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Category:Letter type:L
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0 July 25, 2014 FPL. L-2014-239 10 CFR 50.91 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 Clarification Regarding License Amendment Request for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process - (TAC NOS. MF3618, MF3619)
References:
I. 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 I & 2 Technical Specifications Changes Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process (TAC NOS. MF3618, MF3619), ADAMS accession number ML14121A281.
- 3. FPL Letter L-2014-144 dated May 29, 2014, "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)," ADAMS accession number ML14161A145.
Following Florida Power & Light Company's (FPL's) February 26, 2014, submittal of the Reference I License Amendment Request (LAR), the NRC issued the Reference 2 Request for Additional Information (RAI) seeking clarification of certain aspects of the Reference 1 LAR.
FPL responded to the Reference 2 RAI on May 29, 2014 (Reference 3).
After further discussion with the NRC regarding FPL's proposed Surveillance Requirement 4.0.1, FPL is now providing the revised Insert 10 from Reference 3, as well as the word-processed Technical Specification changes, in the Attachment to this letter in order to facilitate the NRC's continued review of the Reference 1 LAR.
Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
L-2014-239 Page 2 If you should have any questions regarding this submittal, please contact Mr. Eric Katzman, Licensing Manager at 772-467-7734.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the __ day of July, 2014.
Sincerely, oseph Jen Site Vice President St. Lucie Plant Attachment cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Units I and 2 Ms. Cynthia Becker, Florida Department of Health
L-2014-239 Attachment Page 1 of 3 Revised INSERT 10 (SR 4.0.1) (Reference 1)
Surveillance Requirements shall be met during the OPERATIONAL MODES or other specified conditions in the Applicability 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.
Reference:
- 1. FPL Letter L-2014-144 dated May 29, 2014, "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)," ADAMS accession number ML14161A145
L-2014-239 Attachment Page 2 of 3 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other specified conditions in the Applicability 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 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, G, 08, 408.*463,4-6
L-2014-239 Attachment Page 3 of 3 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other specified conditions in the Applicability 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 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 2 314 0-2 Amendment No. ,33,48, 144,4-29