L-2015-034, Response to Requests for Additional Information (Rais) Regarding License Amendment Request to Adopt TSTF-426, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c (MF4631 and MF4632)
| ML15065A235 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/20/2015 |
| From: | Costanzo C Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2015-034, TAC MF4631, TAC MF4632 | |
| Download: ML15065A235 (10) | |
Text
0 February 20, 2015 FPL. L-2015-034 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 Requests for Additional Information (RAIs) Regarding License Amendment Request to Adopt TSTF-426, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c" (MF4631 and MF4632)
References:
- 1. FPL letter L-2014-160 dated August 7, 2014: St. Lucie Plant -Application to Revise Technical Specifications to Adopt TSTF-426, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c," Using the Consolidated Line Item Improvement Process (ADAMS Accession No. ML14225A630)
- 2. NRC letter dated January 16, 2015: RAIs Regarding St. Lucie Units 1 and 2 Requested Licensing Action to Adopt TSTF-426, Revision 5, "Revise or Add Actions To Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c" (MF4631 and MF4632) (ADAMS Accession No. ML15020A084)
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 (TSs) to provide a short Allowed Outage Time to restore an inoperable system for conditions under which the existing TSs require a plant shutdown, consistent with TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 -
RITSTF Initiatives 6b & 6c."
By letter dated January 16, 2015 (Reference 2), NRC staff requested additional information regarding the LAR. The enclosure and attachments to this letter address the requests for additional information (RAIs).
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-2014-160.
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-2015-034 I declare under penalty of perjury that the foregoing is true and correct.
Executed on February . 2015.
Respectfully submitted, 67kýý Christopher R. Costanzo Site Vice President St. Lucie Nuclear Plant
Enclosure:
St. Lucie Units 1 and 2 TSTF-426 LAR RAI Response Attachments: 1. Unit 1 Technical Specifications LCO 3.1.2.2 and Basis Pages
- 2. Unit 2 Technical Specifications LCO 3.1.2.2 and Basis Pages 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 to L-2015-034 Page 1 of 2 Enclosure St. Lucie Units I and 2 TSTF-426 LAR RAI Response Response to Requests for Additional Information (RAls) Regarding License Amendment Request to Adopt TSTF-426, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 -
RITSTF Initiatives 6b & 6c" (MF4631 and MF4632)
RAIl 1
RAI 2
RAI 3
Enclosure to L-2015-034 Page 2 of 2 RAI I Action a. of LCO 3.1.2.2, Boration Systems - Flow Paths - Operating differs between Units 1 and 2 in the fact that Unit 1 refers to LCO 3.1.1.2 but Unit 2 refers directly to the COLR. Since the difference in this action is not explained in the licensee LAR but the same modification is proposed for both units please explain the differences between units that result in the different actions for this LCO and any impact on the proposed changes that this difference may have.
RESPONSE
FPL is withdrawing its proposal to change LCO 3.1.2.2, Boration Systems - Flow Paths -
Operating and its corresponding Basis. LCO 3.1.2.2 and its corresponding Basis will remain unchanged as shown in Attachments 1 and 2 for Units 1 and 2, respectively.
RAI 2
Proposed Action b. of LCO 3.1.2.2, Boration Systems - Flow Paths - Operating includes a difference from the model SE dated May 30, 2013 (ML13036A381) that is not explained in the LAR. In the model SE a reduced level of defense in depth is retained by verification of the operability of the high pressure safety injection (HPSI) system and a pressurizer PORV and its associated block valve. In the proposed actions - for St. Lucie 1 on page 6 of 7 of Attachment 2 and for St. Lucie 2 on page 7 of 8 of Attachment 3 - only HPSI is verified operable. Please explain how you intend to ensure that at least one PORV and its associated block valve are also operable so that the proposed Action b. may fully meet the intent of the model SE for a reduced level of defense in depth.
RESPONSE
FPL is withdrawing its proposal to change LCO 3.1.2.2, Boration Systems - Flow Paths -
Operating and its corresponding Basis. LCO 3.1.2.2 and its corresponding Basis will remain unchanged as shown in Attachments 1 and 2 for Units 1 and 2, respectively.
RAI 3
The notes included with each units' proposed Action b. of LCO 3.1.2.2, Boration Systems - Flow Paths - Operating may create confusion since entrance into existing Action a. is predicated on two of three boron injection flow paths being inoperable. Currently Action a. allows "only one of the above required boron injection flow paths" to be operable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Therefore two of three boron injection flowpaths may be inoperable for any reason while in Action a." The proposed note indicates that the "action not applicable when second or third required boron injection flow path intentionally made inoperable." The proposed note conflicts with existing Action a. in that it infers that a second flow path may not be intentionally made inoperable for any reason. Each proposed bases statement insert indicates that "two required boron injection flow paths" may be inoperable "for any reason." Please propose a new note that mentions only a third train or discuss why the proposed note mentions a second train.
RESPONSE
FPL is withdrawing its proposal to change LCO 3.1.2.2, Boration Systems - Flow Paths -
Operating and its corresponding Basis. LCO 3.1.2.2 and its corresponding Basis will remain unchanged as shown in Attachments 1 and 2 for Units 1 and 2, respectively.
Attachment 1 to L-2015-034 Page 1 of 3 Attachment 1 Unit I Technical Specifications LCO 3.1.2.2 and Basis Pages
Attachment 1 to L-2015-034 Page 2 of 3 REACTIVITY CONTROL SYSTEMS NO CHANGES AS A RESULT FLOW PATHS - OPERATING OF TSTF-426 ADOPTION LIMITING CONDITION FOR OPERATION 3.1.2.2 At least two of the following three boron injection flow paths shall be OPERABLE:
- a. One flow path from the boric acid makeup tank(s) with the tank meeting Specification 3.1.2.8 part a) or b), via a boric acid makeup pump through a charging pump to the Reactor Coolant System.
- b. One flow path from the boric acid makeup tank(s) with the tank meeting Specification 3.1.2.8 part a) or b), via a gravity feed valve through a charging pump to the Reactor Coolant System.
- c. The flow path from the refueling water storage tank via a charging pump to the Reactor Coolant System.
OR At least two of the following three boron injection flow paths shall be OPERABLE:
- d. One flow path from each boric acid makeup tank with the combined tank contents meeting Specification 3.1.2.8 c),
via both boric acid makeup pumps through a charging pump to the Reactor Coolant System.
- e. One flow path from each boric acid makeup tank with the combined tank contents meeting Specification 3.1.2.8 c),
via both gravity feed valves through a charging pump to the Reactor Coolant System.
- f. The flow path from the refueling water storage tank, via a charging pump to the Reactor Coolant System.
APPLICABILITY: MODES 1, 2, 3 and 4.
ACTION:
With only one of the above required boron injection flow paths to the Reactor Coolant System OPERABLE, restore at least two boron injection flow paths to the Reactor Coolant System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or make the reactor subcritical within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and borate to a SHUTDOWN MARGIN equivalent to the requirements of Specification 3.1.1.2 at 200°F; restore at least two flow paths to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
ST. LUCIE - UNIT 1 3/4 1-10 Amendment No. 48, 86, 90, 94, 4-74, 213
Attachment 1 to L-2015-034 Page 3 of 3 FWTION NO.: TITLE: TECHNICAL SPECIFICATIONS PAGE:
3/4.1 BASES ATTACHMENT 3 OF ADM-25.04 6 of 10 REVISION NO.: REACTIVITY CONTROL SYSTEMS 4 ST. LUCIE UNIT 1 3/4.1 REACTIVITY CONTROL SYSTEMS (continued)
BASES (continued) NO CHANGES AS A RESULT 3/4.1.2 BORATION SYSTEMS OF TSTF-426 ADOPTION The boron injection system ensures that negative reactivity control is available during each mode of facility operation. The components required to perform this function include 1) borated water sources,
- 2) charging pumps, 3) separate flow paths, 4) boric acid pumps, and
- 5) an emergency power supply from OPERABLE diesel generators.
With the RCS average temperature above 200 0 F, a minimum of two separate and redundant boron injection systems are provided to ensure single functional capability in the event an assumed failure renders one of the systems inoperable. Allowable out-of-service periods ensure that minor component repair or corrective action may be completed without undue risk to overall facility safety from injection system failures during the repair period.
The boration capability of either system is sufficient to provide a SHUTDOWN MARGIN from all operating conditions corresponding to the requirements of Specification 3.1.1.2 after xenon decay and cooldown to 200 0 F. The maximum boration capability requirement occurs at EOL from full power equilibrium xenon conditions. This requirement can be met for a range of boric acid concentrations in the Boric Acid Makeup Tanks (BAMTs) and Refueling Water Tank (RWT). This range is bounded by 6800 gallons of 3.5 weight percent (6119 ppm boron) boric acid from the BAMTs and 17,000 gallons of 1900 ppm borated water from the RWT to 8700 gallons of 3.0 weight percent (5245 ppm boron) boric acid from the BAMTs and 13,000 gallons of 1900 ppm borated water from the RWT.
A minimum of 45,000 gallons of 1900 ppm boron is required from the RWT if it is to be used to borate the RCS alone.
The requirements for a minimum contained volume of 401,800 gallons of borated water in the refueling water tank ensures the capability for borating the RCS to the desired level. The specified quantity of borated water is consistent with the ECCS requirements of Specification 3.5.4.
Therefore, the larger volume of borated water is specified here as well.
With the RCS temperature below 200 0 F, one injection system is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the additional restrictions prohibiting CORE ALTERATIONS and positive reactivity change in the event the single injection system becomes inoperable.
Attachment 2 to L-2015-034 Page 1 of 3 Attachment 2 Unit 2 Technical Specifications LCO 3.1.2.2 and Basis Pages
Attachment 2 to L-2015-034 Page 2 of 3 REACTIVITY CONTROL SYSTEMS NO CHANGES AS A RESULT FLOW PATHS - OPERATING OF TSTF-426 ADOPTION LIMITING CONDITION FOR OPERATION 3.1.2.2 At least two of the following three boron injection flow paths shall be OPERABLE:
- a. One flow path from the boric acid makeup tank(s) with the tank meeting Specification 3.1.2.8 part a) or b), via a boric acid makeup pump through a charging pump to the Reactor Coolant System.
- b. One flow path from the boric acid makeup tank(s) with the tank meeting Specification 3.1.2.8 part a) or b), via a gravity feed valve through a charging pump to the Reactor Coolant System.
- c. The flow path from the refueling water storage tank via a charging pump to the Reactor Coolant System.
OR At least two of the following three boron injection flow paths shall be OPERABLE:
- d. One flow path from each boric acid makeup tank with the combined tank contents meeting Specification 3.1.2.8 c), via both boric acid makeup pumps through a charging pump to the Reactor Coolant System.
- e. One flow path from each boric acid makeup tank with the combined tank contents meeting Specification 3.1.2.8 c), via both gravity feed valves through a charging pump to the Reactor Coolant System.
- f. The flow path from the refueling water storage tank, via a charging pump to the Reactor Coolant System.
APPLICABILITY: MODES 1, 2, 3 and 4.
ACTION:
With only one of the above required boron injection flow paths to the Reactor Coolant System OPERABLE, restore at least two boron injection flow paths to the Reactor Coolant System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to its COLR limit at 200 OF within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two flow paths to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
ST. LUCIE - UNIT 2 3/4 1-8 Amendment No. 8, 2-6, 40, 4-06, 163
Attachment 2 to L-2015-034 Page 3 of 3 SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PAGE:
3/4.1 BASES ATTACHMENT 3 OF ADM-25.04 6 of 10 REVISION NO.: REACTIVITY CONTROL SYSTEMS 6 ST. LUCIE UNIT 2 3/4.1 REACTIVITY CONTROL SYSTEMS (continued)
BASES (continued) NO CHANGES AS A RESULT 3/4.1.2 BORATION SYSTEMS OF TSTF-426 ADOPTION The boron injection system ensures that negative reactivity control is available during each mode of facility operation. The components required to perform this function include (1) borated water sources, (2) charging pumps, (3) separate flow paths, (4) boric acid makeup pumps, and (5) an emergency power supply from OPERABLE diesel generators.
With the RCS average temperature above 2000 F, a minimum of two separate and redundant boron injection systems are provided to ensure single functional capability in the event an assumed failure renders one of the systems inoperable. Allowable out-of-service periods ensure that minor component repair or corrective action may be completed without undue risk to overall facility safety from injection system failures during the repair period.
The boration capability of either system is sufficient to provide a SHUTDOWN MARGIN from expected operating conditions of the limit specified in the COLR after xenon decay and cooldown to 200 0 F. The maximum expected boration capability requirement occurs at EOL from full power equilibrium xenon conditions. This requirement can be met for a range of boric acid concentrations in the Boric Acid Makeup Tank (BAMT) and Refueling Water Tank (RWT). This range is bounded by 8,750 gallons of 3.1 weight percent (5420 ppm boron) from the BAMT and 10,492 gallons of 1900 ppm borated water from the RWT to 7,550 gallons of 3.5 weight percent (6119 ppm boron) boric acid from BAMT and 11,692 gallons of 1900 ppm borated water from the RWT. A minimum of 33,000 gallons of 1900 ppm boron is required from the RWT if it is to be used to borate the RCS alone. This volume requirement, however, is expected to always be bounded by the ECCS RWT volume requirements of Specification 3.5.4.
With the RCS temperature below 200OF one injection system is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the additional restrictions prohibiting CORE ALTERATIONS and positive reactivity changes in the event the single injection system becomes inoperable.