L-2008-121, Request for Additional Information Response, Alternative Source Term Amendment

Request for Additional Information Response, Alternative Source Term Amendment

ML081560252
Person / Time
Site:	Saint Lucie
Issue date:	06/02/2008
From:	Johnston G Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2008-121, TAC MD6173, TAC MD6202
Download: ML081560252 (21)

Text

Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 June 2, 2008 L-2008-121 F=PL 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC Nos. MD6173 and MD6202 On July 16, 2007, Florida Power and Light Company (FPL) submitted the St. Lucie Unit 1 and 2 Alternative Source Term (AST) license amendment requests via FPL letters L-2007-085 and L-2007-087. On January 29, 2008, the NRC docketed a Request for Additional Information (RAI) for the control room outside air intake (CROAI) isolation setpoint. On February 14, 2008, FPL responded to the NRC RAI concerning the CROAI isolation setpoint via FPL letter L-2008-022. to this correspondence provides closure on the open items contained in letter L-2008-022. The no significant hazard analyses submitted with FPL letter L-2007-087 required revision to account for the proposed change in the existing Unit 2 CROAI setpoint and is included in Attachment 2. The Unit 1 no significant hazard analyses submitted in letter L-2008-085 remains bounding so no change was required. Attachment 3 provides the TS markups, provides the word processed TS changes, and Attachment 5 provides an informational copy of the proposed TS Bases changes.

In accordance with the FPL Quality Assurance Topical Report, this RAI followup response was reviewed by the St. Lucie Onsite Review Group. In accordance with 10 CFR 50.91(b)(1), a copy of the proposed amendment was forwarded to the State Designee for the State of Florida.

Please contact Ken Frehafer at 772-467-7748 if there are any questions about this submittal.

an FPL Group company

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC Nos. MD6173 and MD6202 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the ______

day of

^--e 2008.

Very truly yours, L-2008-121 Page 2 GLJ/KWF Attachment cc: Mr. William A. Passetti, Florida Department of Health

St. Lucie Units 1 and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 1 of 3 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 In the FPL response, letter L-2008-022 dated February 14, 2008, to the NRC RAI dated January 29, 2008, the following open items were left for closure.

1. FPL was to provide the setpoint methodology for the control room outside air intake (CROAI) radiation monitor isolation setpoint.

2. FPL was to provide the TS markups showing the new setpoint.

3. FPL was to provide TS Bases markups.

FPL provides the following information to close these open items.

1.0 Setpoint Methodology This methodology is applicable to the CROAI isolation setpoints for the St. Lucie Units 1 and 2 control room emergency ventilation systems. The setpoint was determined consistent with the guidance provided in EPRI Technical Report TR-102644 "Calibration of Radiation Monitors at Nuclear Power Plants." As stated in TR-102644, the setpoint of a radiation monitor can be established in either of two ways:

• If there is a requirement for the radiation monitor to actuate an accident mitigation safety feature when the actual radioactivity reaches a specific concentration, then the monitor's actuation setpoint is established based on actual radioactivity.

" In other cases, requirements are based on the setpoint being as low as possible without causing spurious alarms. For this case the setpoint is typically established as a multiple of background (such as 8 times background).

Per Unit 1 UFSAR section 9.4.1.2, the existing Unit 1 CROAI radiation monitor setpoint (of approximately 320 cpm) is based on a Kr85 concentration of 2 x 10-6 jtci/cc. It appears that this setpoint was established in a manner consistent with the first of the two methods documented in TR-102644. However, the existing UFSAR setpoint basis is incomplete since: there is no clear link to a specific accident scenario or associated activity transport analysis, there is no allowance for uncertainty in the response of the radiation monitor, and the UFSAR count rate can not be substantiated via the radiation monitor sensitivity curve.

Per Unit 2 Technical Specification Table 3.3-6, the current Unit 2 CROAI radiation monitor setpoint is 2 times background, which would indicate that it was established in a manner consistent with the second of the two methods documented in TR-102644. It is also noted that Unit 2 has experienced spurious actuation of the Control Room Emergency Cleanup System, which appears to be, at least in part, caused by using a setpoint background multiplier that is too low (i.e., multiplier of 2 rather than 8).

St. Lucie Units 1 and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 2 of 3 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 As a result, the CROAI radiation monitor actuation setpoint design basis was re-created to determine a setpoint that is as low as possible without causing spurious alarms and will also ensure that automatic actuation will occur when the actual radioactivity reaches a concentration or equivalent count rate that is bounded by the accident analyses. The setpoint was determined using the following methodology:

1.

Calculate the radiation monitor response in counts per minute (cpm) for each event where automatic actuation of the control room emergency ventilation system credited.

2.

Establish a bounding total loop uncertainty value for the CROAI radiation monitor.

3.

Establish a proposed actuation setpoint in cpm.

4.

Confirm that the proposed setpoint will ensure that automatic actuation will occur for the limiting case (lowest activity) event after accounting for the bounding total loop uncertainty.

Using the above methodology, the proposed actuation setpoint was determined to be 320 cpm. This setpoint is based on the following assumptions/determinations:

1.

The total loop uncertainty was conservatively determined to be 100%. This value was then doubled and a bounding total loop uncertainty of 200% was assumed.

2.

With a total loop uncertainty of 200%, the upper bound for the proposed setpoint of 320 cpm is 960 cpm.

3.

The limiting case event is the Unit 1 Stuck Open MSSV event with a total radiation monitor count rate of 2.5 E+3 cpm.

4.

The limiting case event count rate exceeds the upper bound of the radiation monitor setpoint by a factor of 160%.

The St. Lucie TSs are custom TSs and do not conform to the Improved Standard Technical Specification (ISTS) format. To be consistent with the format established for.

all other area radiation monitors in Technical Specification Table 3.3-6, the CROAI Radiation Monitor Technical Specification setpoint will have an upper limit of 320 cpm and be formally shown as < 320 cpm. Again to be consistent with the St. Lucie conventions established for other area radiation monitors, the surveillance procedure setting tolerance will ensure that the as-left setting is conservative with respect to the Technical Specification setpoint limit. A setting tolerance range of 280 cpm to 320 cpm will be utilized, based on the existing CROAI radiation monitor surveillance procedure and the equipment accuracy. The method used to establish this setting tolerance range is consistent with standard St. Lucie practice, wherein the surveillance procedure setting tolerance is based on equipment accuracy.

In addition to the radiation monitor accuracy, a radiation monitor drift allowance of 12%

has also been accounted for in the setpoint determination. Based on this drift allowance, an as-found channel operability limit of 350 cpm will be captured in the surveillance procedures. If the as-found setting exceeds the nominal setpoint of 320 cpm but is less than the operability limit of 350 cpm, the setting will be restored to the nominal setpoint value. If the as-found sett!ng exceeds 350 cpm, the channel will be removed from service

St. Lucie Units 1 and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 3 of 3 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 and corrective actions will be taken in accordance with the Technical Specifications and the St. Lucie Corrective Action Program. Note that the concept of Allowable Value is not used in Technical Specification Table 3.3-6. The upper limit of 350 cpm is equivalent to the Allowable Value. As such, the implications of exceeding an Allowable Value with respect to channel operability are addressed in the preceding as-found discussion.

The proposed setpoint of < 320 cpm will ensure that automatic actuation of the control room ventilation system will occur for all applicable events with adequate margin for the bounding total loop uncertainty of 200%. The method used to determine the setpoint is consistent With the guidance provided in EPRI Technical Report TR-102644 in that it is as low as possible without causing spurious alarms and it will also ensure that automatic actuation will occur when the actual radioactivity reaches a concentration or equivalent count rate that is bounded by the accident analyses. The as-found and as-left limits are conservative with respect to the corresponding uncertainty allowances in the setpoint determination.

For both St. Lucie Units 1 and 2, FPL determined that a new TS surveillance is required to provide verification that the Control Room Isolation channel response time is within limits. These proposed surveillances are included in the marked up and word processed TS changes include in Attachments 3 and 4, and are consistent with the requirements found in the ISTSs. Because the addition of the new surveillance requirement is a more restrictive change to TS, the no significant hazards evaluations previously submitted bound the addition of the new TS surveillance requirements.

FPL also committed to changing the existing St. Lucie Unit 2 TS setpoint from < 2X background to the value determined from the CROAI setpoint methodology (< 320 cpm).

FPL determined that the new setpoint necessitates a revision to the no significant hazards evaluation previously submitted in letter L-2008-087. The revised no significant hazards evaluation for St. Lucie Unit 2 is provided in Attachment 2.

2.0 TS Changes Provided in Attachments 3 and 4 3.0 TS Bases Changes Provided in Attachment 5.

St. Lucie Units 1 and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 1 of 3 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 Revised St. Lucie Unit 2 No Significant Hazards Determination The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazard 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, or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in the margin of safety. FPL has reviewed this proposed license amendment for FPL's St. Lucie Unit No. 2 and determined that its adaptation would not involve a significant hazards determination. The bases for this determination are:

This proposed change does not involve a significant hazards consideration for the following reasons:

1. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Alternative source term calculations have been performed for St. Lucie Unit 2 which demonstrate that the dose consequences remain below limits specified in NRC Regulatory Guide 1.183 and 10 CFR 50.67. The proposed changes modify the setpoint for Control Room Isolation radiation monitoring instrumentation and add a new surveillance requirement. Control Room Isolation radiation monitoring instrumentation does not adversely affect accident initiators or precursors or prevent the ability of structures, systems, and components to perform their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The modified setpoint and new surveillance requirement will ensure that the Control Room is isolated within the limits assumed in the AST analysis. The use of the AST only changes the regulatory assumptions regarding the analytical treatment of the design basis accidents and has no direct effect on the probability of any accident. The AST has been utilized in the analysis of the limiting design basis accidents listed above. The results of the analyses, which include the proposed changes to the Technical Specifications, demonstrate that the dose consequences of these limiting events are all within the regulatory limits.

The proposed Technical Specification changes are consistent with, or more restrictive than, the current TS requirements, with the possible exception of the alarm/trip setpoint for Control Room Isolation radiation monitoring instrumentation. The current alarm/trip setpoint of < 2 times background is variable. A background reading of approximately 40 cpm is typical for the Control Room Isolation radiation monitors. It is possible that the background reading could increase to above 160 cpm. Revising the Control Room Isolation alarm/trip setpoint from < 2 times background to < 320 cpm will establish a maximum setpoint value and ensure automatic actuation of the control room emergency ventilation system for the limiting case event with adequate margin for the bounding total loop uncertainty of 200%. None of the affected systems, components or programs are related to accident initiators. As such, the

St. Lucie Units 1 and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 2 of 3 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 revised TS requirements can not affect the probability of an accident and can only reduce the consequences of analyzed accidents.

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

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Other than discussed below, the proposed change does not affect any plant structures, systems, or components. The operation of plant systems and equipment will not be affected by this proposed change. Neither implementation of the alternative source term methodology nor establishing more restrictive TS requirements have the capability to introduce any new failure mechanisms or cause any analyzed accident to progress in a different manner.

The proposed changes associated with the Control Room Isolation radiation monitoring instrumentation setpoint and new surveillance requirement are not accident initiators. These proposed changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a significant change in the methods governing normal plant operation. These changes do not alter any safety analysis assumptions and will not affect or degrade the ability of structures, systems, and components to perform their specified safety function.

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

3. The proposed amendment does not involve a significant reduction in the margin of safety.

The proposed implementation of the alternative source term methodology is consistent with NRC Regulatory Guide 1.183. The proposed Technical Specification changes are consistent with, or more restrictive than, the current TS requirements with the possible exception of the alarm/trip setpoint for Control Room Isolation radiation monitoring instrumentation. The current alarm/trip setpoint of < 2 times background is variable. A background reading of approximately 40 cpm is typical for the Control Room Isolation radiation monitors. It is possible that the background reading could increase to above 160 cpm. Revising the Control Room Isolation radiation monitoring instrumentation alarm/trip setpoint from < 2 times background to < 320 cpm will establish a maximum setpoint value and ensure automatic actuation of control room emergency ventilation system for the limiting case event with adequate margin for the bounding total loop uncertainty of 200%. These TS requirements support the AST revisions to the limiting design basis accidents. As such, the current plant margin of safety is preserved. Conservative methodologies, per the guidance of RG 1.183, have been used in performing the accident analyses. The radiological consequences of these accidents are all within the regulatory acceptance criteria associated with use of the alternative source term methodology.

St. Lucie Units 1 and 2 L-2008-121 Docket Nos..50-335 and 50-389 Attachment'2 Proposed License Amendment Page 3 of 3 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 The proposed changes continue to ensure that the doses at the exclusion area and low population zone boundaries and in the Control Room are within the corresponding regulatory limits of RG 1.183 and 10 CFR 50.67. The margin of safety for the radiological consequences of these accidents is considered to be that provided by meeting the applicable regulatory limits, which are set'at or below the 10 CFR 50.67 limits. An acceptable margin of safety is inherent in these limits.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above discussionlFPL has determined that the proposed change does not involve a significant hazards consideration.

Environmental Considerations 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment of an operating license for a facility requires no environmental assessment if the operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in a significant increase in individual or cumulative occupational radiation exposure. FPL has reviewed this proposed license amendment request and determined that the proposed amendment does not involve a significant hazards consideration, does not introduce any new effluents or significantly increase the quantities of existing effluents, and does not result in any physical plant changes or new surveillance that would significantly increase the cumulative occupational radiation exposure. Therefore the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 1 of 5 TS Mark Ups Ul Page 3/4 3-21 Page 3/4 3-22 U2 Page 3/4 3-24 Page 3/4 3-25

St. Lucie Units 1 and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 2 of 5 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 INSTRUMENTATION 314.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING LIMITING CONDITION FOR OPERATION 3.3,3.1 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm setpoints within the specified limits.

APPLICABILITY: As shown in Table 3.3-6.

ACTION:

a.

With a radiation monitoring channel alarm setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable.

b.

With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.

c.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4,3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations during the modes and at the frequencies shown in Table 4.3-3.

412At lease once per 18 months. each Control Room Isolation

~radiation monitoring instrumentation channel,,hall be demonstrated

\\X.0PFRABLE by verifying that the respon., time of the channel is within im i*

ST. LUCIE - UNIT 1 314 3-21 Amendment No. 40, 177

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 3 of 5 MINIMUM CHANNELS APPLICABLE ALARM MEASUREMENT OPERABLE MODES SETPOINT RANGE ACTION 1,

a. F e4 Storage Pool Area

• b.

.ontainment (CIs Containment Area - Hi Range

2.

PROCESS MONITORS

a. Containment i

Gaseous Activity RCS Leakage Detection ii, Particulate Activity RCS Leakage Detection

b. Fuel Storage Pool Area Ventilation System L Gaseous Activity ii. Particulate Activity 3

<16 mR/hr

<90mR/hr

1. 2,3,& 4 1lOR/hr 1I0"* - le0 msz~hr

.1-10 mRlhr 1-107 pjhr 13' 16 15 1

1.2.3&4 NotApplicable 10-_10cpm 1

1,2.3&4 Not Applicable 10 - 10 6 cpm 14 14 10,7 - 10 eCifcc 12 I - 106 CM 12 L

With fuel in the storage pool or building.

With recently irradiated fuel in the storage pool.

The Alarm Selpoints are determined and set in accordance with requirements of the Offsite Dose Calculation Manual.

During movement of recently irradiated fuel assemblies within containment.

ST. LUCIE - UNIT I 3,143-;22 Amendmert No. 59, $23,434, 197

St. Lucie Units 1 and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 4 of 5 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 INSTRUMENTATION 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING INSTRUMENTATION LIMITING CONDITON FOR OPERATION 3,3.311 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm/trip setpoints within the specified limits.

APPLICABIUTY: As shown in Table 3.3-6.

ACTION:

a.ý With a radiation monitoring channel alarm/trip setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable.

b.

With one or more radiation monitoring channelsl inoperable, take the ACTION shown in Table 3.3-6.

c.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.

ST. LUCIE - UNIT 2 3A4 3-24

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 5 of 5 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT

1.

AREA MONITORS a, Fuel Storage Pool Area I. Criticality and Ventilation System Isolation Monitor b, Containment Isolation

c. Control Room Isolation MINIMUM CHANNELS APPLICABLE OPERABLE MODES 4

3 1 per ALL MODES intake ALARMITRIP MEASUREMENT SETPOINT RANGE ACTION

20 mRfnr 10-' - 10 mR/hr 90go mR/hr 1-107 mR/hr 107 7 0 2 PCi/cc

d. Containment Area-Hi 1

1.2.,394 Not Applicable 1-10' R/hr Range

2.

PROCESS MONITORS

5320CPr4

a. Fuel Storage Pool Area Ventilation System I. Gaseous Activity 1

10"-

t10"2 RCitcC ii. Particulate Activity 1

1-10 6 cpm

b. Containment

i.

Gaseous Activity 1

1 2.3 4.

NotApplicable 107

- 2 RCS Leakage Detection

-10 Ci/cc i, Particulate Activity 1

1.2.3&4 Not Applicable 1

10 cpm RCS Leakage Detection With fuel in the storage pool or building.

During movement of recently irradiated fuel assemblies or during crane operations with loads over recently irradiated fuel assemblies in the spent fuel storage pool.

.. The Alarm/Trip Setpoints are determined and set in accordance with requirements of the Offsite Dose Calculation Manual, During movement of recently irradiated fuel assemblies within containment 22 25 26 27 24 24 23 23 ST. LUCIE - UNIT 2 X*4 3-25 Amemmet NO, 26, 61.139

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 1 of 5 WORD PROCESSED TS PAGES U1 Page 3/4 3-21 Page 3/4 3-22 U2 Page 3/4 3-24 Page 3/4 3-25

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 2 of 5 INSTRUMENTATION 314.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING LIMITING CONDITION FOR OPERATION 3.3.3.1 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm setpoints within the specified limits.

APPLICABILITY: As shown in Table 3.3-6.

ACTION:

a.

With a radiation monitoring channel alarm setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable.

b.

With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.

c.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHAN N EL FUNCTIONAL TEST operations during the modes and at the frequencies shown in Table 4.3-3.

4.3.3.2 At lease once per 18 months, each Control Room Isolation radiation monitoring instrumentation channel shall be demonstrated OPERABLE by verifying that the response time of the channel is within limits.

ST. LUCIE - UNIT 1 3/4 3-21 Amendment No. 40,4-T7

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 3 of 5 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION MINIMUM CHANNELS APPLICABLE OPERABLE MODES INSTRUMENT

1.

AREA MONITORS

a. Fuel Storage Pool Area

b. Containment (CIS)

c. Containment Area - Hi Range

d. Control Room Isolation

2.

PROCESS MONITORS a, Containment

i.

Gaseous Activity RCS Leakage Detection ii. Particulate Activity RCS Leakage Detection

b. Fuel Storage Pool Area Ventilation System

i.

Gaseous Activity ii. Particulate Activity ALARM SETPOINT 3

1

< 15 mR/hr

< 90 mR/hr 1,2,3,&4

< 10 R/hr MEASUREMENT RANGE 10" 1 - 104 mR/hr 1 -105 mR/hr 1-107 R/hr ACTION 13 16 15 17 14 14 1

ALL MODES

• 320 cpm 10 - 106 cpm 1

1,2, 3 & 4 Not Applicable 10-e106 cpm 1

1,2, 3 & 4 Not Applicable 10- 106 pm 1

1 10-7 _ 105 P.Ci/cc 12 1-106 cpm 12 With fuel in the storage pool or building.

With recently irradiated fuel in the storage pool.

The Alarm Setpoints are determined and set in accordance with requirements of the Offsite Dose Calculation Manual, During movement of recently irradiated fuel assemblies within containment.

ST. LUCIE - UNIT 1 3/4 3-22 Amendment No. 59.4=, 434, 1

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 4 of 5 INSTRUMENTATION 314.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.1 The radiation monitoring instrumentation channels shown in Table 3.3-6 shall be OPERABLE with their alarm/trip setpoints within the specified limits.

APPLICABILITY: As shown in Table 3.3-6.

ACTION:

a.

With a radiation monitoring channel alarr/trip setpoint exceeding the value shown in Table 3.3-6, adjust the setpoint to within the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or declare the channel inoperable.

b.

With one or more radiation monitoring channels inoperable, take the ACTION shown in Table 3.3-6.

c.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHAN N EL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.

4.3.3.2 At lease once per 18 months, each Control Room Isolation radiation monitoring instrumentation channel shall be demonstrated OPERABLE by verifying that the response time of the channel is within limits.

ST. LUCIE - UNIT 2 3/4 3-24

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 5 of 5 TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT

1. AREA MONITORS

a. Fuel Storage Pool Area

i.

Criticality and Ventilation System Isolation Monitor

b. Containment Isolation

c. Control Room Isolation MINIMUM CHANNELS APPLICABLE OPERABLE MODES 4

ALARM/TRIP MEASUREMENT SETPOINT RANGE

< 20 mR/hr 10m1-104 mR/hr A(

3 1 per intake

< 90 mR/hr 1 -107mR/hr ALL MODES

< 320 cpm 10 7 2 pCi/cc

d. Containment Area - Hi 1

1,2, 3 & 4 Not Applicable 1 - 10 R/hr Range

2.

PROCESS MONITORS

a. Fuel Storage Pool Area Ventilation System

i. Gaseous Activity 1

10-7 _ 10-2 p.Ci/cc ii. Particulate Activity 1

1 -106 cpm

b. Containment

i. Gaseous Activity 1

1,2, 3&4 NotApplicable 10 -10

ýtCi/cc RCS Leakage Detection ii. Particulate Activity 1

1.2, 3 & 4 Not Applicable 1 - 106 cpm RCS Leakage Detection With fuel in the storage pool or building.

During movement of recently irradiated fuel assemblies or during crane operations with loads over recently irradiated fuel assemblies in the spent fuel storage pool.

The Alarm/Trip Setpoints are determined and set in accordance with requirements of the Offsite Dose Calculation Manual.

During movement of recently irradiated fuel assemblies within containment.

CTION 22 25 26 27 24 24 23 23 ST. LUCIE - UNIT 2 3/4 3-25 Amendmet N.. 25, 61.439

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendment Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 L-2008-121 Page 1 of 3 Information Only TS Bases Mark Ups

St. Lucie Units I and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 2 of 3 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 SECTION NO.'.

TITLE, TECHNICAL SPECIFICATIONS::

PAGE:

314.3 BASES ATTACHMENT 5 OF ADM-25.04 4 of 5 REVISION NO.:

INSTRUMENTATION 1

ST. LUCIE UNIT 1 314.3 INSTRUMENTATION (continued)

BASES (continued) 314.3.1 and 314.3.2 (continued)

The CEOG topical report and FPL evaluation only cover certain sensor model numbers. If sensors are replaced with types not previously evaluated, then periodic response time testing (RTT) for the new sensor must either be performed and the appropriate changes made to plant procedures, or an additional request for RTT elimination must be submitted and approved by the NRC. If, however, the replacement sensor is one for which RTT elimination has been approved, then FPL may modify the plant procedures, using an allocated response time based upon a vendor-supplied response time value, or upon statistical analysis of historical data for that transmitter type and model.

The Safety Injection Actuation Signal (SIAS) provides direct actuation of the Containment Isolation Signal (CIS) to ensure containment isolation in the event of a small break LOCA.

314.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION The OPERABILITY of the radiation monitoring channels ensures that 1) the radiation levels are continually measured in the areas served by the individual channels; and (2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded; and (3) sufficientinformation is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident,"

December 1980 and NUREG-0737, "Clarification of TMI Action Plan Requirements," N or 314.3.3.2 Deleted 314.3.3.3 Deleted actuation response times are less than the maximum times 3/4.3.3.4 Deleted devices. which make up the bulk of the response time, is

St. Lucie Units 1 and 2 L-2008-121 Docket Nos. 50-335 and 50-389 Proposed License Amendment Page 3 of 3 Request for Additional Information Response Alternative Source Term Amendment - TAC No. MD6173 and MD 6202 SECT.

NO:

TtILE TECHNICAL SPECIFICATIONS PAGE 3/4.3 BASES ATTACHMENT 5 OF ADM-25.04 5 of 6 REVISION NO,:

INSTRUMENTATION 1

ST. LUCIE UNIT 2 314.3 INSTRUMENTATION (continued)

BASES (continued) 3/4.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION The OPERABILITY of the radiation monitoring channels ensures that: (1) the radiation levels are continually measured in the areas served by the individual channels; and (2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded; and (3) sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident,' December 1980 and NUREG-0737, "Clarification of TMI Action Plan Requirements," November 1980.

3/4.3.3.2 DEI kEXEC 314.3.3.3 DE TED 314.3.3.4 DEL ED 314.3.3.5 RE TOE SHUTDOWN INSTRUMENTATION The PERABILITY of the remote shutdown.instrumentation ensures that suffi ient capability is available to permit shutdown and maintenance of:

HO STANDBY of the facility from locations outside of the control room.

This capability is required in -the event control room habitability is lost and is con istent with General Design Criteria 19 of 10 CFR 50.

The OPERABILITY of the remote shutdown system instrumentation ensures that a fire will not preclude achieving safe shutdown. The remote shutdown sys m instrumentation, control circuits, and transfer switches are Ind, pendent of areas where a fire could damage systems normally used to shu down the reactor. This capability is consistent with General Design Surveillance Requirement 4.3.3 ).2 ensures that the cbannel actuation rOCd pns "insaels hntemxintmsasmdi h

anayse. estng f he ina atuain dejce ' whch ak upth