L-2014-144, Response to Request for Additional Information (RAI) Regarding License Amendment Request for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

Response to Request for Additional Information (RAI) Regarding License Amendment Request for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

ML14161A145
Person / Time
Site:	Saint Lucie
Issue date:	05/29/2014
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-144, TAC MF3618, TAC MF3619
Download: ML14161A145 (17)

Text

0FPL May 29, 2014 L-2014-144 10 CFR 50.91 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Response to Request for Additional Information (RAI) Regarding License Amendment Request for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process - (TAC NOS. MF3618, MF3619)

References:

1. FPL Letter L-2013-233 dated February 26, 2014, "Application for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process," ADAMS accession number ML14077A265

2. NRC Request for Additional Information (RAI) Related to St. Lucie Units 1 & 2 Technical Specifications Changes Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process (TAC NOS. MF3618, MF3619), ADAMS accession number ML14121A281 As a result of the Reference 1 License Amendment Request, the NRC requested additional information via Reference 2. Attachment 1 to this letter provides the FPL response to the NRC Request for Additional Information (RAI). Attachment 2 provides the marked up Technical Specifications (TSs), and Attachment 3 provides the word processed TSs.

The no significant hazard analyses submitted in Reference 1 remains bounding. 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.

If you should have any questions regarding this submittal, please contact Mr. Eric Katzman, Licensing Manager at 772-467-7734.

Aob(

Florida Power & Light Company (2 a

ý-(A(--f-6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2014-144 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 2-1"_ day of May, 2014.

Sincerely, Josep e Site Vice President St. Lucie Plant Attachment cc: Ms. Cynthia Becker, Florida Department of Health

L-2014-144 Attachment 1 Page 1 of 4 ATTACHMENT 1 Request for Additional Information (RAI) Related to St. Lucie Units 1 & 2 Technical Specifications Changes Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process (TAC NOS. MF3618, MF3619)

In its application (Agency Wide Document Access System Accession No: ML14077A265) dated February 26, 2014, Florida Power and Light (FPL) proposed to amend the St. Lucie Unit 1 and Unit 2 (St. Lucie) TS requirements for mode change limitations in LCO 3.0.4 and SR 4.0.4. The submittal stated that the changes are to be based on Nuclear Regulatory Commission (NRC) approved Industry /Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-359, Revision 9.

Regulatory Basis The availability of TSTF-359 for adoption by licensees announced in the Federal Register on April 4, 2003 (68 FR 16579) included a model application that provides the expected level of detail and content for an application to revise technical specifications regarding mode change limitations and adoption of a technical specification bases control program.

RAI # I - This request consists of two parts. First, TSTF-359, Revision 9 inserts for LCO 3.0.4 includes the provision that "The specification [LCO 3.0.4] shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit." FPL did not include this language in the proposed St.

Lucie LCO 3.0.4 despite the existence of a similar provision in current LCO 3.0.4: "This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION statements. Exceptions to these requirements are stated in individual specifications."

Secondly, by letter dated September 21, 2011, the TSTF Transmitted TSTF-529, Revision 0, "Clarify Use and Application Rules." By letter dated February 28, 2013 (ML13063A539), TSTF-529 was revised to reflect the discussions between the NRC and the TSTF at the October 16, 2012 public meeting to discuss the Traveler. TSTF-529, Revision 1 makes twelve changes.

The pertinent change to TSTF-359 corrects the punctuation in LCO 3.0.4.b for the LCO 3.0.4 ordered list, 3.0.4.a, 3.0.4.b and 3.0.4.c, to ensure proper use and application of LCO 3.0.4.

This punctuation change is preferred over the FPL proposed change and would be consistent with STS changes the staff is processing under TSTF-529.

The staff requests FPL revise the St. Lucie 1 & 2 mode change limitations LCO 3.0.4 to be consistent with TSTF-359, Revision 9 inserts, including the Bases, and with the proposed traveler TSTF-529, Revision 1 punctuation changes to LCO 3.0.4.b as shown in the markup below:

LCO 3.0.4 "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated Actions to be entered permit continued operation in that MODE or other specified condition in the Applicability for an unlimited period of time;

L-2014-144 Attachment 1 Page 2 of 4

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit."

Response

FPL has revised Insert 1 to LCO 3.0.4 to be consistent with TSTF-359, Revision 9 inserts and with the proposed traveler TSTF-529, Revision 1 punctuation changes to LCO 3.0.4.b as shown in the attached proposed Technical Specification pages. The proposed Technical Specification Bases did not require revision because they were already consistent with TSTF-359 inserts.

L-2014-144 Attachment 1 Page 3 of 4 RAI #2 -The staff has determined that adopting standard TS LCO 3.0.4 as Specification 3.0.4 and standard TS SR 4.0.4 as Specification 4.0.4 in accordance with TSTF-359, Revision 9 without adopting standard TS SR 3.0.1 as Specification 4.0.1 would result in non-conservative implementation of technical specifications due to language incongruences between standard TS SR 3.0.1 and Specification 4.0.1. Therefore, to establish a consistent licensing basis that would ensure the allowances of TSTF-359, Revision 9 are correctly implemented the staff requests FPL revise St. Lucie Units 1 & 2 technical specifications SR 4.0.1 to be equivalent to standard TS SR 3.0.1.

Evaluation Standard TS SR 3.0.1 requires Surveillance Requirements be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Standard TS SR 3.0.1 also includes the two following requirements:

Standard TS SR 3.0.1 Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.

Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Thus, standard TS SR 3.0.1 specifies failure to meet a Surveillance or failure to perform a Surveillance is failure to meet the LCO. Whereas, Specification 4.0.1 (shown below) specifies failure to perform a Surveillance Requirement is failure to meet the LCO:

SR 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. Surveillance Requirements do not have to be performed on inoperable equipment. [Emphasis added]

In accordance with TSTF-359, Revision 9 Specification 3.0.4 is revised to be implemented:

"When an LCO is not met, [...] [Emphasis added]. Thus, Specification 3.0.4 would apply for noncompliance with a LCO which according to Specification 4.0.1 occurs upon failure to perform a Surveillance Requirement, but not explicitly for any other reason of noncompliance.

Specification 4.0.4 requires:

L-2014-144 Attachment 1 Page 4 of 4 Entry into a MODE or other specified condition in the Applicability of a Limiting Condition for Operation (LCO) shall only be made when the LCO's Surveillances have been met within their specified frequency, except as provided by Surveillance Requirement 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

In accordance with TSTF-359, Revision 9 Specification 4.0.4 applies "When an LCO is not met due to Surveillances not having been met." Thus, Specification 4.0.4 would apply for noncompliance with a LCO which according to Specification 4.0.1 only occurs upon failure to perform a Surveillance Requirement, but not meet the Surveillance Requirement as the new Specification requires.

Therefore, to ensure the allowances of TSTF-359, Revision 9 are correctly implemented the staff requests FPL revise St. Lucie SR 4.0.1 to be equivalent to standard TS SR 3.0.1.

Response

FPL has revised SR 4.0.1 to be equivalent to standard TS SR 3.0.1 as shown in the proposed Technical Specification pages attached.

L-2014-144 Attachment 2 Page 1 of 6 TS Markups Unit 1 TS Page 314 0-1 Unit 1 TS Page 314 0-2 Unit 2 TS Page 3/4 0-1 Unit 1 TS Page 3/4 0-2

L-2014-144 Attachment 2 Page 2 of 6 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation (LCO) contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation (LCO) and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation (LCO) is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which specification does not apply by placing it, as applicable in:

1. 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 />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the LCO. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODES 5 or 6.

3 ntry into anOPERATIONAL MODE or other specified applicability condition shall not be made when the conditions of the Limiting Condition for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION statements. Exceptions to these requirements are stated in the individual specifications.

VcCL-,7  %,'-\*:5jEV- a-J ST. LUCIE - UNIT 1 314 D-1 Amendment No. 40, 98, 103

L-2014-144 Attachment 2 Page 3 of 6 APPLICABILITY

,SURVEILLANCE RELiJIREMJEK1$NS = =

4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. Surveillance Requirements do not have to be performed on ino erabte --

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken. R.ple.P tqc--- Wi. 5 2,_

4.0.4 ntry into anOPERATIONAL MODE or other specified applicability condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (i).

b. deleted ST. LUCIE - UNIT 1 3/4 0.2 Amendment No. 26, 40, 90. 98,

.108,463,186

L-2014-144 Attachment 2 Page 4 of 6 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 314.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0,2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and/or associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, action shall be initiated to place the unit in a MODE in which specification does not apply by placing it, as applicable, in:

1. 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 />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the Individual specifications.

This specification is not applicable in MODE 5 or 6.

3.0. ntry into an OPERATIONAL MODE or other specified condition s-halt-n-e made when the conditions of the Limiting Condition for Operation are not met and the associated ACTION requires a shutdown ifthey are not met within a specified time interval. Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time, This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION statements. Exceptions to these requirements re stated in the individual specifications.

• ..e* _C

• L' i*N,

• ,C _. .\ 'I ST LUCIE - UNIT 2 3/4 0-1 Amendment No. 33 corrected

L-2014-144 Attachment 2 Page 5 of 6 APPLICABILITY aURVEILLANCEREQJ*IJREMENI' 3 __ /

4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to perform a Surveillance Requirement within the allowable surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. Surveillance Requirements do not have to be pefformed on inoperableS

[equipment.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken. R*R c-p-e " -

4.0.4 Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (i).

b. deleted c, deleted ST. LUCIE - UNIT 2 3/4 0.2 Amendmenr No. 33. 48, 91, 129

L-2014-144 Attachment 2 Page 6 of 6 INSERT 1 for LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

INSERT 2 for SR 4.0.4 Entry into a MODE or other specified condition in the Applicability of a Limiting Condition for Operation (LCO) shall only be made when the LCO's Surveillances have been met within their specified frequency, except as provided by Surveillance Requirement 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

INSERT 10 for SR 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance Requirement or between performances of the Surveillance Requirement, shall be failure to meet the LCO. Failure to perform a Surveillance Requirement within the allowed surveillance interval shall be failure to meet the LCO except as provided in SR 4.0.3. Surveillance Requirements do not have to be performed on inoperable equipment or variables outside specified limits.

L-2014-144 Attachment 3 Page 1 of 5 Word Processed TSs Unit 1 TS Page 3/4 0-1 Unit 1 TS Page 3/4 0-2 Unit 2 TS Page 3/4 0-1 Unit I TS Page 314 0-2

L-2014-144 Attachment 3 Page 2 of 5 314 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 314.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation (LCO) contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation (LCO) and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation (LCO) is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which specification does not apply by placing it, as applicable in:

1. 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 />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the LCO. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODES 5 or 6.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

ST. LUCIE - UNIT 1 314 0-1 Amendment No. 40, 9,4403

L-2014-144 Attachment 3 Page 3 of 5 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance Requirement or between performances of the Surveillance Requirement, shall be failure to meet the LCO. Failure to perform a Surveillance Requirement within the allowed surveillance interval shall be failure to meet the LCO except as provided in SR 4.0.3. Surveillance Requirements do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.

4.0.4 Entry into a MODE or other specified condition in the Applicability of a Limiting Condition for Operation (LCO) shall only be made when the LCO's Surveillances have been met within their specified frequency, except as provided by Surveillance Requirement 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

4.0.5 Surveillance Requirements for inservice inspection of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1,2 and 3 components shall be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (i).

b. deleted ST. LUCIE - UNIT 1 3/4 0-2 Amendment No. 26, 40, 99,98, 409, 48, 4684

L-2014-144 Attachment 3 Page 4 of 5 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and/or associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, action shall be initiated to place the unit in a MODE in which specification does not apply by placing it, as applicable, in:

1. 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 />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

ST. LUCIE - UNIT 2 3/4 0-1 Amendment No. 33,GOFFeeted

L-2014-144 Attachment 3 Page 5 of 5 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance Requirement or between performances of the Surveillance Requirement, shall be failure to meet the LCO.

Failure to perform a Surveillance Requirement within the allowed surveillance interval shall be failure to meet the LCO except as provided in SR 4.0.3. Surveillance Requirements do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.

4.0.4 Entry into a MODE or other specified condition in the Applicability of a Limiting Condition for Operation (LCO) shall only be made when the LCO's Surveillances have been met within their specified frequency, except as provided by Surveillance Requirement 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

4.0.5 Surveillance Requirements for inservice inspection of ASME Code Class 1,2 and 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (i).

b. deleted

c. deleted ST. LUCIE - UNIT 2 3/4 0-2 Amendment No. 33, 48,94, 429