L-2015-015, Response to Request for Additional Information Regarding License Amendment Request to Permanently Extend the Integrated Leak Rate Test (ILRT) Frequency to 15 Years (MF4694 and MF4695)

Response to Request for Additional Information Regarding License Amendment Request to Permanently Extend the Integrated Leak Rate Test (ILRT) Frequency to 15 Years (MF4694 and MF4695)

ML15029A496
Person / Time
Site:	Saint Lucie
Issue date:	01/14/2015
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2015-015, TAC MF4694, TAC MF4695
Download: ML15029A496 (10)

Text

January 14, 2015 FPL L-2015-015 10 CFR 50.90 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: St. Lucie Units 1 and 2 Dockets Nos. 50-335 and 50-389 Response to Request for Additional Information (RAI) Regarding License Amendment Request to Permanently Extend the Integrated Leak Rate Test (ILRT) Frequency to 15 Years (MF4694 AND MF4695)

References:

1. FPL letter L-2014-230 dated August 26, 2014: St. Lucie Plant - Application for Technical Specifications Change to Permanently Extend the Integrated Leak Rate Test (ILRT) Frequency to 15 Years (ADAMS Accession No. ML14241A496)

2. NRC letter dated December 18, 2014: Request for Additional Information RAI Regarding to LAR for a Permanent Extension to the Containment Type A Leak Rate Testing License Amendment Request for a Permanent Extension to the Containment Type A Leak Rate Testing (MF4694 AND MF4695) (ADAMS Accession No. ML14356A147)

Per Reference 1 above, Florida Power & Light Company (FPL) requested an amendment to the Renewed Facility Operating Licenses for St. Lucie Unit 1 and Unit 2.

The license amendment request (LAR) would modify the St. Lucie Units 1 and 2 Technical Specifications to permanently extend the frequency of the containment integrated leak rate test (ILRT) from once per 10 years to once per 15 years.

By letter dated December 18, 2014 (Reference 2), NRC staff requested additional information regarding the LAR. The enclosure and attachments to this letter provide a detailed response to a request for additional information (RAI) from the Containment and Ventilation Branch (SCVB).

The information provided in this submittal does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in FPL letter L-2014-230.

This submittal makes no new commitments or changes to existing commitments.

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

Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

Page 2 L-2015-015 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January .14, 2015.

Respectfully submitted, St. Lucie Nuclear Plant

Enclosure:

1. St. Lucie Units 1 and 2 ILRT LAR RAI Response Attachments:

1. Unit 1 Technical Specifications Markup

2. Unit 2 Technical Specifications Markup cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Units 1 and 2 USNRC Project Manager, St. Lucie Units 1 and 2 Ms. Cindy Becker, Florida Department of Health

Enclosure 1 to L-2015-015 Page 1 of 2 Enclosure I St. Lucie Units I and 2 ILRT LAR RAI Response Response to Request for Additional Information (RAI) Regarding License Amendment Request to Permanently Extend the Integrated Leak Rate Test (ILRT)

Frequency to 15 Years (MF4694 AND MF4695)

SCVB RAI 1

Enclosure 1 to L-2015-015 Page 2 of 2 SCVB RAI 1 10 CFR 50 Appendix J, Option B Implementation item #3 states that:

The regulatory guide or other implementation document used by a licensee or applicant for an operating license under this part or a combined license under part 52 of this chapter to develop a performance-based leakage-testing program must be included, by general reference, in the plant technical specifications.

In addition, in the August 20, 2013 letter from NRC to Nuclear Energy Institute (NEI) (ADAMS Accession no. ML13192A394) (Reference 2), the staff indicated that:

Due to the omission of the limitations and conditions from NEI 94-01, Revision 2 SE into NEI 94-01, Revision 3-A, the NRC will not be able to reference NEI 94-01, Revision 3-A in the update to RG 1.163. Any licensee submissions referencing the TR [Technical Report] will require requests for additional information from the NRC to address the limitations and conditions from the NRC SE for NEI 94-01, Revision 2.

In the enclosure to the submittal dated August 26, 2014, Section 2.0, "Detailed Description,"

changes to the proposed TS 6.8.4.h for Units 1 and 2, included a reference to Nuclear Energy Institute, NEI 94-01, Revision 3-A. However, the conditions and limitations contained in NEI 94-01, Revision 2-A, were not incorporated in NEI 94-01, Revision 3-A.

Explain how the 10 CFR 50 Appendix J, Option B Implementation item #3 and NRC concerns stated in the August 20, 2013 letter from NRC to NEI will be addressed.

REFERENCES

1. Florida Power & Light Company letter to NRC dated August 26, 2014 "St Lucie Nuclear Plant Docket Nos. 50-335 and 50-389 LAR Application for TSs Change to Permanently Extend the ILRT Frequency to 15 Years" (ADAMS Accession Number ML14241A496).

2. NRC letter to Biff Bradley (Director, Nuclear Energy Institute), dated August 20, 2013, "REQUEST REVISION TO TOPICAL REPORT NEI 94-01, REVISION 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR PART 50, Appendix J", (ADAMS Accession Number ML13192A394).

RESPONSE

Florida Power & Light Company proposes to change the reference in Unit 1 and Unit 2 Technical Specification (TS) 6.8.4.h from NEI 94-01, Revision 3-A to NEI 94-01, Revision 2-A as shown in Attachments 1 and 2 for Unit 1 and Unit 2, respectively. (The markup for Unit 2 TS 6.8.4.h contains an editorial correction that was proposed in the application.) The limitations and conditions contained in NEI 94-01, Revision 2 (i.e., Revision 2-A) are addressed in the application.

Attachment 1 to L-2015-015 Page 1 of 3 Attachment 1 Unit I Technical Specifications Markup

Attachment 1 to L-2015-015 Page 2 of 3 Unit 1 Technical Specifications Insert Insert A NEI 94-01, Revision 2-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," except that the next Type A test performed after the December 8, 2005 Type A test shall be performed no later than December 8, 2020.

Attachment 1 to L-2015-015 Page 3 of 3 ADMINISTRATIVE CONTROLS (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following:

1) Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM.

2) A Land Use Census to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the monitoring program are made if required by the results of this census, and

3) Participation in a Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring.

h. Containment Leakage Rate Testing Program A program to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50 Appendix J, Option B, as modified by approved exemptions. This program is in accordance with the INu Lguidelnes containe R . .. 1.163, "P.. form.anc. Based

-MtLeak1 et Pregram,' as moedified by the follow-ming exccptien(s}-.

a-) Be-htet-T-epiea-Rep e*-,-BN-T-OP-I-efANS-568-1 ,$ -e e by.R-G.--1-.-1&)-w-3-ll-lbe-used-for-type-A4esMiRAg b) .,-T-h,-fir-t-Type-A-test-peFfeormed-after-4he4e-My 1993-Type-A4est--,ha4-be-Re

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The peak calculated containment internal pressure for the design basis loss of coolant accident Pa, is 42.8 psig. The containment design pressure is 44 psig.

The maximum allowed containment leakage rate, La, at Pa, shall be 0.50% of containment air weight per day.

Leakage rate acceptance criteria are:

a. Containment leakage rate acceptance criterion is < 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests,

< 0.75 La for Type A tests, and < 0.096 La for secondary containment bypass leakage paths.

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate is < 0.05 La when tested at > Pa.

2) For the personnel air lock door seal, leakage rate is < 0.01 La when pressurized to > 1.0 Pa.

3) For the emergency air lock door seal, leakage rate is < 0.01 La when pressurized to > 10 psig.

ST LUCIE - UNIT 1 6-15b Amendment No. 6.9, 4-2-,

-1 44-9 447-, 4W, 2-N,-24

Attachment 2 to L-2015-015 Page 1 of 3 Attachment 2 Unit 2 Technical Specifications Markup

Attachment 2 to L-2015-015 Page 2 of 3 Unit 2 Technical Specifications Insert Insert B NEI 94-01, Revision 2-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," except that the next Type A test performed after the December 18, 2007 Type A test shall be performed no later than December 18, 2022.

Attachment 2 to L-2015-015 ADMINISTRATIVE CONTROLS Page 3 of 3 than 8 days in gaseous effluents released from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50,

10) Limitations on the annual dose or dose commitment to any MEMBER OF THE PUBLIC, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

The provisions of Specifications 4.0.2 and 4.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency.

g. Radiological Environmental Monitoring Pro qram A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of the environmental exposure pathways. The program shall (1) be contained in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following:

1) Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM.

2) A Land Use Census to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the monitoring program are made if required by the results of this census, and

3) Participation in a Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring.

h. Containment Leakage Rate Testing Program A program to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50 Appendix J, Option B, as modified by approved INSERT B -- exemptions. This program is in accordance with the guidelines contained in Regulater'y Guide 1.163, "Performnancc Based Containment Lealk Test Program,"

onediied by-Beehtel 1epie-a[Repe~fl N TOP 1 )F-ANS-56-.84994-(as Feeefnmnded- y-RG-A463 whieh.wil ,-be-used-fe pe A testng The peak calculated containment internal pressure for the design basis loss of coolant accident Pa, is 43.48 psig. The containment design pressure is 44 psig.

allowed]

The maximum *a4ew containment leakage rate, La, at Pa, shall be 0.50% of containment air weight per day.

ST. LUCIE - UNIT 2 6-15b Amendment No. 64 88, 4-0, 44.,

446,163