L-2003-217, Proposed License Amendments Relocation of Pump Technical Specification Surveillance Requirements

Proposed License Amendments Relocation of Pump Technical Specification Surveillance Requirements

ML033040254
Person / Time
Site:	Saint Lucie
Issue date:	10/29/2003
From:	Jefferson W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2003-217
Download: ML033040254 (40)

Text

I Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 October 29, 2003 FPL L-2003-217 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 RE:

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Relocation of Pump Technical Specification Surveillance Requirements Pursuant to 10 CFR 50.90, Florida Power and Light Company (FPL) requests to amend Facility Operating Licenses DPR-67 for St. Lucie Unit I and NPF-16 for St. Lucie Unit 2 by incorporating the attached Technical Specification (TS) revisions. In accordance with the CE Improved Standard Technical Specifications and the NRC Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors, the proposed amendments would relocate specific pressure and flow values associated with the high pressure safety injection (HPSI), low pressure safety injection (LPSI), boric acid makeup (BAM), and containment spray (CS) pumps from the TS to the St. Lucie Units I and 2 Updated Final Safety Analysis Reports (UFSARs).

Attachment I is an evaluation of the proposed changes. Attachment 2 is the "Determination of No Significant Hazards Consideration." Attachment 3 contains the affected Technical Specifications pages marked-up to show the proposed changes. Attachment 4 contains the word-processed TS changes. Attachment 5 contains an information-only copy of the proposed changes to the TS Bases.

The St. Lucie Facility Review Group and the FPL Company Nuclear Review Board have reviewed the proposed amendments. In accordance with 10 CFR 50.91(b)(1), copies of the proposed amendments are being forwarded to the State Designee for the State of Florida.

Please contact us if there are any questions about this submittal.

William rso Vice President St. Lucie Plant WJ/KWF Attachments cc:

Mr. W. A. Passetti, Florida Department of Health an FPL Group company

I r

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Page 2 STATE OF FLORIDA

)

)

ss.

COUNTY OF ST. LUCIE

)

William Jefferson, Jr., being first duly swom, deposes and says:

That he is Vice President, St. Lucie Plant, for the Nuclear Division of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.

STATE OF FLORIDA COUNTY OF St. Lucie_

Sworn to and subscribed before me this 29 day of 2003 by William Jefferson, Jr., who is personally known to me.

Signature try Publig§-WjjR[Xorida A WCOMMISSION#

DD02?212 ERES AsOND May 12 2005

,THRtu IOY FAiN INSURANCE INC Name of Notary Public (Print, Type, or Stamp)

I St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment I Page I ATTACHMENT I EVALUATION OF PROPOSED TS CHANGES

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment I Page 2 EVALUATION OF PROPOSED TS CHANGES BACKGROUND Pursuant to 10 CFR 50.90, Florida Power and Light Company (FPL) requests to amend Facility Operating Licenses DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2 by incorporating the attached Technical Specification (TS) revisions. The proposed amendments would relocate specific pressure and flow values associated with the high pressure safety injection (HPSI), low pressure safety injection (LPSI), boric acid makeup (BAM), and containment spray (CS) pumps from the TSs to the St. Lucie Units 1 and 2 Updated Final Safety Analysis Reports (UFSARs). Relocation of the specific criteria to the St. Lucie Units 1 and 2 UFSARs would afford FPL operational flexibility to revise the criteria without need for requesting an amendment to the operating license. All changes to the St. Lucie Units I and 2 UFSARs require evaluation pursuant to the 10 CFR 50.59 process.

Precedent Licensing Actions Seabrook Station received a similar license amendment in May 2002 to relocate Technical Specification surveillance requirements for pumps to another licensee-controlled document

[Reference 5].

DESCRIPTION OF PROPOSED CHANGE The marked-up pages of the proposed St. Lucie Units I and 2 TS changes are shown in. Word processed TSs are shown in Attachment 4. The description of the proposed changes is presented below.

BAM Pumps - Operating Unit 1 TS Surveillance Requirement (SR) 4.1.2.5 shall be revised to read:

The above required boric acid pump shall be demonstrated OPERABLE by verifying that on recirculation-flow, -the pump develops a the specified discharge pressure ef '

5 psig when tested pursuant to the Inservice Testing Program.

Unit 2 TS SR 4.1.2.5 shall be revised to read:

The above required boric acid makeup pump shall be demonstrated OPERABLE by verifying;-that on rcirculation flos, the pump develops a the specified discharge pressure of greater than or equal to 90 psig when tested pursuant to the Inservice Testing Program.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment I Page 3 BAM Pumps - Shutdown Unit I TS SR 4.1.2.6 shall be revised to read:

The above required boric acid pump(s) shall be demonstrated OPERABLE by verifying that on recireulation flow, the pumps) develops a the specified discharge pressure 4Ž

S-psig when tested pursuant to the Inservice Testing Program.

Unit 2 TS SR 4.1.2.6 shall be revised to read:

The above required boric acid makeup pump(s) shall be demonstrated OPERABLE by verifying,-that on recireulation flow, the pump(s) develop a the specified discharge pressure of greater than or equal to 90 psi when tested pursuant to the Inservice Testing Program.

CS Pumps Unit 1 TS SR 4.6.2.1.b shall be revised to read:

By verifying that on reeireulation flow, each spray pump develops a the specified discharge pressure ef 200 psig; when tested pursuant to the Inservice Testing Program.

Unit 2 TS SR 4.6.2.1.b shall be revised to read:

By verifying that on recireulation flow, each spray pump develops a the specified discharge pressure of greater than or equal to 200 psig, when tested pursuant to the Inservice Testing Program.

HPSI and LPSI Pumps Unit I TS SR 4.5.2.f shall be revised to read:

By verifying that each of the following pumps develops the specified total developed head on reeirculatinflow-when tested pursuant to the Inservice Testing Program.

1. High-Pressure Safety Injection pumps: greater than or equal to 2571 ft.

2. Low-Pressure Safety Injection pumps:greaterthanorequalto350.

Unit 2 TS SR 4.5.2.g shall be revised to read:

By verifying that each of the following pumps develops the specified total developed head on recirculation flow-when tested pursuant to the Inservice Testing Program.

1. High-Pressure Safety Injection pumps: greater than or equal to 285.

2. Low-Pressure Safety Injection pump: reater than or equal to 371ft.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment I Page 4 Unit 2 TS SR 4.5.2.i is to be completely deleted from the TS (there is no corresponding TS SR for St. Lucie Unit 1).

The TS changes delete the specific testing requirements for the subject pumps and will relocate the requirements to the St. Lucie Units I and 2 UFSARs. This action is consistent with the intent of the 1993 NRC Policy Statement, and is also consistent with revision 2 of NUREG-1432 (STS for CE Plants).

BASIS/JUSTIFICATION FOR PROPOSED CHANGE In July 1993, the NRC issued a Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors in the Federal Register [Reference 1]. The policy statement contained four objective criteria, whose purpose was to focus the Technical Specifications on only those requirements that are important to operational safety. The four criteria are now codified in 10 CFR 50.36 [Reference 2]. The criteria identify requirements derived from the analyses and evaluations included in the UFSAR that are of immediate concern to the health and safety of the public. Generally, the criteria identify operating requirements related to: 1) detecting reactor coolant pressure boundary degradation; 2) operation within the initial conditions of the accident analyses; 3) accident mitigation; and 4) the operation of other risk-significant structures, systems, or components not covered by the first three criteria. 10 CFR 50.36(c)(2)(ii) requires that a technical specification limiting condition for operation (LCO) must be established for items meeting one or more of the criteria.

The Final Policy Statement also encouraged licensees to implement a voluntary update program of their Technical Specifications to be consistent with the Standard Technical Specifications (i.e.,

NUREG-1432 for Combustion Engineering (CE) plants [Reference 3]). The four 10 CFR 50.36 criteria provide a basis for relocating requirements from the Technical Specifications to other licensee-controlled documents, provided the requirements meet none of the four criteria. NRC Staff Review of NSSS Vendor Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications ("split report") [Reference 4] provides NRC staff review of each reactor vendor Owners Group's application of the four criteria to their respective Standard Technical Specifications (STS). The list of retained and relocated LCOs is tabulated in Appendix C of Reference 4.

The subject TS SRs currently provide details describing pump acceptance criteria and test methods (e.g., testing on recirculation flow) associated with performance surveillance testing of centrifugal pumps. It is proposed that these details be relocated to the UFSAR. These details are not necessary to ensure operability. The requirements of the applicable Limiting Condition for Operation (LCO) and the associated Surveillance Requirements for these systems, as well as the TS definition of OPERABILITY, are adequate to ensure the systems are maintained operable.

As a result, these details are not necessary to ensure the systems can perform their intended safety function and are not required to be in the TS to provide adequate protection of the public health and safety. BAM pumps are not specifically addressed in NUREG-1432, Revision 2.

However, relocating the BAM pump surveillance requirement success criteria and testing methods to the UFSAR meets the intent of the ISTS treatment of other emergency core and containment heat removal centrifugal pumps.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment I Page 5 The relocation of these surveillance details for the CS, LPSI, HPSI, and BAM pumps to the St.

Lucie UFSARs maintains the consistency with NUREG-1432. Any change to these details will be made in accordance with 10 CFR 50.59.

Current Unit 2 TS SR 4.5.2.i requires the performance of a flow balance test to the emergency core cooling system (ECCS) subsystems following the completion of modifications that alter the subsystem flow characteristics. Plant procedures governing the restoration of equipment after maintenance specify the appropriate post maintenance testing. It is proposed that this requirement be relocated to the UFSAR. Any time the operability of a system or component has been affected by repair, maintenance, or replacement of a component, post maintenance testing is required to demonstrate operability of the system or component. As such, the requirement to perform a flow balance test after modifications that alter flow characteristics is not required to be in the TS to provide adequate protection of the public health and safety. The TS SR Bases will be revised to state that the flow balancing criteria are contained in the UFSAR to ensure that post modification testing criteria continues to verify the safety analysis assumptions. The relocation of this requirement maintains the consistency with NUREG-1432. Any change to this requirement will be made in accordance with 10 CFR 50.59.

These proposed changes relocate requirements that are not of controlling importance to operational safety. This is consistent with the Improved Standard Technical Specifications for CE plants and the 1993 NRC Policy Statement. The specific pump surveillance verification criteria currently within the TSs may be removed from TSs because they do not meet the four specific criteria in 10 CFR 50.36. Specifically:

Pump performance verification criteria is not considered installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Thus, the specific pump performance verification criteria do not satisfy Criterion I (as amended in 10 CFR 50.36) for retention; Pump performance verification criteria is not a process variable that is an initial condition of a design basis accident (DBA) or transient analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, the specific pump performance verification criteria do not satisfy Criterion 2 (as amended in 10 CFR 50.36) for retention; Pump performance verification criteria is not a structure, system, or component (SSC) that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, the specific pump performance verification criteria do not satisfy Criterion 3 (as amended in 10 CFR 50.36) for retention; Pump performance verification criteria is not considered as a significant risk contributor.

Therefore, the specific pump performance verification criteria do not satisfy Criterion 4 (as amended in 10 CFR 50.36) for retention in the Technical Specifications.

Though it is recognized that proper engineered safety feature (ESF) pump performance is necessary to ensure the safety analysis assumptions remain valid, the specific values for determining proper ESF pump performance need not be contained within the TS SR itself. The

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment I Page 6 specific details controlled by the subject specifications do not need to be included within the scope of the Technical Specifications. The subject details will be adequately controlled in the St.

Lucie UFSARs. The inclusion of the subject details in TSs is not specifically required by 10 CFR 50.36, or other regulations. Additionally, the activities controlled by the subject specification do not pose a threat to the public health and safety. Therefore, the proposed changes to the subject TS SR do not affect plant safety.

SUMMARY

CONCLUSION The TS SRs reviewed above do not meet any of the four 10 CFR 50.36 screening criteria and may be relocated to the respective unit's UFSAR. Relocating these technical specification requirements to the UFSAR will be consistent with the Improved Standard Technical Specifications for CE plants, will be consistent with the 1993 NRC Policy Statement regarding Technical Specifications content, and will ensure future changes are controlled under the requirements of 10 CFR 50.59.

REFERENCES

1. Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, 58 FR 39132, dated July 22, 1993.

2.

10 CFR 50.36(c)(2)(ii), Technical Specifications [screening criteria].

3.

NUREG-1432, Standard Technical Specifications for Combustion Engineering Plants, Rev.

2, dated April 2001.

4.

NRC Staff Review of NSSS Vendor Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications ("split report"), dated May 9, 1988.

5.

NRC SER for Seabrook Station dated May 2, 2002, Issuance of Amendment Re: Relocation of Certain Engineered Safety Features Pump Values From Technical Specifications to the Technical Requirements Manual (TAC No. MB4258).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 2 Page I ATTACHMENT 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 2 Page 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Description of amendment request: Pursuant to 10 CFR 50.90, Florida Power and Light Company (FPL) requests to amend Facility Operating Licenses DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2 by incorporating the attached Technical Specification (TS) revisions. The proposed amendments would relocate specific pressure and flow values associated with the high pressure safety injection (HPSI), low pressure safety injection (LPSI),

boric acid makeup (BAM), and containment spray (CS) pumps from the TSs to the St. Lucie Units I and 2 Updated Final Safety Analysis Reports (UFSARs). Relocation of the specific criteria to the St. Lucie Unit 1 and 2 UFSARs would afford FPL operational flexibility to revise the criteria without need for requesting an amendment to the operating license. All changes to the St. Lucie Units I and 2 UFSARs require an evaluation pursuant to 10 CFR 50.59 prior to implementation. Relocation of these requirements to the St. Lucie Units I and 2 UFSARs is consistent with the NRC Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, FR, 58, No. 139, page 39132, dated July 22, 1993, and is also consistent with 10 CFR 50.36 and Revision 2 of NUREG-1432, Standard Technical Specifications for CE Plants.

Pursuant to 10 CFR 50.92, a determination may be made that a proposed license amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Each standard is discussed as follows.

1) Would operation of the facility in accordance with the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes to relocate the BAM, CS, HPSI, and LPSI pump surveillance verification details in the aforementioned Technical Specifications surveillance requirements to the St. Lucie UFSARs do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, configuration of the facility, or the manner in which it is operated. The proposed changes do not alter or prevent the ability of structures, systems, or components to perform their intended function to mitigate the consequences of an initiating event within the acceptance limits assumed in the St. Lucie UFSARs.

The subject surveillance requirement criteria relocated to the St. Lucie UFSARs will continue to be administratively controlled. Changes to the St. Lucie UFSARs are evaluated and controlled under 10 CFR 50.59 prior to implementation. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 2 Page 3

2)

Would operation of the facility in accordance with the proposed amendments create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed changes do not alter the design assumptions, conditions, or configuration of the facility or the manner in which the plant is operated. There are no changes to the source term or radiological release assumptions used in evaluating the radiological consequences in the St. Lucie UFSARs. The proposed changes have no adverse impact on component or system interactions. The proposed changes vill not adversely degrade the ability of systems, structures and components important to safety to perform their safety function nor change the response of any system, structure or component important to safety as described in the UFSARs. The proposed changes do not change the level of programmatic and procedural details of assuring operation of the facility in a safe manner. Since there are no changes to the design assumptions, conditions, configuration of the facility, or the manner in which the plant is operated and surveilled, the proposed changes do not create the possibility of a new or different kind of accident from any previously analyzed.

3)

Would operation of the facility in accordance with the proposed amendments involve a significant reduction in a margin of safety?

There is no adverse impact on equipment design or operation and there are no changes being made to the Technical Specification required safety limits or safety system settings that would adversely affect plant safety. The proposed changes do not reduce the level of programmatic or procedural controls associated with the activities presently performed via the aforementioned surveillance requirements.

Future changes to the relocated technical requirements will require an evaluation pursuant to the provisions of 10 CFR 50.59 prior to implementation.

Therefore, relocation of the specific pump pressure and flow criteria contained in the aforementioned Technical Specifications Surveillance Requirements to the St. Lucie Units 1 and 2 UFSARs does not involve a significant reduction in the margin of safety provided in the existing specifications.

Based on the determination made above, FPL concludes that the proposed amendments involve no significant hazards consideration.

Environmental Consideration The proposed license amendments do not change requirements with respect to the use of a facility component located within the restricted area as defined in 10 CFR Part 20. The proposed amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure. FPL concluded that the proposed amendments involve no significant hazards consideration and meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and that, pursuant to 10 CFR 51.22(b), an environmental impact

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 2 Page 4 statement or environmental assessment need not be prepared in connection with issuance of the amendments.

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

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page I ATTACHMENT 3 ST. LUCIE MARKED-UP TECHNICAL SPECIFICATION PAGES Unit I TS Page 3/4 1-14 Page 3/4 1-15 Page 3/4 5-5 Page 3/4 6-15a Unit 2 TS Page 3/4 1-11 Page 3/4 1-12 Page 3/4 5-5 Page 3/4 5-6 Page 3/4 6-15a

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page 2 REACTIVITY CONTROL SYSTEMS BORIC ACID PUMPS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.5 At least one boric acid pump shall be OPERABLE if only the flow path through the boric acid pump in Specification 3.1.2.1a above, is OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no boric acid pump OPERABLE as required to complete the flow path of Specification 3.1.2.1a, suspend all operations involving CORE ALTERATIONS or positive reactivity changes' until at least one bo acidup s restored to OPERABLE status.

15lSYEILt ACEURE UBEE 4.1.2.5 The above required boric acid pump shabe demonstrated OPERABLE by verifying that rocGil'tion now, the pump develops ischarge pressure eft-7Spsigwhen tested pursuant to the Inservice Testing Program.

Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

ST. LUCIE - UNIT 3/4 1-14 Amendment No. 60. 43. I

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page 3 REACTIVITY CONTROL SYSTEMS BORIC ACID PUMPS - OPERATING LIMMNQ CONDION FOR OPERATION 3.1.2.6 At least the boric acid pump(s) In the boron injection flow path(s) required OPERABLE pursuant to Specification 3.1.2.2a shall be OPERABLE if the flow path through the boric acid pump in Specification 3.1.2.2a is OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

With one boric acid pump required for boron injection flow path(s) pursuant to Specification 3.1.2.2a Inoperable, restore the boric acid pump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVELLAN-EQ UIRE ENTSfi

_(.

4.1.2.6 The above required boric acid pum (s) shall be demonstrated OPERABLE by verifying that a.

Heeifeulelk"ote pump Jevelops discharge pressure 'vi-F6-pe§-when tested pursuant to the Inservice T s ing Progrm.

• i-i~Sm e

ST. LUCIE -UNIT 3/4 1-15 Amendment No. 60, 468

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page 4 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REOUIREMENT (continued)I

e.

At least once per 18 months, during shutdown, by:

1.

Verifying that each automatic valve in the flow path actuates to Its correct position on a Safety Injection Actuation Signal.

2.

Verifying that each of the following pumps start automatically upon receipt of a Safety Injection Actuation Signal;

a.

High-Pressure Safety Injection Pump.

b.

Low-Pressure Safety Injection Pump.

3.

Verifying that upon receipt of an actual or simulated Recirculation Actuation Signal: each low-pressure safety injection pump stops, each containment sump Isolation valve opens, each refueling water tank outlet valve closes, and each safety injection system recirculation valve to the refueling water tank doses.

f.

By verifying that each of the following pumps develops the specified total developed head on roiou1ltion Rflowwhen tested pursuant to the Inservice Testing Program.

1.

High-Pressure Safety Injection pumps: gfezter then of equal 2571 ft..

2.

Low-Pressure Safety Injection pumps: geater than or equal to 30 f.

ST. LUCIE -UNIT I 3M4 i-Amendment No. 26,90, 430,400.48

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page 5 sURYEllARNCEREQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a.

At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, seated, or otherwise secured in position, is positioned to take suction from the RWT on a Containment Pressure

- High High test signal.

b.

By verifying that on roiruation flow each spray pump develops discharge pressure of 00pslig1 when tested pursuant to the Inservice Te g Program.

i ST. LUCIE - UNIT 3/4 6-15a Amendment No. 434, t5-

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page 6 REACTIVITY CONTROL SYSTEMS BORIC ACID MAKEUP PUMPS - SHUTDOWN LIMITING CONDON FOR OPERATION 3.1.2.5 At least one boric acid makeup pump shall be OPERABLE and capable of being powered from an OPERABLE emergency bus if only the flow path through the boric acid pump in Specification 3.1.2.1a Is OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no boric acid pump OPERABLE as required to complete the flow path of Specification 3.1.2.1a, suspend all operations invoyinqORE ALTERATIONS or positive reactivity changes*.

rw.

5 p

eci 6URVEILLANCE RFQIIENTS 4.1.2.5 The above required boric acid makeup pump shall be monstrated OPERABLE by verifying,that cn rcirculation now, the pump develops e-discharge pressure efgreei than or equal o 0 psig when tested pursuant to the Inservice Testing Program.

Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

ST. LUCIE -UNIT 2 3/4 1-1 1 Amendment No.

. 43*-

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page 7 REACTIVITY CONTROL SYSTEMS BORIC ACID MAKEUP PUMPS -OPERATING LIMITING ONDITION FOR OERATION 3.1.2.6 At least the boric acid makeup pump(s) in the boron Injection flow path(s) required OPERABLE pursuant to Specification 3.1.2.2 shall be OPERABLE and capable of being powered from an OPERABLE emergency bus if the flow path through the boric acid pump(s) in Specification 3.1.2.2 is OPERABLE.

APPLICABILITY: MODES 1 2,3 and 4.

ACTION:

With no boric acid makeup pump required for the boron injection flow path(s) pursuant to Specification 3.1.2.2 Inoperable, restore the boric acid makeup pump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to its COLR limit at 2000F; restore the above required boric acid makeup pump(s) to OPERABLE status within the next 7 days or be In COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

EURVEILLANCE RERUIREUEM 4.1.2.6 The above required boric acid makeup pump(s) shall be demonstrated OPERABLE by verifyingrthat on rocirc'htio' flow the pump(s) develop kdischarge pressure ef gro;Ir than or qul to 90 prig when tested pursuant to thl~nservice Testing Program.

ST. LUCIE - UNIT 2 314 1-12 Amendment No. 8. 25.40.94, " 5

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-2 17 Attachment 3 Page 8 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS continued)i

2.

A visual inspection of the containment sump and verifying that the subsystem suction Inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

3.

Verifying that a minimum total of 173 cubic feet of solid granular trisodium phosphate dodecahydrate (TSP) is contained within the TSP storage baskets.

4.

Verifying that when a representative sample of 70.5 +/- 0.5 grams of TSP from a TSP storage basket Is submerged, without agitation, In 10.0 +/- 0.1 gallons of 120 +/- ooF borated water from the RVWT, the pH of the mixed solution Is raised to greater than or equal to 7 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

f.

At least once per 18 months, during shutdown, by.

1.

Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and/or RAS test signals.

2.

Verifying that each of the following pumps start automatically upon receipt of a Safety Injection Actuation Test Signal:

a.

High-Pressure Safety Injection pump.

b.

Low-Pressure Safety Injection pump.

3.

Verifying that upon receipt of an actual or simulated Recirculation Actuation Signal: each low-pressure safety Injection pump stops, each containment sump isolation valve opens, each refueling water tank outlet valve closes, and each safety injection system recirculation valve to the refueling water tank Closes.

g.

By verifying that each of the following pumps develops the specified total developed head e

izuFWbthe Rewwhen tested pursuant to the Inservice Testing Program:

1.

High-Pressure Safety Injection punm~s-yz9tze thM~ zW e 1 t 2854 Ft..

2.

Low-Pressure Safety Injection pum g§ tee8e hen r r equt 9Nft.- a

h.

By verifying the correct position of each electrical and/or mechanical position stop for the following ECCS throttle valves:

1.

During valve stroking operation or following maintenance on the valve and prior to declaring the valve OPERABLE when the ECCS subsystems are required to be OPERABLE.

ST. LUCIE - UNIT 2 314 5-5 Amendment No. 94, 99, 406

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page 9 EMERGENCY CORE COOLING SYSTEMS S5URVEILLANCE REQUIREMENTS (Continued)

2.

At least once per 18 months.

HPSI Sstem LPSI Sstem Valve Number Valve Number

a. HCV3616/3617

a. HCV 3615

b. HCV 3626/3627

b. HCV 3625

c.

HCV363613637

c.

HCV 3635

d. HCV 3646/3647

d. HCV 3645

e.

V3523N3540 By performing ow balance test, during shutdowrollowing compin Mdfctions to the ECCS subsy ms that alter the) subsysefo chrceristics. The test sha ~easure the individual leg f ates and pump total developed h d to verify the following HPSI Pump 2A/

The sum of the three low cold leg flow rates shall be greater than or equal to 476 g with total developed head greater t n or equal to 1150 fb less than equal to 1290 f.

2.

HPSI Pump 2 The sum of e three lowest cold leg flow rates s be greater than or e alto 484 gpm with total developed ad greater than oreq to 910 ft but less than or equal to I ft.

3.

h the system operating in hot/cold injection mode, the ot leg flow shall be greater than orqual to 317 gpm and

/

~within 10% of the cold leg head~to and:/

/ /

HPSI Pump 2A://

The pump shall be prod ng total developed head greater t n or equal to 1297 ft butIs than or equal to 1500 ft.

~HPSI Pump 2B/

The pump s be producing total developed he greater than or equal to 2 ft but less than 1250 ft.

/

4.

LP ystem - Each Pump:/;

e flow through each injection leg s I be greater than or equal to 1763 gpm at a total devel ed head greater than or equal to 298 ft but less than or al to 337 ft.

ST. LUCIE - UNIT 2 3/45-6 Amendment No.*5

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 3 Page 10 SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a.

At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is positioned to take suction from the F Geq tnqt Pressure - -

High-High test signal.

H Z

Cpne-K

b.

By verifying that on-oFic ii ach pump develops discharge pressure f groater tht o quao 200ig when tested pursuant to the Inservice Testing Program.I

c.

At least once per 18 months, during shutdown, by:

1.

Verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal.

2.

Verifying that upon a Recirculation Actuation Test Signal (RAS), the containment sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established.

ST. LUCIE - UNIT 2 3/4 6-15a Amendment No. 70, St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 4 Page I ATTACHMENT 4 ST. LUCIE WORD PROCESSED TECHNICAL SPECIFICATION PAGES Unit I TS Page 3/4 1-14 Page 3/4 1-15 Page 3/4 5-5 Page 3/4 6-15a Unit 2 TS Page 3/4 1-11 Page 3/4 1-12 Page 3/4 5-5 Page 3/4 5-6 Page 3/4 6-iSa

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 4 Page 2 REACTIVITY CONTROL SYSTEMS BORIC ACID PUMPS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.5 At least one boric acid pump shall be OPERABLE If only the flow path through the boric acid pump in Specification 3.1.2.1a above, is OPERABLE.

APPLICABILITY: MODES 5 and 6.

ACTION:

With no boric acid pump OPERABLE as required to complete the flow path of Specification 3.1.2.1a, suspend all operations Involving CORE ALTERATIONS or positive reactivity changes* until at least one boric acid pump Is restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.1.2.5 The above required boric acid pump shall be demonstrated OPERABLE by verifying that the pump develops the specified discharge pressure when tested pursuant to the Inservice Testing Program.

Plant temperature changes are allowed provided the temperature change is accounted for in the calculated SHUTDOWN MARGIN.

ST. LUCIE -UNIT I 3/4 1-14 Amendment No. 0, 453, 44a.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-2 17 Attachment 4 Page 3 REACTiVITY CONTROL SYSTEMS

'IORIC ACID PUMPS - OPERATING

Ae.

ial-th.'

M

.ih~

3i.i2.6 At ieast the bricacid b

pIrthebioron njection flow Ot(s) reulred OPERABLE pursuant to Specification 3.i.2 2a shall be OPERABLE, If the fow path tiugh the boric acid'pump In Speclficain n31.22a IsOPERABLE.'

APPLICABILITY: MODES i, 2;3 and ;4.

ACMON:

With one boric acid pump required for-boron InJe1iori flaw path(s) pursuant to Specification 3.1.2.2a inoperable, restore the boric acid pumpto OPERABLE stifii'i ilthin'72 hiors or 6be Wi'et Ieast HOT STANDBY with Wn the nxt 6 hurs i In^OOLD.

SHUTDOWN 'Mithin tbiefot ng'30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />

.. ~ ~ ~ ~ ~ ~

r_.s SURVEILLANCE REIREMENTS--

4.126 Theab requre bricadd "purmp(s) 4hat berdemonstrate haflhe'pumps) develp the specifi discha'rge'pressure when tested purs'uant to the :

Inservice(Testing Pio-ram.

-ST. UCIE UNrr 1 3141-15 Amendment No.90,- 43,

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 4 Page 4 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

e.

At least once per 18 months, during shutdown, by:

1.

Verifying that each automatic valve In the flow path actuates to its correct position on a Safety Injection Actuation Signal.

2.

Verifying that each of the following pumps start automatically upon receipt of a Safety Injection Actuation Signal;

a.

High-Pressure Safety Injection Pump.

b.

Low-Pressure Safety Injection Pump.

3.

Verifying that upon receipt of an actual or simulated Recirculation Actuation Signal: each low-pressure safety injection pump stops, each containment sump Isolation valve opens, each refueling water tank outlet valve closes, and each safety njection system recirculation valve to the refueling water tank closes.

f.

By verifying that each of the following pumps develops the specified total developed head when tested pursuant to the Inservice Testing Program.

1.

High-Pressure Safety Injection pumps.

2.

Low-Pressure Safety Injection pumps.

ST. LUCIE - UNIT 1 3/4 i-5 Amendment No. 26. 0, 453. 40, 464,

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 4 Page 5 SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a.

At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is positioned to take suction from the RWT on a Containment Pressure

- High High test signal.

b.

By verifying that each spray pump develops the specified discharge pressure when tested pursuant to the Inservice Testing Program.

ST. LUCIE - UNIT I 3/4 6-15a Amendment No. 43X, 453,

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-2 17 Attachment 4 Page 6 REACTiViTY CONTROL SYSTEM~S

'BORIC 'ACID'MAKEUP PUMPS-SHUTDOWN

-3.~1.2.5 Ait basf ofeabodacld rnak'eup pump shall be OPERABLE'and caableof ben-powered from 'anOPERABLE emirigency bus If onljIh6 flow ptti bon -'id t'

Speifiaton 31.2.la is"OPERABLE.

t'e

'borc aci pmp n

APPLiCABILITY:-:MODES,5'and 6.

ACTION:

With no boric acd pump 'OPERABLE as required to complete 'the 'fow path of Sp-efifalion 3i 2.1 a', susperidall operatons Involving CORE ALTERATIONS orp'sitive

'reactivity 'changes*,

SUBMCILMACE REQUIREMENT

'4.12.5 Thio boveqr'cured bbri'caicid r'nakoup puriip'haII ;9demo'nstrate'OPERABL£ by' v6rWfying that the pu-Idelops the specifieci 'di we sure whetested pu'rsuant

'ti'the Inservice Testing Proiram.

Plant temperature 6hanges arei aliowed provicecthe tern erature change is accounted for In tte calculated SHUTDOWN MARGIN. ""r c

i a for

'STAUCIE'UNrr2

'3/4 1-11 S UAmondmwt No. 04 -422.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 4 Page 7 REACIVtY CONTROL SYSTEMS

,BORIC ACID MAKEUP PUMPS -OPERATING

,3.1.2.8 '

iAt lea'st the 'b'o'c aid 'nak-i p piii!n(s)

In'th brb'n Inje dn fiw ath(s) 'eqbired OPERABLE pursu'a'nl to Specification 3.1.22 shall be OPERABLE a'nd capable' 'o' being powered rom an'OPERABLE emergency bus if the'1ow'path through the borc aid pumps) In Spedificaton 3.1.2.2 is OPERABLE.

APPLICABILITY: MODES 1.2.,3'and4

-,cTIoN:

With no bonc a'dd maTeup pump reqired for itioheorninjection fbw path(s) pursuant to Specificaion 3.1.2.2 inopbe, restb the boric acId makeup pump to '

OPERABLE status ithnl2 hours or be in at leasi HOT STANDBY uwithin the neid 6 hois and birated to a SHUTDOWN MARGIN equlvalent to'Its COLR Irt at'"

200°F; restore'theabov'e req'uired bos acid mak'eup puip(s)to'OPERABLE status within th 6next 7 days'or bein COLD 'SHUTDOWN within the'next 30 hou'rs.

1,SURYCILLMNE 13EQUIREMENTS' 4.1i.26 The a(ove required bonc add riakeup pumps) sha I be demorfnsrled PER8LE by venif4ng that the pump(is) deveop the speifed dis rge pressurew'"ien tosted pursuant to the lnsemice Testing Program.

ST. LUCIE -UNIT2

,3I41.12 Amerdnenl No., 26, 0F4,405.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 4 Page 8 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REOUIREMENTS (otinued

2.

A visual inspection of the containment sump and verifying that the subsystem suction Inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

3.

Verifying that a minimum total of 173 cubic feet of solid granular trisodium phosphate dodecahydrate (TSP) Is contained within the TSP storage baskets.

4.

Verifying that when a representative sample of 70.5 +/- 0.5 grams of TSP from a TSP storage basket is submerged, without agitation, In 10.0 + 0.1 gallons of 120 +/- 1 0F borated water from the RWT, the pH of the mixed solution is raised to greater than or equal to 7 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

f.

At least once per 18 months, during shutdown, by.

1.

Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and/or RAS test signals.

2.

Verifying that each of the following pumps start automatically upon receipt of a Safety Injection Actuation Test Signal:

a.

High-Pressure Safety Injection pump.

b.

Low-Pressure Safety Injection pump.

3.

Verifying that upon receipt of an actual or simulated Recirculation Actuation Signal: each low-pressure safety Injection pump stops, each containment sump isolation valve opens, each refueling water tank outlet valve closes, and each safety Injection system recirculation valve to the refueling water tank doses.

g.

By verifying that each of the following pumps develops the specified total developed head when tested pursuant to the Inservice Testing Program:

1.

High-Pressure Safety Injection pumps.

2.

Low-Pressure Safety Injection pumps.

h.

By verifying the correct position of each electrical and/or mechanical position stop for the following ECCS throttle valves:

1.

During valve stroking operation or following maintenance on the valve and prior to declaring the valve OPERABLE when the ECCS subsystems are required to be OPERABLE.

ST. LUCIE - UNIT 2 3/45-5 Amendment No. 94,99. 49g,

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 4 Page 9 EMERGENCY CORE COOLING SYSTEMS SURVEILLaC2

REQUIREMENTS (Conlnuenf HPS Svstem Valve umber'

a.

HCV361613617 1-I.

HC36263627 cIHCV36363637.

.HCV 3646/3647

3. 5v3523/N3540

.LPSI System.

Valve Number

a. HCV3615 b.d HCV 3625.

c.

HCV 3635 d; HCV 3645

. 7ST. LCE UT 2

.'314 5-6 TIAmendmert No.25.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 4 Page 10 SU5jRV1E1LLANE REQUIREMENTS 4.6.2.1 Each contanment spraysysiem shaii be demonstraed OPERABLE.

.a. At st once per 3f

y. en acii vaF,, (manua, poweroperated, or

.'.atornatic) the'flow path'that is'not 16le'd, 'sealed, orotherwisesecu'red in p'osih, Is o'sitioned to bkoatiion'fro i RWTo' a'C6nrrin 'es'sure,- t' '

~High-High st signai. '

uc'o fro th

~W

on

'a' C

' ' ' '"'m " 't "Pr'e~ '^'"!

r~-

,b. *By.verifying that each spray pump develops the specified discharge pressure when tested pursuant to Inserico Testing'ram.;

c.

Atet onceper.18 months;during shit wn, by

• 1. ;Yrifing that each autoiiatic valve ln the flow path actuates to its-correct

-positionon a CSAS test signal.

Verifying that upon a'Reciculatio fAiuation Test Slgnal (RAS), the

.conlalnment sump isolation alves open end that a recircueaton mo fl:

pathvia an OPERABLE'shuldown cooling heat exchanger'<esablshd.

.:
ST. LUC UNrr 2

,1..

sT.L~~cI-u~~rr2 5/4 6-15.

-Aa~4ie4k4.`k

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 5 Page I ATTACHMENT 5 ST. LUCIE MARKED-UP TS BASES CHANGES

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment Page 2 SECTION NO-TITLE:

TECHNICAL SPECIFICATIONS PAGE:

314.1 BASES ATTACHMENT 3 OF ADM-25.04 6 of 9 REVISION NO.:

REACTIVITY CONTROL SYSTEMS 1

ST. LUCIE UNIT 1 314.1 REACTIVITY CONTROL SYSTEMS (continued)

BASES (continued) 314.2 BORATION SYSTEMS (continued)

Temperature changes In the RCS Impose reactivity changes by means of the moderator temperature coefficient. Plant temperature changes are allowed provided the temperature change Is accounted for In the calculated SDM. Small changes In RCS temperature are unavoidable and so long as the required SDM Is maintained during these changes, any positive reactivity additions will be limited to acceptable levels.

Introduction of temperature changes must be evaluated to ensure they do not result In a loss of required SDM.

The boron addition capability after the plant has been placed In MODES 5 and 6 requires either 3650 gallons of 2.5 to 3.5 weight percent boric acid solution (4371 to 6119 ppm boron) from the boric acid tanks or 11,900 gallons of 1720 ppm borated water from the refueling water tank to makeup for contraction of the primary coolant that could occur if the temperature Is lowered from 2000F to 140 0F.

The restrictions associated with the establishing of the flow path from the RWT to the RCS via a single HPSI pump provide assurance that 10 CFR 50 Appendix G pressure/temperature limits will not be exceeded in the case of any Inadvertent pressure transient due to a mass addition to the RCS. If RCS pressure boundary Integrity does not exist as defined In Specification 1.16, these restrictions are not required. Additionally, a limit on the maximum number of operable HPSI pumps Is not necessary when the pressurizer manway cover or the reactor vessel head Is removed.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 5 Page 3 SECTION NO.:

TLE:

TECHNICAL SPECIFICATIONS PAGE:

3/4.1 BASES ATTACHMENT 3 OF ADM-25.04 6 of 10 REVISION NO.:

REACTIVITY CONTROL SYSTEMS I

ST. LUCIE UNIT 2 3/4.1 REACTIVITY CONTROL SYSTEMS (continued)

BASES (continued) 3/4.1.2 BORATION SYSTEMS (continued)

Temperature changes In the RCS Impose reactivity changes by means of the moderator temperature coefficient Plant temperature changes are allowed provided the temperature change Is accounted for In the calculated SDM. Small changes In RCS temperature are unavoidable and so long as the required SDM Is maintained during these changes, any positive reactivity additions will be limited to acceptable levels. Introduction of temperature changes must be evaluated to ensure they do not result In a loss of required SDM.

The boron capability required below 2000F Is based upon providing a SHUTDOWN MARGIN corresponding to its COLR limit after xenon decay and cooldown from 200OF to 1400F. This condition requires either 6750 gallons of 1720 ppm - 2100 ppm borated water from the refueling water tank or 3550 gallons of 2.5 to 3.5 weight percent boric acid solution from the boric acid makeup tanks.

The contained water volume limits Includes allowance for water not available because of discharge line location and other physical characteristics.

The OPERABILITY of one boron Injection system during REFUELING ensures that this system is available for reactivity control while In MODE 6.

The limits on contained water volume and boron concentration of the RWT also ensure a pH value of between 7.0 and 8.0 for the solution recirculated within containment after a LOCA. This pH band minimizes the evolution of iodine and minimizes the effect of chloride and caustic stress corrosion on mechanical systems and components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 5 Page 4 SECTION NO.:

TmLE, TECHNICAL SPECIFICATIONS PAGE:

3/4.5 BASES ATTACHMENT 7 OF ADM-25.04 4 of 5 REVISION NO.:

EMERGENCY CORE COOLING SYSTEMS (ECCS) 0 ST. LUCIE UNIT 1 3)4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued)

BASES (continued) 3/4.5.2 and 314.5.3 ECCS SUBSYSTEMS The OPERABILITY of two separate and independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available In the event of a LOCA assuming the loss of one subsystem through any single failure consideration. Either subsystem operating In conjunction with the safety injection tanks Is capable of supplying sufficient core cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double ended break of the largest RCS cold leg pipe downward. In addition, each ECCS subsystem provides long term core cooling capability In the recirculation mode during the accident recovery period.

TS 3.5.2. ACTION a.1. provides an allowed outagelaction completion time (AOT) of up to 7 days from Initial discovery of failure to meet the LCO provided the affected ECCS subsystem Is Inoperable only because its associated IPSI train Is inoperable. This 7 day AOT Is based on the findings of a deterministic and probabilistic safety analysis and Is referred to as a risk-informed' AOT extension. Entry Into this ACTION requires that a risk assessment be performed in accordance with the Configuration Risk Management Program (CRMP) which is described In the Administrative Procedure (ADM-17.08) that implements the Maintenance Rule pursuant to 10 CFR 50.65.

The Surveillance Requirements provided to ensure OPERABILITY of each component ensure that at a minimum, the assumptions used in the accident analyses are met and that subsystem OPERABILITY is maintained.

The limitations on HPSI pump operability when the RCS temperature Is

< 270OF and < 2360F, and the associated Surveillance Requirements provide additional administrative assurance that the pressure/temperature limits (Figures 3.4-2a and 3.4-2b) will not be exceeded during a mass addition transient mitigated by a single PORV. A limit on the maximum number of operable HPSI pumps Is not necessary when the pressurizer manway cover or the reactor vessel head Is removed.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 5 Page 5 SECTION NO.:

TITLE:

TECHNICAL SPECIFICATIONS PAGE:

3/4.5 BASES ATTACHMENT 7 OF ADM-25.04 5 of 6 REVISION NO.:

EMERGENCY CORE COOLING SYSTEMS (ECCS) 0 ST. LUCIE UNIT 2 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued)

BASES (continued) 314.5.2 and 3/4.5.3 ECCS SUBSYSTEMS (continued)

The requirement for one high pressure safety injection pump to be rendered Inoperable prior to entering MODE 5, although the analysis supports actuation of safety Injection in a water solid RCS with pressurizer heaters energized, provides additional administrative assurance that a mass addition pressure transient can be relieved by the operation of a single PORV or SDCRV. A limit on the maximum number of operable HPSI pumps Is not necessary when the ressurizer manway cover or the reactor vessel head is remo 0 pet The Surveillance Requiremen sprovided to ensure PERA ILITY of each component ensure that a minimum, the assumptions used in the accident analyses are met and that subsystem OPERABILITY is mai ained.

-r3e.' Surveillance quiremenyKfor throttle valve position stop i flow balance testi rovdeassurance that proper ECCS fi ill be maintained %n' event of a LOCA. Maintenance of proper flow resistance and pressure drop in the piping system to each Injection point Is necessary to: (1) prevent total pump flow~ from exceeding runout conditions when the system is in Its minimum resistance configuration, (2) provide the proper flow split between Injection points In accordance with the assumptions used In the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injection points equal to or above that assumed In the ECCS-LOCA analyses. The requirement to dissolve a representative sample of TSP In a sample of RWT water provides assurance that the stored TSP will dissolve In borated water at the postulated post-LOCA temperatures.

Te practice of calibrating and testing the SDC Isolation valve interlock function below 515 psia (the current plant practice Is to set and test the iN) } Interlock function at 500 psia) meets the requirements of Technical Specification Surveillance 4.5.2.e.1. The staff accepted that testing the SDC Isolation Interlock at a more conservative setpoint demonstrates operability at and above the setpoint (NRC letter from William C. Gleaves to J.A. Stall dated November 2, 1999, subject St. Lucie Unit 2 -

Amendment Request Regarding Safety Injection Tank and Shutdown Cooling System Isolation Interlock Surveillances (TAC No. MA5619)."

C' RQVC "0

"TK'rP.eXR AR $br

\\5\\ #>t-e ff.Ai-s)

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 5 Page 6 SECTION NO.:

TlE:

TECHNICAL SPECIFICATIONS PAGE:

3/4.6 BASES ATTACHMENT 8 OF ADM-25.04 5 of 10 REVISION NO.:

CONTAINMENT SYSTEMS 2

ST. LUCIE UNIT 1 3/4.6 CONTAINMENT SYSTEMS (continued)

BASES (continued) 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS The OPERABILITY of the containment spray and cooling systems ensures that depressurization and cooling capability will be available to limit post-accident pressure and temperature In the containment to acceptable values. During a Design Basis Accident (DBA), at least two containment cooling trains or two containment spray trains, or one of each, is capable of maintaining the peak pressure and temperature within design limits. One containment spray train has the capability, In conjunction with the Spray Additive System, to remove iodine from the containment atmosphere and maintain concentrations below those assumed In the safety analyses. To ensure that these conditions can be met considering single-failure criteria, two spray trains and two cooling trains must be OPERABLE.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action Interval specified in ACTION.a and ACTION 1.d, and the 7 day action Interval specified In ACTION 1.b take into account the redundant heat removal capability and the Iodine removal capability of the remaining operable systems, and the low probability of a DBA occurring during this period. The 10 day constraint for ACTIONS 1.a and 1.b is based on coincident entry Into two ACTION conditions (specified In ACTION.c) coupled with the low probability of an accident occurring during this time. If the system(s) cannot be restored to OPERABLE status within the specified completion time, alternate actions are designed to bring the unit to a mode for which the LCO does not apply. The extended interval (54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />) specified In ACTION l.a to be in MODE 4 Includes 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of additional time for restoration of the Inoperable CS train, and takes Into consideration the reduced driving force for a release of radioactive material from the RCS when In MODE 3. With two containment spray trains or any combination of three or more containment spray and containment cooling trains Inoperable In MODES 1, 2, or Mode 3 with Pressurizer Pressure > 1750 psia, the unit Is In a condition outside the accident analyses and LCO 3.0.3 must be entered Immediately. In MODE 3 with Pressurizer Pressure < 1750 psia, containment spray Is not required.

The specifications and bases for LCO 3.6.2.1 are consistent with NUREG-1432, Revision 0 (9/28/92), Specification 3.6.6A (Containment Spray and Cooling Systems; Credit taken for iodine removal by the Containment Spray System), and the plant safety analyses.

(ASer-4 3

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 5 Page 7 SECTION NO.:

TITLE:

TECHNICAL SPECIFICATIONS PAGE:

3/4.6 BASES ATTACHMENT 8 OF ADM-25.04 6 of 12 REVISION NO.:

CONTAINMENT SYSTEMS 4

ST. LUCIE UNIT 2 314.6 CONTAINMENT SYSTEMS (continued)

BASES (continued) 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS The OPERABILITY of the containment spray and cooling systems ensures that depressurization and cooling capability will be available to limit post-accident pressure and temperature In the containment to acceptable values. During a Design Basis Accident (DBA), at least two containment cooling trains or two containment spray trains, or one of each, Is capable of maintaining the peak pressure and temperature within design limits. One containment spray train has the capability, In conjunction with the Iodine Removal System, to remove Iodine from the containment atmosphere and maintain concentrations below those assumed In the safety analyses. To ensure that these conditions can be met considering single-failure criteria, two spray trains and two cooling trains must be OPERABLE.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action Interval specified in ACTION 1.a and ACTION 1.d, and the 7 day action Interval specified In ACTION 1.b take Into account the redundant heat removal capability and the Iodine removal capability of the remaining operable systems, and the low probability of a DBA occurring during this period. The 10 day constraint for ACTIONS 1.a and 1.b Is based on coincident entry Into two ACTION conditions (specified In ACTION 1.c) coupled with the low probability of an accident occurring during this time. If the system(s) cannot be restored to OPERABLE status within the specified completion time, alternate actions are designed to bring the unit to a mode for which the LCO does not apply. The extended Interval (54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />) specified In ACTION 1.a to be In MODE 4 Includes 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of additional time for restoration of the Inoperable CS train, and takes Into consideration the reduced driving force for a release of radioactive material from the RCS when In MODE 3. With two containment spray trains or any combination of three or more containment spray and containment cooling trains Inoperable In MODES 1, 2, or Mode 3 with Pressurizer Pressure > 1750 psia, the unit Is In a condition outside the accident analyses and LCO 3.0.3 must be entered Immediately. In MODE 3 with Pressurizer Pressure < 1750 psia, containment spray Is not required.

The specifications and bases for LCO 3.6.2.1 are consistent with NUREG-1432, Revision 0 (9128/92), Specification 3.6.6A (Containment Spray and Cooling Systems; Credit taken from Iodine removal by the Containment Spray System), and the plant safety analyses.

St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2003-217 Attachment 5 Page 8 Insert I Ensuring that the BAM pump discharge pressure is met satisfies the periodic surveillance requirement to detect gross degradation caused by impeller structural damage or other hydraulic component problems. Along with this requirement,Section XI of the ASME Code verifies the pump developed head at one point of the pump characteristic curve to verify both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis. Surveillance Requirements are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements.

Insert 2 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis. Surveillance Requirements are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements.

Insert 3 Ensuring that the containment spray pump discharge pressure is met satisfies the periodic surveillance requirement to detect gross degradation caused by impeller structural damage or other hydraulic component problems. Along with this requirement,Section XI of the ASME Code verifies the pump developed head at one point of the pump characteristic curve to verify both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis. Surveillance Requirements are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements.