear Regulatory Commission (NRC), dated May 13, 2013, Supplement 7 to Response to NRC RAI Letter 108 - Implementation of Fukushima Near-Term Task Force Recommendations. Serial: NPD-NRC-2013-022. Letter from Christopher Fallon (PEF) to Nuclear Regulatory Commission (NRC), dated April 5, 2013, Supplement 6 to Response to NRC RAI Letter 108 - Implementation of Fukushima Near-Term Task Force Recommendations. Serial: NPD-NRC-2013-008. Enclosure 4 contains Westinghouse Proprietary Class 2 information. The Westinghouse proprietary information for which withholding is being requested is further identified in the affidavit signed by Westinghouse Electric Company, LLC (Enclosure 1). The Westinghouse affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3537 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse

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Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066. Based on Enclosure 1 to this letter, FPL requests that Enclosure 4 be withheld from public disclosure under 10 CFR 2.390(a)(4). W/O Enclosure 4

Hearing Identifier: TurkeyPoint_COL_Public Email Number: 956 Mail Envelope Properties (377CB97DD54F0F4FAAC7E9FD88BCA6D001E3FD795344) Subject: FW: Supplemental Response Letter L-2013-0303 for eRAI 6434- concerning AP1000 Spent Fuel Pool Instrumentation EMAIL 3 OF 3 Sent Date: 1/5/2015 12:27:52 PM Received Date: 1/5/2015 12:27:54 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 6434 1/5/2015 12:27:54 PM L-2013-0303_Spent Fuel Pool Level,_Enclosures 1 & 2 & 3 Combined-sized.pdf 358800 L-2013-0303_Spent Fuel Pool Level,_Proprietary & Non_ Response_Cover Letter.pdf 194608 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Enclosure 1

Westinghouse Application for Withholding

Proprietary Information from Public Disclosure

CAW-12-3537(7 Total Pages)

Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-12-3537, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice pursuant to 10 CFR 2.390(a)(4)

Enclosure 4 of this letter, AP1000 APP-SFS-M3R-003 Rev A, Response to NRC Orders EA-12-051 and EA-12-063, and Background Information for Future Licensees on AP1000 Spent Fuel Pool Instrumentation" contains Westinghouse Proprietary Class 2 information.

As Enclosure 4 of this letter contains proprietary information to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The Westinghouse affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and address with specificity the considerations listed in 10 CFR 2.390(b)(4).

Accordingly, it is respectfully requested that the information which is proprietary be withheld from public disclosure in accordance 10 CFR 2.390.

Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3537 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

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Proposed Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2013-303 Enclosure 2 Page 1 of 10

Enclosure 2

FPL Supplemental Response to NRC RAI 01.05-3

(eRAI 6434)

Contains Westinghouse Non-Proprietary Class 3 Information

(10 Total Pages)


NRC RAI Letter No. PTN-RAI-LTR-058 Dated May 1, 2012 SRP Section: 01.05 – Other Regulatory Considerations Question from Licensing Branch 4 NRC RAI Number: Supplement to 01.05-3 (eRAI 6434)Provide sufficient reliable instrumentation, able to withstand design-basis natural phenomena, to monitor spent fuel pool water level, as described in Attachment 3 to Order EA-12-051 (ML12054A679).

FPL RESPONSE:This response supplements information previously submitted in FPL letter L-2012-268 to the NRC, dated June 29, 2012, “Response to NRC Request for Additional Information Letter No. 58 (eRAI 6434) - Concerning Implementation of Fukushima Near-Term Task Force Recommendations.” This response provides additional FPL COLA future revisions to FPL FSAR Table 1.8-201 and to FPL COLA Part 7 related to the FPL departure from DCD Table 3.11-1 (Sheet 14 of 51), and FPL COLA Part 10. This response also provides left-hand margin annotations designations for the FPL departure from DCD Table 3.11-1 (Sheet 14 of 51) in FPL FSAR Section 3.11 and text being added to FPL FSAR Section 9.1.3.7.D.

FPL proposed license condition 12.B developed in response to RAI 01.05-3 (eRAI 6434) is being modified to delete item 12.B.1 of the license condition. In addition, the text in the license condition associated with developing the overall integrated plan (item 12.B.3) and providing status reports to the NRC (item 12.B.4) are being deleted. These items are being deleted based on requirements in item 12.B of the license condition being described in the AP1000 DCD and in information being added to Section 9.1.3.7.D in the FPL FSAR by this response. Appendix A-4 for AP1000 plants in NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, “To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,” Revision 1, provides guidance on spent fuel pool (SFP) instrumentation requirements. The NRC staff considers NEI 12-02 Appendix A-4 an acceptable means to meet the requirements of Order EA-12-051 per JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0. Items 12.B.1 through 12.B.4 in the current FPL proposed license condition 12.B is based on the requirements contained in the orders received by AP1000 licensees.

In addition to the changes described above, this response also includes an FPL departure to correct an inconsistency in the AP1000 DCD. To avoid conflict between the instrument location information being added to Chapter 9 of the FPL FSAR by this supplemental response and information contained in DCD Revision 19, Table 3.11-1, an FPL departure is being added to the FPL COLA. This departure is needed to revise the environmental zones for each spent fuel pool level instrument to align with the actual location of the instruments as described in the Westinghouse report APP-SFS-M3R-003, Proprietary, Revision A, and Westinghouse AP1000 design information.

A description of how the AP1000 design as described in the DCD and FPL FSAR (text to be added per this response) meets the design features in item 12.B.1 of the current proposed license condition and the requirements of NEI 12-02 Appendix A-4 guidance is provided below.


Arrangement:

The AP1000 design has three safety-related SFP level instrument channels as stated in Westinghouse AP1000 DCD Revision 19, Table 7.5-1 (Sheet 7 of 12). All three channels and associated instrument tubing lines are located below the fuel handling area operating deck and the cask washdown pit as stated in the additional text being added to the FPL FSAR. This location provides level indication function protection from missiles that may result from damage to the structure over the spent fuel pool. In addition, the SFP level instruments associated with PMS divisions A and C are physically separated from the SFP instrument associated with PMS division B as stated in the text being added to the FPL FSAR Section 9.1.3.7.D.

Qualification:

The three safety-related SFP level instruments are seismically qualified as stated in Westinghouse AP1000 DCD Revision 19, Table 7.5-1 (Sheet 7 of 12). The SFP level instruments are located below the fuel handling area operating deck as described in the “Arrangement” section above. As stated in Westinghouse AP1000 DCD Revision 19, Section 9.1.3.4.3.4 and Table 7.5-1 (Sheet 7 of 12), the environment in these areas during SFP steaming is mild with respect to safety-related equipment qualification and affords access for post-accident actions. Even though they are not directly exposed to SFP boiling, the instruments are qualified to function at the conditions (temperature, humidity, radiation) that could be seen at the lower elevations in the spent fuel building where these instruments are located. This provides assurance that the SFP level transmitters exposed to these environmental conditions will remain available and functional for an extended period.

Power Sources:

The AP1000 design provides extended SFP level monitoring capability with two trains of dedicated class 1E DC power supply for at least 72 hours of post-accident monitoring.One of these safety-related instruments is powered through PMS Division B, and the other is powered through PMS Division C. A third safety-related instrument is powered through PMS Division A which contains a 24-hour battery supply. The safety-related SFP level instrument PMS divisions are described in the text being added to the FPL FSAR Section 9.1.3.7.D. A description of the AP1000 class 1E DC and UPS system is contained in AP1000 DCD Revision 19, Section 8.3.2.1.1.

Beyond the initial 72 hours, instrument power can be supplied by the use of onsite permanently installed ancillary diesel generators or offsite portable generators with quick and accessible connection points. Permanently installed onsite ancillary diesel generators are capable of providing power for Class 1E post-accident monitoring including SFP level instrumentation. This capability is described in Westinghouse AP1000 DCD Revision 19, Section 8.3.1.1.1. Each ancillary diesel generator output is connected to a distribution panel in the same room as the ancillary diesel generators. The distribution panel contains outgoing feeder circuit breakers directly connected to the PMS Division B and PMS Division C voltage regulating transformers that power the


post-accident monitoring loads, the lighting in the MCR, and the ventilation in the MCR and PMS Division B and C I&C rooms. This configuration is depicted in Westinghouse AP1000 DCD Revision 19, Figures 8.3.1-3 and 8.3.2-2.

The AP1000 design does not require that the ancillary diesel generators be safety related. Their operation is not required following a loss of all AC power for 72 hours because they are easily replaced with offsite portable generators, which are capable of being connected to the distribution panel in the same room or to a safety-related connection as described in Westinghouse AP1000 DCD Revision 19, Section 1.9.5.4. This section of the Westinghouse AP1000 DCD describes the post-72 hour support actions.

Accuracy:

The measured range of SFP level by the safety-related instruments is from the top of the SFP to the top of the fuel racks as described in the text to be added to the FPL FSAR. These instruments are calibrated at a reference temperature suitable for normal SFP operation as described in the text to be added to the FPL FSAR and thus will read conservatively at elevated temperatures including during boiling conditions. These instruments are calibrated on a regular basis and their accuracy is not affected by power interruptions as described in the text to be added to the FPL FSAR.

Display:

Three safety-related SFP level sensors provide continuous indication of the SFP level to the MCR as well as the Remote Shutdown Workstation (RSW) and are included in the Qualified Data Processing System (QDPS) PMS display as indicated in Westinghouse AP1000 DCD Revision 19, Table 7.5-1 (Sheet 7 of 12). The redundant sensors are capable of measuring the SFP level from the top of the spent fuel racks up to the operating deck as described in the “Accuracy” section above.

Safety-related instrumentation gives an alarm in the main control room when the water level in the SFP reaches the low-low-level setpoint as stated in AP1000 DCD Revision 19, Section 9.1.3.7.D.

As described in the “Power Sources” section above, two of the level instruments are powered by 2 trains of the class 1E batteries for the first 72 hours. After 72 hours, the permanently installed ancillary diesel generators will be used if available or offsite portable generators can be used to power two of the PMS divisions, and thus two of the SFP level transmitters as well as the indication.

A future revision of the FPL COLA will reflect the changes discussed above, as shown in the Associated COLA Revisions below.

This response is PLANT SPECIFIC.


References:1. NRC Letter EA-12-051, dated March 12, 2012, Issuance of Order to Modify Licenses with

Regard to Reliable Spent Fuel Pool Instrumentation, Attachment 3 [ML12054A679]. 2. NRC SECY-12-0025 dated February 17, 2012, Enclosure 6: Order Modifying Licenses:

Reliable Spent Fuel Pool Level Instrumentation at Operating Reactor Sites [ML12039A148].

3. FPL letter L-2012-268 to the NRC, dated June 29, 2012, "Response to NRC Request for Additional Information Letter No. 58 (eRAI 6434) Concerning Implementation of Fukushima Near-Term Task Force Recommendations." [ML121850685]

4. NEI 12-02, Appendix A-4, Industry Guidance for Compliance with NRC Order EA-12-051, “To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,” Revision 1. [ML12240A307]

5. JLD-ISG-2012-03, “Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation,” Revision 0. [ML12221A339]

6. Westinghouse report APP-SFS-M3R-003, Proprietary, “Response to NRC Orders EA-12-051 and EA-12-063, and Background Information for Future Licensees on AP1000 Spent Fuel Pool Instrumentation,” Revision A.

ASSOCIATED COLA REVISIONS:

A new departure, PTN DEP 3.11-1, will be added to FSAR Table 1.8-201 in a future COLA revision.

Table 1.8-201 (Sheet 2 of 2) Summary of FSAR Departures from the DCD

DepartureNumber Departure Description Summary

FSAR Section or Subsection

PTN DEP 3.11-1 DCD Table 3.11-1 (Sheet 14 of 51) "Envir. Zone" numbers for Spent Fuel Pool Level instruments SFS-JE-LT019A, SFS-JE-LT019B, and SFS-JE-LT019C are revised to be consistent with the location of the instruments

3.11


FSAR Section 3.11 will be revised to add FSAR Table 3.11-1R (with LMA PTN DEP 3.11-1) to replace DCD Table 3.11-1 (Sheet 14 of 51) in a future COLA revision.

Table 3.11-1R

ENVIRONMENTALLY QUALIFIED ELECTRICAL AND MECHANICAL EQUIPMENT

Description AP1000 Tag No.

Envir. Zone

(Note 2) Function (Note 1)

Operating Time

Required (Note 5)

Qualification Program (Note 6)

SG1 Wide Range Level SGS-JE-LT011 1 ESF PAMS

5 min 2 wks

E *


5 min 2 wks

E *


5 min 2 wks

E *


5 min 2 wks

E *


5 min 2 wks

E *


5 min 2 wks

E *


5 min 2 wks

E *


5 min 2 wks

E *

Spent Fuel Pool Level SFS-JE-LT019A 11 6 PAMS 2 wks E **

Spent Fuel Pool Level SFS-JE-LT019B 11 7 PAMS 2 wks E **

Spent Fuel Pool Level SFS-JE-LT019C 11 6 PAMS 2 wks E **

Air Storage Tank Pressure – A VES-JE-PT001A 7 PAMS 2 wks E +

Air Storage Tank Pressure – B VES-JE-PT001B 7 PAMS 2 wks E +

Containment Pressure Normal Range

PCS-JE-PT005 7 ESF PAMS

5 min 4 mos

E *



5 min 4 mos

E *



5 min 4 mos

E *



5 min 4 mos

E *


PCS-JE-PT012 7 PAMS 4 mos E *






The following new FSAR Subsection 9.1.3.7 will be added in a future COLA revision.

9.1.3.7 Instrumentation Requirements

Add the following paragraph after the first paragraph of DCD Subsection 9.1.3.7.D.

All three safety-related spent fuel pool level instruments and associated instrument tubing lines are located below the fuel handling area operating deck and the cask washdown pit. This location provides protection from missiles that may result from damage to the structure over the spent fuel pool. The SFP level instruments associated with PMS divisions A and C are physically separated from the SFP level instrument associated with PMS division B. The safety- related spent fuel pool level instruments measure the water level from the top of the spent fuel pool to the top of the fuel racks. These instruments are conservatively calibrated at a reference temperature suitable for normal spent fuel pool operation on a regular basis and accuracy is not affected by power interruptions.

The following changes will be made to COLA Part 7 (pages 7-1 and 7-2), to add the new departure PTN DEP 3.11-1, in a future COLA revision.

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

PTN DEP 3.11-1 Revision of "Envir. Zone" numbers for Spent Fuel Pool Level instruments

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


New departure PTN DEP 3.11-1 will be added to COLA part 7 in a future COLA revision. Departure Number PTN DEP 3.11-1AFFECTED DCD/FSAR SECTIONS: DCD Table 3.11-1 (Sheet 14 of 51) SUMMARY OF DEPARTURE: DCD Table 3.11-1 (Sheet 14 of 51) "Envir. Zone" numbers for Spent Fuel Pool Level instruments SFS-JE-LT019A, SFS-JE-LT019B, and SFS-JE-LT019C are changed to correct an inconsistency in the DCD. All 3 instruments currently have a Environmental Zone number of "11". SFS-JE-LT019A is changed to Envir. Zone 6, SFS-JE-LT019B is changed to Envir. Zone 7 and SFS-JE-LT019C is changed to Envir. Zone 6 in DCD Table 3.11-1 (Sheet 14 of 51). SCOPE/EXTENT OF DEPARTURE: SFS-JE-LT019A is revised to Envir. Zone 6, SFS-JE-LT019B is revised to Envir. Zone 7 and SFS-JE-LT019C is revised to Envir. Zone 6 in DCD Table 3.11-1 (Sheet 14 of 51). DEPARTURE JUSTIFICATION: The actual location of the Spent Fuel Pool Level instruments is not being changed from the designed location in this departure. The environmental zones the instruments are located in are being revised to be consistent with the designed instrument location. The AP1000 SFP level transmitters are located in rooms outside of the Fuel Handling Area in the Auxiliary Building. Per Westinghouse design documents, Spent Fuel Pool Level channels 019A and 019C are in room 12365 and channel 019B is in room 12341. Room 12365 is in Zone 6 on DCD Table 3.D.5-1 (Sheet 2 of 3). Room 12341 is in Zone 7 on DCD Table 3.D.5-1 (Sheet 2 of 3). Based on this information, SFS-JE-LT019A is being changed to Envir. Zone 6, SFS-JE-LT019B is being changed to Envir. Zone 7 and SFS-JE-LT019C is being changed to Envir. Zone 6 in DCD Table3.11-1 (Sheet 14 of 51). DCD Table 3.11-1 Environmental Zone numbers for Spent Fuel Pool Level provide a reference to enviromental conditions in the associated instrument location correlated to an environmental zone in DCD Table 3D.5-1 for "Normal Operating Environments", DCD Table 3D.5-4 for "Abnormal Operating Environments Outside Containment" and DCD Table 3D.5-5 for "Accident Environments". The environmental qualification of the instrument is consistent with conditions identified for the associated environmental zone. Revising the Spent Fuel Pool Level instruments' environmental zone to accurately reflect their actual location will ensure they are enviromentally qualified to function properly during normal, abnormal, and accident conditions.


DEPARTURE EVALUATION: This Tier 2 departure revises SFS-JE-LT019A Envir. Zone from 11 to 6, SFS-JE-LT019B Envir. Zone from 11 to 7, and SFS-JE-LT019C Envir. Zone from 11 to 6 in DCD Table 3.11-1 (Sheet 14 of 51). This departure does not result in any adverse affects to the SFP level indication design function and does not change the environmental qualification methodology. Therefore, this departure does not: 1. Result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the plant-specific DCD. 2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety and previously evaluated in the plant specific DCD.3. Result in more than a minimal increase in the consequences of an accident previously evaluated in the plant-specific DCD. 4. Result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the plant-specific DCD. 5. Create a possibility for an accident of a different type than any evaluated previously in the plant-specific DCD. 6. Create a possibility for a malfunction of an SSC important to safety with a different result than any evaluated previously in the plant-specific DCD. 7. Result in a design basis limit for a fission product barrier as described in the plant specific DCD being exceeded or altered. 8. Result in a departure from a method of evaluation described in the plant-specific DCD used in establishing the design bases or in the safety analyses. This departure does not affect resolution of a severe accident issue identified in the plant specific DCD. Therefore, this departure has no safety significance. NRC APPROVAL REQUIREMENT: This departure does not require NRC approval pursuant to 10 CFR Part 52, Appendix D, Section VIII.B.5.


COLA Part 10, License Condition 12.B. will be revised in a future COLA revision as follows. B. RELIABLE SPENT FUEL POOL LEVEL INSTRUMENTATION Prior to initial fuel load, the licensee shall fully implement the following requirements for spent fuel pool (SFP) level indication: 1. The SFP level instrumentation shall include the following design features:

� Arrangement: The SFP level instrument channels shall be arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP. This protection may be provided by locating the safety-related instruments to maintain instrument channel separation within the SFP area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the SFP structure.

� Qualification: The level instrument channels shall be reliable at temperature, humidity, and radiation levels consistent with the SFP water at saturation conditions for an extended period.

� Power supplies: Power for instrumentation channels shall be supplied from sources independent of the plant alternating current (ac) and direct current (dc) power distribution systems, such as portable generators or replaceable batteries. Power supply designs should provide for quick and accessible connection of sources independent of the plant ac and dc power distribution systems. Onsite generators used as an alternate power source andreplaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.

� Accuracy: The instrumentation shall maintain its designed accuracy following a power interruption or change in power source without recalibration.

� Display: The display shall provide on-demand or continuous indication of SFP water level.

2. The SFP instrumentation shall be maintained available and reliable through appropriate development and implementation of a training program. Personnel shall be trained in the use and the provision of alternate power to the safety-related level instrument channels.

3. The licensee shall within one (1) year after issuance of the COL, submit to the NRC an overall integrated plan, including a description of how compliance with the requirements described in this license condition will be achieved.

4. The licensee shall provide to the NRC an initial status report sixty (60) days following issuance ofthe COL and updates at six (6) month intervals following submittal of the overall integrated plan described above which delineates progress made in implementing the requirements of this license condition.

� The spent fuel pool instrumentation shall be maintained available and reliable through the development and implementation of a training program. The training program shall include provisions to ensure trained personnel can route the temporary power lines from the alternate power source to the appropriate connection points and connect the alternate power source to the safety-related level instrument channels

ASSOCIATED ENCLOSURES: None

Enclosure 3

AP1000

Response to NRC Orders EA-12-051 and EA-12-063, and Background Information for Future Licensees on AP1000

Spent Fuel Pool Instrumentation

APP-SFS-M3R-004, Rev A

Contains Westinghouse Non-Proprietary Class 3 Information

(20 Total Pages)

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APP-SFS-M3R-004 WESTINGHOUSE NON-PROPRIETARY CLASS 3 AP1000

APP-SFS-M3R-004, Revision A i

REVISION HISTORY

RECORD OF CHANGES

Revision Author Description

A See cover page Initial issue.

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APP-SFS-M3R-004, Revision A ii

TABLE OF CONTENTS

LIST OF FIGURES ..................................................................................................................................... iii�

ACRONYMS AND TRADEMARKS ......................................................................................................... iv�

REFERENCES ............................................................................................................................................. v�

1� BACKGROUND .......................................................................................................................... 1-1�2� INTRODUCTION ........................................................................................................................ 2-1�3� REQUIREMENTS ........................................................................................................................ 3-1�

3.1� ARRANGEMENT ........................................................................................................... 3-1�3.2� QUALIFICATION ........................................................................................................... 3-3�3.3� POWER SUPPLIES ........................................................................................................ 3-4�3.4� ACCURACY ................................................................................................................... 3-9�3.5� DISPLAY ....................................................................................................................... 3-10�3.6� PROGRAMMATIC CONTROLS ................................................................................. 3-10�

4� CONCLUSIONS .......................................................................................................................... 4-1�

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APP-SFS-M3R-004, Revision A iii

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TABLE OF FIGURES

Figure 1: � Location of SFP Instrumentation for PMS Divisions A and C and Connections to the SFP For PMS Divisions A, B, and C ....................................................................................... 3-2�

Figure 2: � [ a ]a,c ...................................................................................................................... 3-7

Figure 3 [A a ]a,c ...................................................................................................................... 3-8�

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APP-SFS-M3R-004, Revision A iv

ACRONYMS AND TRADEMARKS

Acronyms Definition

AC alternating current COL combined operating license DC direct current DCD Design Control Document DG diesel generator FLEX diverse and flexible coping strategies FSAR Final Safety Analysis Report I&C instrumentation and control MCR main control room NRC Nuclear Regulatory Commission PCS passive containment cooling system PCCWST passive containment cooling water storage tank PMS protection and safety monitoring system RSW remote shutdown workstation QDPS qualified data processing system SBO station blackout SFP spent fuel pool SSE safe shutdown earthquake

AP1000® is a trademark or registered trademark in the United States of Westinghouse Electric Company LLC, its subsidiaries and/or its affiliates. This mark may also be used and/or registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademarks of their respective owners.

All other product and corporate names used in this document may be trademarks or registered trademarks of other companies, and are used only for explanation and to the owners’ benefit, without intent to infringe.

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APP-SFS-M3R-004, Revision A v

REFERENCES

1. Order EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, United States Nuclear Regulatory Commission, March 12, 2012.

2. Order EA-12-063, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, United States Nuclear Regulatory Commission, March 30, 2012.

3. NEI 12-02, Rev. 0, Industry Guidance for Compliance with NRC Order EA-12-051, Nuclear Energy Institute, August 2012.

4. Westinghouse document AP1000 Design Control Document, Revision 19, June 11, 2011.

5. Order EA-12-049, Issuance of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, United States Nuclear Regulatory Commission, March 12, 2012.

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APP-SFS-M3R-004, Revision A 1-1

RESPONSE TO NRC ORDERS EA-12-051 AND EA-12-063, AND BACKGROUND INFORMATION FOR FUTURE LICENSEES ON AP1000

SPENT FUEL POOL INSTRUMENTATION

1 BACKGROUND

In studying the sequence of events that took place at Fukushima Daiichi during the accident that occurred due to the March 11, 2011 earthquake and resulting tsunami, the U.S. Nuclear Regulatory Commission (NRC) determined that several near-term actions were needed at U.S. commercial nuclear power plants. Among them was to provide spent fuel pools (SFP) with reliable level instrumentation to significantly enhance the knowledge of key decision makers such that resources are allocated effectively in the event of a very low probability beyond design basis event. Consequently, the NRC issued Order EA-12-051 (Reference 1), Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (ML12054A679), on March 12, 2012, for all U.S. nuclear plants with an operating license, construction permit or Combined Construction and Operating License (COL). Order EA-12-063 (Reference 2), Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (ML12089A163) was issued on March 30, 2012 and applies to VC Summer.

Subsequent to the issuance of NRC Orders EA-12-051 and EA-12-063, Nuclear Energy Institute (NEI) developed NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051 (Reference 3). Appendix A-4 of NEI 12-02 provides NRC endorsed Order response guidance for the AP1000 design, to which this report is fully compliant.

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2 INTRODUCTION

The referenced NRC Orders noted that the NRC is now requiring 10 CFR Part 50 licensees to provide reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel:

1) Level that is adequate to support operation of the normal fuel pool cooling system, 2) Level that is adequate to provide substantial radiation shielding for a person standing on the spent

fuel pool operating deck, and 3) Level where fuel remains covered and actions to implement make-up water addition should no

longer be deferred.

The NRC Order further noted that the AP1000 plant described in Westinghouse AP1000 Design Control Document (DCD) Revision 19 (Reference 4), addresses many of these attributes of spent fuel pool level instrumentation. The NRC staff reviewed these design features prior to issuance of the combined licenses for these facilities and certification of the AP1000 design referenced therein. The AP1000 certified design largely addresses the above requirements by providing three safety-related spent fuel pool level instrument channels. The instruments measure the water level from the top of the spent fuel pool to the top of the fuel racks to address the range requirements listed above. The AP1000 safety-related spent fuel pool instrumentation provides for the following design features:

� Continuous measurement range from the normal pool level down to just above the top of the fuel � Accurate measurement with boiling water in the pool � Seismic and environmental qualification of the channels (power supplies, sensors, and displays) � Protection from physical hazards, including internal and external floods� Three independent, safety-related battery power supplies, two rated for 72 hours and one for 24

hours with connections provided for an offsite diesel generator (DG) to continue the power supply after 72 hours

� Electrical isolation and physical separation between instrument channels � Display in the control room as part of the post-accident monitoring instrumentation � [ ]a,c

� Available in all modes � Provisions to perform required routine calibration and testing

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3 REQUIREMENTS

The AP1000 plant must address the following requirements that were not specified in the certified design.

3.1 ARRANGEMENT

Order Requirement

The spent fuel pool level instrument channels shall be arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the spent fuel pool. This protection may be provided by locating the safety-related instruments to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure.

NEI 12-02 AP1000 Guidance

Protection against missiles should be described, noting the protection that may be provided by location of the safety-related instruments and their associated connections below the operating deck. Describe the arrangement and basis for why the operating deck provides protection of the level indication function against missiles that may result from damage to the structure over the spent fuel pool. Alternatively, provide description of the features for additional protection that may be provided by the location of the safety-related instruments to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure.

AP1000 Design Response

The AP1000 design has three safety-related spent fuel pool level instrument channels. All three channels and associated instrument tubing lines are located below the fuel handling area operating deck and the cask washdown pit. The operating deck is at Elevation 135’-3” and the cask washdown pit floor is at Elevation 117’-6”. Level instruments associated with protection and safety monitoring system (PMS) divisions A and C are located in Room 12365, which can be seen on Westinghouse AP1000 DCD Revision 19, Figure 1.2-7 and as referenced in the FSAR of each COL holder or applicant. The level instrument associated with PMS division B is located in the middle annulus (Room 12341, as seen on Westinghouse AP1000 DCD Revision 19 Figure 1.2-7 and as referenced in the FSAR of each COL holder or applicant). The SFP connection and tubing for level instruments associated with PMS divisions A and C is physically separated from the SFP connection and tubing for the level instrument associated with PMS division B within Room 12365.

The cask washdown pit is normally covered by a removable hatch located on the operating deck. The floor of the cask washdown pit is a two-foot thick steel-concrete composite structure. Location of these instrument channels below the operating deck and cask washdown pit provides protection for the level indication function against missiles that may result from damage to the structure over the spent fuel pool. See Figure 1.

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SRIRedacted Version, Withheld Under 10 CFR 2.390

Figure 1: Location of SFP Instrumentation for PMS Divisions A and C and Connections to the SFP For PMS Divisions A, B, and C

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3.2 QUALIFICATION

Order Requirement

The level instrument channels shall be reliable at temperature, humidity, and radiation levels consistent with the spent fuel pool water at saturation conditions for an extended period.


Provide a description of the instrumentation sensors and their capability to operate in the environmental conditions that they will experience during design basis events, noting that for the AP1000 design basis conditions include a SBO with steaming in the SFP. The environmental conditions to be addressed should include appropriate consideration for temperature, humidity, steaming, radiation, and seismic activity (SSE) levels where the sensors are located. Provide information to demonstrate the reliability of the instrument under these conditions.

Appropriate evaluations should also be provided to demonstrate the operability of these sensors for indefinite SBO durations.


The three safety-related, seismically qualified spent fuel pool level instruments are located in rooms below the fuel handling area operating deck as described in Section 3.1. As stated in Westinghouse AP1000 DCD Revision 19, Section 9.1.3.4.3.4 and PAMS Table 7.5-1 (Sheet 7 of 12) and as referenced in the FSAR of each COL holder or applicant, the environment in these areas during spent fuel pool steaming is mild with respect to safety-related equipment qualification and affords access for post-accident actions. This is because the fuel handling area, rail car bay, and spent resin area do not have connecting ductwork with other radioactively controlled areas of the auxiliary building, which prevents steam migration into the areas housing the SFP instruments. In addition, there is a vent path between the fuel handling area and outside environment to vent steam generated by elevated spent fuel pool water temperature. Even though they are not directly exposed to spent fuel pool boiling, the instruments are qualified to function at the conditions (temperature, humidity, radiation) that could be seen at the lower elevations in the spent fuel building where these instruments are located. For example, they are qualified for 100 percent humidity. This provides assurance that the SFP level transmitters exposed to these environmental conditions will remain available and functional for an extended period, as specified in the Order.

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3.3 POWER SUPPLIES

Order Requirement

Instrumentation channels shall provide for power connections from sources independent of the plant alternating current (AC) and direct current (DC) power distribution systems, such as portable generators or replaceable batteries. Power supply designs should provide for quick and accessible connection of sources independent of the plant ac and dc power distribution systems. Onsite generators used as an alternate power source and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.


Provide a description of the design features provided to ensure continuous power supply to the instrumentation for extended loss of power conditions. The AP1000 design provides extended SFP monitoring capability with two trains of dedicated class 1E DC power supply for at least 72 hours of post accident monitoring. Beyond the initial 72 hours, the response shall detail how the instrument power supply can be met by the use of offsite portable generators with quick and accessible connection points and sufficient capacity to maintain level indication indefinitely. The capability to use both onsite and offsite equipment should be discussed as well as the availability of clear guidance for the operator as part of the AP1000 post-72 hours procedures per AP1000 DCD Section 1.9.5.4.


The AP1000 design provides extended SFP level monitoring capability with two trains of dedicated class 1E DC power supply for at least 72 hours of post-accident monitoring. One of these safety-related instruments is powered through PMS Division B, and the other is powered through PMS Division C. A third safety-related instrument is powered through PMS Division A; however, PMS Division A contains only a 24-hour battery supply.

As stated in NRC Order EA-12-051 and Order EA-12-063, the safety-related classification of the SFP instrumentation provides for the following design features:

� Seismic and environmental qualification of the instruments � Independent power supplies � Electrical isolation and physical separation between instrument channels � Display in the control room as part of the post-accident monitoring instrumentation � Required routine calibration and testing

Beyond the initial 72 hours, instrument power can be supplied by the use of onsite permanently installed ancillary diesel generators or offsite portable generators with quick and accessible connection points. Permanently installed onsite ancillary diesel generators located in the annex building are capable of providing power for Class 1E post-accident monitoring (including SFP level instrumentation), MCR lighting, MCR and I&C room ventilation, and power to refill the passive containment cooling water storage tank (PCCWST) using the PCS recirculation pumps. This capability is described in Westinghouse AP1000 DCD Revision 19, Section 8.3.1.1.1 and as referenced in the FSAR of each COL

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Redacted Version, Withheld Under 10 CFR 2.390d

holder or applicant. Each ancillary diesel generator output is connected to a distribution panel in the same room as the ancillary diesel generators. The distribution panel contains outgoing feeder circuit breakers directly connected to the PMS Division B and PMS Division C voltage regulating transformers that power the post-accident monitoring loads, the lighting in the MCR, and the ventilation in the MCR and PMS Division B and C I&C rooms. This configuration is depicted in Westinghouse AP1000 DCD Revision 19, Figures 8.3.1-3 and 8.3.2-2 (Reference 4) and as referenced in the FSAR of each COL holder or applicant. The post-72 hour procedures discussed in Section 3.6 of this report include provisions to start and connect the ancillary diesel generators.

The AP1000 design does not require that the ancillary diesel generators be safety related. Their operation is not required following a loss of all AC power for 72 hours because they are easily replaced with offsite portable generators, which are capable of being connected to the distribution panel in the same room or to a safety-related connection as described in Westinghouse AP1000 DCD Revision 19, Section 1.9.5.4 and as referenced in the FSAR of each COL holder or applicant. This section of the Westinghouse AP1000 DCD states: “the AP1000 design includes both onsite equipment and safety-related connections for use with transportable equipment.” [ a b ]a,c

[ a b a b a b a b a a b a ]a,c, SRI

[Alternatively, an offsite generator could be placed on top of the turbine building first bay roof. Placing an offsite generator on the roof is easily done considering the small size and weight of the generator. From here, temporary cabling could be routed through a hatch in the first bay roof, and down a stairway to Elevation 135'-3". From this elevation in the turbine building first bay, cabling could be routed into annex building room 40500, then into auxiliary building room 12501, descend stairwell S01 to elevation 82'-6", and then utilize corridor 12211 to access rooms 12207 and 12203. The corridors and rooms mentioned for this path are shown in Westinghouse AP1000 DCD Revision 19 Figures 1.2-25, 1.2-20, 1.2-10, and 1.2-5 and as referenced in the FSAR of each COL holder or applicant. See Figure 3 for a sketch of thh.]a,c, SRI

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[ a b a b a a b b. ]a,c

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a,c,SRI


Figure 2: [ a ]a,c

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a,c,SRI


Figure 3: [ a ]a,c

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3.4 ACCURACY

Order Requirement

The instrument shall maintain its designed accuracy following a power interruption or change in power source without recalibration.


As discussed under NEI 12-02 Section A-4-3.3 the AP1000 design provides means for continued power supply to the spent fuel pool level instrumentation, relying for the first 72 hours only on class 1E batteries. The power supply can then be extended indefinitely by various means as described in NEI 12-02 Section A-4-3.3.

Additionally, the potential impact on temporary loss of power to the level instrument shall be discussed and evaluated in this section including confirmation that the instruments would not need to be re-calibrated following a loss of power.

The instrument should be discussed to address sufficient accuracy during SBO conditions which includes boiling of the SFP water.


[ a a a a a a a a a a a a .]a,c

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3.5 DISPLAY

Order Requirement

The display shall provide on-demand or continuous indication of spent fuel pool water level.


For the first 72 hours, provide details regarding the continuous display provided in the Main Control Room with power provided by the class 1E batteries. For Post 72 hours, describe the features of the Main Control Room display and use of power supplies described in NEI 12-02 Section A-4-3.3. Describe the SFP water level display features. Provide a description of appropriate alarms for low water level. The display requirement may be described by reference to appropriate instrumentation datasheets, specifications, and other relevant documentation.


Three safety-related SFP level sensors provide continuous indication of the SFP level to the MCR as well as the Remote Shutdown Workstation (RSW). Note that though three safety-related instruments are provided, the number of instruments required to meet single failure criteria after stable plant conditions is two. Therefore, two channels are provided with power from separate 1E DC power supplies for at least 72 hours of post-accident monitoring and a third channel is available with power from a 1E DC power supply for at least 24 hours. The redundant sensors are capable of measuring the SFP level continuously from the top of the spent fuel racks up to the operating deck. The continuous level is easily accessed by the operators in the MCR via the Qualified Data Processing System (QDPS) PMS display. In order to alert the operators of abnormally low levels in the SFP, [ a a a a a a a a a ]a,c As described in Section 3.3 of this report, the level instruments are powered by the class 1E batteries for the first 72 hours. After 72 hours, the permanently installed ancillary diesel generators will be used if available or offsite portable generators can be used to power two of the PMS divisions, and thus two of the SFP level transmitters as well as the MCR continuous indication.

3.6 PROGRAMMATIC CONTROLS

Order Requirement

The spent fuel pool instrumentation shall be maintained available and reliable through appropriate development and implementation of a training program. Personnel shall be trained in the use and the provision of alternate power to the safety-related level instrument channels.

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As noted in the background, the safety-related classification of the AP1000 spent fuel level instrumentation ensures routine calibration and testing of the instrumentation, which maintains the equipment as available and reliable. The training program shall be described to provide training to personnel in the use and the provision of alternate power supplies to the existing ac or dc power distribution system to power the instrument channels consistent with the post-72 hours procedures detailed in DCD Section 1.9.5.4. Implemented procedures consistent with the training program shall be summarized and clarified as part of the response.


The training program utilized for implementation of the NEI 06-12, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, will contain the programmatic and training considerations required to deploy and utilize the offsite portable generator that is credited above to continue the SFP level indication function post 72 hours. No additional operational or training requirements are necessary to implement the strategies described above beyond the commitments required as part of the response to EA-12-049, Issuance of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Reference 5).

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4 CONCLUSIONS

The AP1000 design currently meets, or its design allows for the plant to meet (for the interface of FLEX equipment), all additional requirements set forth by NRC Order EA-12-051 (Reference 1) and NRC Order EA-12-063 (Reference 2). These requirements cover the arrangement, qualification, power supplies, accuracy, display, and programmatic controls for the AP1000 safety-related spent fuel pool level instrumentation.

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Enclosure 4 contains Westinghouse Proprietary Class 2 Information requested to be withheld from public disclosure under 10 CFR 2.390(a)(4)

Florida Power & Light Company

700 Universe Boulevard, Juno Beach, FL 33408

L-2013-30310 CFR 52.3 10 CFR 2.390

October 28, 2013

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 Supplemental Response to NRC Request for Additional Information Letter No. 58 (eRAI 6434) - Concerning Implementation of Fukushima Near-Term Task Force Recommendations

References:

1. FPL Letter L-2012-268 to NRC dated June 29, 2012, Response to NRC Request for Additional Information Letter No. 58 (eRAI 6434) - Concerning Implementation of Fukushima Near-Term Task Force Recommendations

2. FPL Letter L-2012-236 to NRC dated May 31, 2012, Schedule for Response to NRC Request for Additional Information Letter No. 58 (eRAI 6434) - Concerning Implementation of Fukushima Near-Term Task Force Recommendations

3. NRC Letter to FPL dated May 1, 2012, Request for Additional Information Letter No. 58 - Concerning Implementation of Fukushima Near-Term Task Force Recommendations for the Turkey Point Units 6 and 7 Combined License Application

Florida Power & Light Company (FPL) provided its response in a letter (Reference 1) to the Nuclear Regulatory Commission’s (NRC) request for additional information (RAI) No. 01.05-3 (eRAI 6434) provided in Reference 3.

FPL provided the schedule (Reference 2) for providing the response to NRC RAI Letter No. 58.

FPL provides, as Enclosure 2 to this letter, its supplemental response to RAI 01.05-3. The Enclosure identifies changes that will be made in a future revision of the Turkey Point Units 6 and 7 Combined License Application (if applicable).

Enclosure 4 contains Westinghouse Proprietary Class 2 Information requested to be withheld from public disclosure under 10 CFR 2.390(a)(4)

Proposed Turkey Point Units 6 and 7 Docket Nos. 52-040 and 52-041 L-2013-303 Page 2

Included in this supplemental response is a report that provides a description of how compliance with the requirements of the proposed license condition for Reliable Spent Fuel Pool Level Instrumentation described in Enclosure 2 will be achieved. This report was developed in conjunction with Westinghouse Electric Company, LLC (Westinghouse) for the AP1000. Enclosure 4 (proprietary) is the Westinghouse report, APP-SFS-M3R-003, Response to NRC Orders EA-12-051 and EA-12-063, and Background Information for Future Licensees on AP1000 Spent Fuel Pool Instrumentation, Rev A.

Enclosure 3 contains the redacted version of Enclosure 4, Westinghouse report, APP-SFS-M3R-004, Response to NRC Orders EA-12-051 and EA-12-063, and Background Information for Future Licensees on AP1000 Spent Fuel Pool Instrumentation, Rev A , Redacted. This is a redacted version and is therefore non-proprietary.

Except for utility specific correspondence and COLA specific License Condition numbering changes, this response follows the technical content, including future COLA changes, submitted for the AP1000 lead plant - Levy Nuclear Plant, Units 1 and 2, Docket Numbers 52-029 and 52-030 in letters:

Letter from Christopher Fallon (PEF) to Nuclear Regulatory Commission (NRC), dated September 25, 2013, Supplement 8 to Response to NRC RAI Letter 108 - Implementation of Fukushima Near-Term Task Force Recommendations. Serial: NPD-NRC-2013-041.

Letter from Christopher Fallon (PEF) to Nuclear Regulatory Commission (NRC), dated May 13, 2013, Supplement 7 to Response to NRC RAI Letter 108 - Implementation of Fukushima Near-Term Task Force Recommendations. Serial: NPD-NRC-2013-022.

Letter from Christopher Fallon (PEF) to Nuclear Regulatory Commission (NRC), dated April 5, 2013, Supplement 6 to Response to NRC RAI Letter 108 - Implementation of Fukushima Near-Term Task Force Recommendations. Serial: NPD-NRC-2013-008.

Enclosure 4 contains Westinghouse Proprietary Class 2 information. The Westinghouse proprietary information for which withholding is being requested is further identified in the affidavit signed by Westinghouse Electric Company, LLC (Enclosure 1).The Westinghouse affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4).

Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3537 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse

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