Text

Exigent Technical Specification Amendment Request RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG
	ML19205A407
Person / Time
Site:	Saint Lucie
Issue date:	07/24/2019
From:	Deboer D; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2019-149
	Download: ML19205A407 (24)
	v • d • e

JUL 2 4 2019 L-2019-149 10 CFR 50.90 10 CFR 50.91 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 RE: St. Lucie Unit 1 Docket Nos. 50-335 Renewed Facility Operating Licenses DPR-67

Subject:

Exigent Technical Specification Amendment Request RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG

Reference:

1. FPL Letter L-2019-147 dated July 19, 2019, "Exigent Technical Specification Amendment Request One-Time Allowed Outage Time Extension for Inoperable EDG." ADAMS Accession No. ML19200A283

2. NRC SER dated July 2, 2019, St. Lucie Plant, Unit Nos . 1and2 - Issuance of Amendment Nos. 247 and 199 Regarding Adoption of Risk-Informed Completion Times in Technical Specifications ADAMS Accession No. ML19113A099 In the Reference 1, FPL submitted an exigent request for an amendment to Facility Operating License No. DPR-67 for St. Lucie Unit 1 for Nuclear Regulatoiy Commission (NRC) approval.

FPL requested a change in the allowed outage time (AOT) for an inoperable emergency diesel generator (EDG). The current AOT allowed by Technical Specification (TS) 3/4.8.1 Action bis 14 days. FPL is requesting a one-time AOT extension for a total of 30 days.

On July 22, 2019, a teleconference was held between the NRC and FPL to discuss clarifications the Staff required to complete their review. FPL captured these requests and this correspondence provides responses to the NRC's questions in attachment 1. Additionally, satisfying the request to include the compensatory action commitments within the proposed TS required changes to the proposed TS changes. Attachment 2 provides a markup of the affected TS, and Attachment 3 provides the word processed TS change. Additionally, in order to minimize risk, consistent *with defense-in-depth philosophy, FPL is also requesting to suspend monthly testing of EDGs 1A, 2A, and 2B per TS surveillance requirements (SRs) 4.8. i.1.2.a.1, 4.8.1.1.2.a.2, 4.8 .1.1.2.a.3, 4.8.1.1.2.a.5, 4.8.1.1.2.a.6, 4.8.1.1.2.b.1, and 4.8.1.1.2.c. for the duration of the proposed extended AOT. The suspended surveillance testing of ED Gs 1A, 2A, and 2B will resume and be completed within seven days of the planned expiration of the extended AOT. These TS changes are also reflected in attachments 2 and 3.

Note that although the proposed TS includes reference to the Risk Informed Completion Time program, the RICT requirements will remain under administrative hold pending full implementation of the RICT amendment of Reference 2.

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

L-2019-149 Page2 The St. Lucie Onsite Review Group reviewed this submittal and concluded that operation of St.

Lucie Unit 1 in accordance with the proposed change will not endanger the health and safety of the public. The LAR justification and the exigent nature of the request remain unchanged. The responses to the RAis and revisions to the proposed TS changes do not affect the conclusions of the No Significant Hazards Consideration evaluation provided in Reference 1.

Additionally, in accordance with 10 CFR 50.91(b)(1), FPL is sending a copy of this letter and enclosure to the Florida Department of Health.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on JUL 2 4 2019 Respectfully,

!J~u~

DanDeBoer St. Lucie Nuclear Plant Site Director cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - St. Lucie Nuclear Plant NRC Project Manager - St. Lucie Nuclear Plant Director, Division of Radiological Health - Florida State Department of Health

L-2019-149 Attachment 1 Page 1of10 Defense in Depth Questions NRC Question: What Compensatory Measures will St. Lucie implement during the extended allowed outage time (AOT)?

Response

FPL commits to implementing the following compensatory measures du ring the extended AOT:

1. The availability of AAC power sources shall be checked every 8-12 hours (once per shift). If an alternate AC (AAC) power source (e.g., a Unit 2 emergency diesel generator (EDG)) becomes unavailable any time during extended AOT, the unit shall start shutting down within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. No elective load threatening tests or maintenance activities will be allowed (e.g., component testing or maintenance of safety systems and important non safety equipment in the offsite power systems which can increase the likelihood of a plant transient (unit trip or loss of offsite power (LOOP))).

3. Any other preplanned maintenance will be rescheduled if severe weather conditions are anticipated.

4. The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended AOT.

From the St. Lucie procedure that implements the Configuration Risk Management Program, the following risk management actions (RMAs) are required while in the extended AOT:

Conduct a plant fire protection walkdown of the areas that could impact EDG availability, offsite power availability, or the ability to use the SBO crosstie prior to entering the extended AOT.

Perform a thermographic examination of high risk potential ignition sources in the Cable Spreading Room and the Control Room prior to entering the extended AOT.

Restrict planned hot work in the Cable Spreading Room and Control Room during the extended AOT.

Establish a continuous fire watch in the Cable Spreading Room when in the extended AOT.

A Unit 2 EDG or the SBO crosstie shall only be removed from service for corrective maintenance required to ensure or restore operability of the equipment.

Ensure that the relevant Guarded Equipment protected train measures have been taken.

Validate availability of the minimum required fire detection and/or functional suppression systems in the identified important Fire Zones to be protected by plant procedures. If not met, then initiate fire watches in the affected zones in accordance with the Fire Protection Plan.

Brief operators and fire team members on the significance of a fire in the identified important fire zones to be protected .

In addition to the above compensatory measures, existing plant procedures address monitoring weather conditions, and ensuring that actions are taken in the event adverse conditions are expected on-site. These actions are relevant during severe weather, tornado, or hurricane watches or warnings and include housekeeping, flooding, and high wind preparation considerations. Also, the procedure places the unit outside the EDG limiting condition of operation (LCO) applicability for operating units (i.e., MODES 1 or 2) by directing a shutdown based on the hurricane category. Upon issuance of a watch or warning which impacts the site, the following actions will be executed as required by the procedures for the watch or warning in effect:

L-2019-149 Attachment 1 Page 2of10

Perform site walk-downs and eliminate or secure missile hazards.

Secure exterior cranes.

Ensure Unit 1 and Unit 2 Reactor Auxiliary Building (RAB) exterior doors are closed.

Ensure storm drain system capacity and the basin influent and discharge are clear of blockages.

Pump down yard sumps, Unit 1 RAB sumps and Unit 2 RAB sumps.

Verify RAB storage tanks have capacity for storm drainage.

Deploy the portable diesel fire pump for dewatering.

Perform a shiftly tail board with Operations Fire Team members to discuss the location of the fire equipment that has been relocated per plant procedures.

Obtain meteorological forecasts and data from the National Hurricane Center in Miami, Florida at least once per six hours during either a Hurricane Watch or a Hurricane Warning and enter in the narrative log.

Shutdown to at least HOT STANDBY (for Category 1, 2, or 3 hurricanes) or COLD SHUTDOWN (for Category 4 or 5 hurricanes) at least two hours prior to the onset of hurricane force winds at the site.

NRC Question: What are the Licensing Bases for SBO Timing?

Response

Section 15.10 of the Unit 2 UFSAR contains the SBO analysis. This analysis shows that St. Lucie Unit 2 can successfully endure a complete loss of AC power for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . However, it is expected that AC power would be restored within 30 minutes to one hour as a result of either one of the following corrective actions:

a. Offsite power is restored;

b. One or both of the St. Lucie Unit 2 diesel generators are started.

No credit is given for Unit 1 EDGs, but the DC coping capability is further enhanced by the ability to provide power to the one division of the Class lE distribution system from the available Unit 1 EOG. Even though the amount of power available to Unit 2 loads under a Station Blackout scenario (only one EOG operation on Unit

1) is limited by plant procedures_ ~s not to affect Unit 1 safe shutdown, it can be used to power selected loads, i.e., battery chargers, certain fans, etc.

Section 15.2.13 of the Unit 1 UFSAR contains the SBO analysis. As stated, Unit 1 is a four-hour SBO coping plant. At 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the DC coping period is assumed to end when the Unit 14160V lAB bus and Unit 2 4160V 2AB bus are manually connected and AC power is available to Unit 1, based on excess Unit 2 EOG capacity.

After 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , either offsite power is restored or one or both St. Lucie Unit 1 EDGs are started, thus terminating the event.

L-2019-149 Attachment 1 Page 3of10 NRC Question: What is the Licensing Basis for the required EDG capacity during SBO conditions?

Response

The Unit 1 and Unit 2 Section 3.1.5 requirements for EDG capability during SBO conditions is that in the unlikely event of a station blackout in one unit, i.e., total loss of AC power on-site and off-site, both units can be electrically connected, under administrative control, such that a diesel generator set from the non-blacked out unit is able to provide power to the minimum loads required to maintain both units in a hot standby condition.

NRC Question: Describe how the EDGs are protected from external flooding events.

Response :

Seismic Category I SSCs are protected from the effects of high water levels and wave run up through:

Design to withstand such effects

Positioning to preclude inoperability

Housing within waterproof structures The plant grade around the structures is approximate EL +18.5 ft-PSL datum. Structures are flood protected up to EL +19.5 ft-PSL datum. Any exterior doors and penetrations below EL +19.5 ft-PSL datum which lead to areas containing safety-related equipment are watertight. All permanent door openings in the exterior walls of the RAB, fuel handling building, and diesel generator building are provided with either roll-up or swing-type doors for protection from rain, wind, and other atmospheric effects. Doors are furnished with continuous, adjustable rubber stripping at jambs, head, and floor to provide a positive weather-tight closure.

For Unit 1, the two diesel oil storage tank foundations have a top elevation of EL +22.2 ft-PSL datum and are surrounded by a 1-ft thick reinforced concrete retaining wall extending to EL +24.5 ft-PSL datum. The operating floor of the Unit 1 diesel generator building is at EL +22.67 ft-PSL datum. The Unit 1 diesel tank essentially has a concrete half-wall surrounding it which provides flood protection up to EL +24.5 ft-PSL datum .

For Unit 2, the diesel generator build ing floor and equipment are above EL +22 ft-PSL datum and no openings below EL +22.67 ft-PSL datum . The Diesel Oil Storage Tank Building have no openings below EL

+29.5 ft-PSL datum.

Flood hazards for St. Lucie were re-evaluated and submitted to the NRC via FPL letter L-2015-048 dated March 10, 2015. This letter documents that the probable maximum storm surge (PMSS) water level associated with hurricanes was determined to be at EL+l8.3 ft-PSL datum, which is below the level forthe Unit 1 and Unit 2 EDG buildings and equipment as shown above.

The St. Lucie flood hazards were re-evaluated for local intense precipitation events (LIP) and submitted to the NRC via FPL Letter L-2016-027 dated February 18, 2016. This evaluation documents that the local flood levels remain below the Unit 1 and 2 EDG operating floor and door levels. Therefore, LIP events have no adverse effects on EDG availability.

L-2019-149 Attachment 1 Page 4of10 Justification for suspending EDG surveillances during the extended AOT Monthly surveillance testing of the opposite train EDG would require entry into Technical Specification Action 3.8.l.l.e. to restore one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

During monthly surveillance testing EDG is inoperable during the following evolutions:

manually aligning the Diesel Oil Storage Tank for recirculation for verification of the Diesel Oil Transfer Pump and sampling per Diesel Fuel Oil Program;

barring the EOG (may be waived with the opposite train EOG out of service); and

while paralleled to offsite power via the 4.16 KV bus. When the EDG breaker is CLOSED, the loss of voltage and degraded voltage relay protection is blocked and NOT available to protect the EOG from an overload condition due to a grid or system disturbance.

The following TS surveillance requirements (SRs) are met by performance of the monthly surveillance procedure: 4.8.1.1.2.a.1, 4.8.1.1.2.a.2, 4.8.1.1.2.a.3, 4.8.1.1.2.a.5, 4.8.1.1.2.a.6, 4.8.1.1.2.b.l, and 4.8.1.1.2.c.

In order to minimize risk, consistent with defense-in-depth philosophy, FPL is requesting to suspend monthly testing of EDGs lA, 2A, and 2B per SR 4.8.1.1.2.a.1, 4.8.1.1.2.a.2, 4.8.1.1.2.a.3, 4.8.1.1.2.a.5, 4.8.1.1.2.a.6, 4.8.1. 1.2.b.l, and 4.8.1.1.2.c during the proposed extended AOT.

FPL proposes that until EOG 1B is returned to OPERABLE status, not to exceed 0736 EST on August 14, 2019, performance of the above SRs for EDGs lA, 2A, and 2B may be suspended. Past due surveillances will be completed within 7 days of restoration of EOG 1B operability or August 21, 2019, whichever occurs first.

The following asterisk will be added to the applicable TSs with the note below. Markups and Word Processed changes are provided in attachments 2 and 3.

Until EDG 1B is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs lA, 2A, and 2B may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 1B operability or August 21, 2019, whichever occurs first.

L-2019-149 Attachment 1 Page 5of10 PRA Related Questions NRC Question: The submittal states that some F&Os remain open. NRC requested a list of the open F&Os and an explanation as of why they do not impact the application Response :

Finding Description Resolution Impact CS-A3-01 4kV power and 125VDC control cables The Component and Cable Selection Report Issue resolved for required to support the operation of the documents the equipment added to the fire the 4b model.

Containment Spray Pump were not PRA and provide a list of cables required to Resolution was identified. Fire PRA Plant Response model support the proper operation of credited purely and other Fire PRA support tasks are equipment. documentation.

adversely affected. Perform a comparison There is no impact Documentation added to show the function of the components identified on the MSO to this application.

of the cables that were selected to verify (multiple spurious operation) list against that all appropriate cables have been the Fire PRA components for which new selected and of a thorough review of the cable selection was performed (i.e.,

existing cable selection.

components not previously identified on the Appendix R safe shutdown equipment list). Verify that the cable selection for the common components supports all credited operations. Fire PRA Plant Response model and other Fire PRA support tasks are adversely affected CS-Bl-01 No evaluation was performed to verify A detailed review of the coordination Issue resolved for that the new components and cables analysis was performed including those the 4b model.

associated with the Fire PRA is bounded power supplies associated with Fire PRA Resolution was by the existing overcurrent coordination components. The Component and Cable purely analysis. The evaluation was not Selection Report documents breaker documentation .

completed at this time. coordination evaluations. There is no impact to this application .

Reference 21 and 22 have been added to support this claim. Documentation issues in the Breaker Coordination Calculation have been resolved.

SF-Al-03 The documented assessment/ review of Fire PRA Summary Notebook updated to Issue resolved for fires induced by seismic events fails to:

address common cause failures, review of plant seismic response procedures, review address the items in the finding. the 4b model.

Resolution was purely of fire brigade training, associated documentation.

equipment storage and routes, and the There is no impact impact a seismic event would have on to this application.

them.

L-2019-149 Attachment 1 Page 6of10 NRC Question: Discuss the status of implementation items for this application and the impact to the application - [Very Early Warning Fire Detection System (VEWFDS} and whether or not its credited for this application]

Response

VEWFDS is not credited in the Unit 1 Fire PRA. Consequently, there is no impact for this application.

Note, VEWFDS is credited in the Unit 2 Fire PRA, which incorporates NUREG 2180. However, the Unit 2 PRA has no impact for this application.

NRC Question: RICT RAI discussed including the latest bounding plant-level seismic risk as part of RICT calculations. Why is it not needed for this application?

Response :

Seismic risk at PSL is evaluated at plant-level with CDF and LERF of 3.49E-6 per year and 3.49E-07 per year, respectively. Consequently, incremental seismic risk is assumed to have no impact on the considered configuration . However, for the purpose of this submittal, if a seismic risk impact equivalent to the plant-level values is added to delta CDF/LERF, the overall risk impact due to the considered configuration is still below the RG 1.177 limits for one-time CT change NRC Question: NRC requested confirmation that FLEX is not credited

Response

FPL did not credit FLEX in the PRA evaluation for the extended EDG AOT. While FLEX equipment and strategies remain available and would be utilized if needed, they are not specifically identified in any compensatory actions.

NRC Question: NRC questioned what is credited or not in the ICCDP. It seems to be different from the estimate in the RICT LAR (14-day max in Enclosure 2}.

Response

The FPL LAR for RICT utilized the draft Fire PRA model. The Fire PRA update made during implementation of the self-approval model included refinements that improved the overall risk. Examples include NU REG 2169 and 2178.

L-2019-149 Attachment 1 Page 7of10 NRC Question: Could you explain the model changes you listed in attachment 3.0, Section 3.0? Explain the changes associated with station blackout cross ties.

Response

There were no model changes made to the baseline model to produce the application-specific model configuration. The baseline model and the application-specific model are the same PRA model but with different runs to consider the referenced EDG is out of service. The bulleted items represent the assumptions that were considered when calculated the configuration-specific results. The referenced methods associated with the station blackout cross ties are already credited in the model and assumed available when needed. It was also assumed that these cross ties are protected by compensation measures and thus no further treatment oftheir availability, or unavailabiltiy, were considered beyond those considered in the baseline calculation .

NRC Question: Provide the top 10 dominant CDF scenarios associated with internal events risk and fire risk.

Provide descriptive listing.

Answer:

Top dominant Cutsets in delta CDF in Internal Events:

1 SMALL LOCA IE, A-train MOV to containment sump (source for lA HPSI injection during long term) fails to open, AC breaker from 1B startup transformer to 4KV 1B2 bus fails to close, EDG 1B OOS in TM.

2 Stuck open SRV initiator occurred (similar to SLOCA}, A-train MOV to containment sump (source for lA HPSI injection during long term) fails to open, AC breaker from 1B startup transformer to 4KV 1B2 bus fails to close, EDG lB OOS in TM.

3 LOSS OFF-SITE POWER {PLANT-CENTERED}, EDG lA FTR, EDG lB OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and OPERATOR FAILS TO CONTROL TD AFW PUMP DURING SBO & LODC.

4 LOSS OFF-SITE POWER {PLANT-CENTERED}, EDG FO PUMP lA FAILS TO START, EDG lB OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and OPERATOR FAILS TO CONTROL TD AFW PUMP DURING SBO & LODC.

5 LOSS OFF-SITE POWER {PLANT-CENTERED), EDG lA FTS, EDG 1B OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and OPERATOR FAILS TO CONTROL TD AFW PUMP DURING SBO & LODC.

6 LOSS OF 4KV BUS 1B2 IE, 4 KV SWGR BUS 1B2 FAULT (1 YR EXPOSURE), EDG 1B OOS in TM, OPERATOR FAILS TO PROVIDE LONG TERM MAKEUP TO CST VIA TWST, OPERATOR FAILS TO PROVIDE SUCTION TO Ul AFW FROM U2 CST, OPERATOR FAILS TO USE THE DIESEL-DRIVEN FIRE PUMP TO REFILL THE CST, OPERATOR FAILS TO INITIATE ONCE-THROUGH-COOLING (OTC} using 2 PORVs.

7 LOSS OFF-SITE POWER (PLANT-CENTERED), EDG lA FTR, EDG 1B OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and TURBINE-DRIVEN AFW PUMP lC FAILS

L-2019-149 Attachment 1 Page 8of10 TO RUN.

8 LOSS OFF-SITE POWER (PLANT-CENTERED), EDG lA FTR, EDG 1B OOS in TM, OPERATOR FAILS TO ALIGN BLACKOUT XTIE TO POWER UNIT 1 FROM UNIT 2, OPERATOR FAILS TO ALIGN NSR 4KV BUSES XTIE TO POWER UNIT 1 FROM UNIT 2, and AFW PUMP lC TRAIN UNAVAILABLE DUE TO TEST/MAINTENANCE.

9 LOSS OF 4KV BUS 1B2 IE, 4 KV SWGR BUS 1B2 FAULT (1 YR EXPOSURE), EDG 1B OOS in TM, CCF 20% OR MORE CRD/RODS FAIL TO INSERT.

10 SMALL LOCA IE, AC breaker from 1B startup transformer to 4KV 1B2 bus fails to close, EDG 1B OOS in TM, HPSI PUMP lA FAILS TO RUN DURING INJECTION.

Top dominant Cutsets in delta CDF in Internal Fire:

Description 1 Main Control Board RTGB-103, [UlPAF] Plant Availability Factor Control Building Personnel Room Fire - Whole Room Burn, fail ctrl TD AFW pp during SBO &

LODC-FIRE, EDG 1B IN TEST OR MAINTENANCE, [UlPAF] Plant Availability Factor, FLAG - lAB 2 4KV BUS ALIGNED TO 1A3 4KV BUS Junction Box Bl12, EDG lB IN TEST OR MAINTENANCE, [UlPAF] Plant Availability Factor, FLAG -

3 lAB 4KV BUS ALIGNED TO 1A3 4KV BUS 4 Cable Spreading Room - Hot Gas Layer Fire, [UlPAF] Plant Availability Factor Control Building Personnel Room Fire - Whole Room Burn, TURBINE-DRIVEN PUMP AFWlC FAILS TO RUN, EDG 1B IN TEST OR MAINTENANCE, [UlPAF] Plant Availability Factor, FLAG - lAB 5 4KV BUS ALIGNED TO 1A3 4KV BUS 6 PC-83 Severe Fire, [UlPAF] Plant Availability Factor 7 -0.5' Elevation Multi-Compartment Fire, [UlPAF] Plant Availability Factor 8 -0.5' Elevation Hot Gas Layer Fire. [UlPAF] Plant Availability Factor Control Building Personnel Room Fire - Whole Room Burn, fail ctrl TD AFW pp during SBO &

LODC-FIRE, EDG FO PUMP lA FAILS TO START, EDG 1B IN TEST OR MAINTENANCE, [UlPAF]

9 Plant Availability Factor, Control Building Personnel Room Fire - Whole Room Burn, AFW PUMP lC TRAIN UNAVAILABLE DUE TO TEST/MAINTENANCE, EDG 1B IN TEST OR MAINTENANCE, [UlPAF] Plant Availability 10 Factor, FLAG - lAB 4KV BUS ALIGNED TO 1A3 4KV BUS

L-2019-149 Attachment 1 Page 9of10 NRC Question: Why is LERF 3 orders of magnitude lower than CDF?

Response

Previously fire risk results were obtained using aggregate baseline cutsets resulting from quantifying all fire scenarios at high truncation. The LERF data input was obtained from different version of the model. The FRANX model was rerun and the new LERF numbers are in alignment and show a one order of magnitude lower than the CDF.

Table 4.1-1: PSL Unit 1 llCDF and llLERF Hazard Breakdown Internal Internal Fire Total Events Flood BASE CASE 3.SSE-06 7.58E-07 4.31E-OS lBEDG CDF OUT OF 3.62E-06 7.58E-07 7.12E-OS SERVICE LKDF 7.00E-08 l.62E-10 2.81E-OS BASE CASE 4.22E-07 4.41E-07 7.88E-06 lBEDG LERF OUT OF 4.33E-07 4.41E-07 1.4SE-05 SERVICE ll.LERF l .lOE-08 3.00E-11 6.59E-06 6.60E-06 Note: CDF and LERF results presented as "at-power" results for this onetime CT extension, instead of annualized like would be presented in a permanent plant change.

The ICCDP and ICLERP are presented in Table 4.1-2 is based on an overall 1 B EOG CT of 30 days, including the 14 days associated with the current TS limit.

Table 4.1-3: ICCDP and ICLERP for Technical Specification Extension Based on Total Completion Time Per Day ICCDP ICLERP ICCDP ICLE RP 2.32E-06 5.43E-07 7.72E-08 1.SlE-08 NRC Question: NRC requested the external flooding screening impact to be provided.

Response

PER NRC Letter dated 12/15/17 (ML17325B360):

"The NRC staff concludes, based on the information provided by FPL, that adequate margin exists for the reevaluated LIP mechanism. The NRC staff agrees that the licensee's estimation of water accumulation is conservative. The staff also finds that the hydrostatic and hydrodynamic loading analysis performed on power block structures was done using appropriate engineering codes and standards and the resultant loads are relatively low and are not expected to negatively impact such structures. Therefore, the NRC staff concludes that the licensee has demonstrated that adequate and reliable passive features exist to provide flood

L-2019-149 Attachment 1 Page 10of10 protection of key SSCs and maintain key safety functions as defined in Appendix B of NE/ 16- 05, Rev 1.

3.2.3 Overall Site Response The licensee does not rely on any personnel actions or new modifications to the plant in order to respond to the LIP event. As described above, the licensee's evaluation relied on passive existing flood protection features to demonstrate adequate flood protection; therefore, there is no need to review overall site response".

Based on this NRC letter, and the current plant design, no unique PRA model for external flooding scenarios is required to assess configuration risk for this application.

L-2019-149 Attachment 2 Page 1of6 TS Mark Up

- A one-time AOT extension for the inoperable 1B EOG allows 30 days to restore the EOG to OPERABLE status.

Compensatory Measure within FPL Letter L-2019-149 dated July 24, 201 9 will remain in effect during the extended AOT period. This extension expires on August 14, 201 9 at 0736 hours0.00852 days 0.204 hours 0.00122 weeks 2.80048e-4 months EDT.

3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8 .1 .1 As a minimum , the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and

b. Two separate and independent diesel generator sets each with:

1. Engine-mounted fuel tanks containing a minimum of 152 gallons of fuel,

2. A separate fuel storage system containing a minimum of 19,000 gallons of fuel, and

3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one offsite circuit of 3.8.1.1 .a inoperable , except as provided in Action f.

below, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8 .1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

b. With one diesel generator of 3.8.1.1 .b inoperable, demonstrate the OPERABILITY of the A.C . sources by performing Surveillance Requirement 4 .8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the EOG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing , demonstrate the OPERABILITY of the re OPERABLE EOG by performing Surveillance Requir .. 1.1 .2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed tha se of the inoperable EOG does not exist on the remai in , estore the diesel generator to OPERABLE status within 14 days be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN. Additionally, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from the discovery of concurrent inoperability of required redundant feature(s)

(including the steam driven auxiliary feed pump in MODE 1, 2, and 3), declare required feature(s) supported by the inoperable EOG inoperable if its redundant required feature(s) is inoperable.

If the absence of any common-cause failure cannot be confirmed, this test shall be completed regardless of when the inoperable EOG is restored to OPERA Bl LITY.

LUCIE- UNIT 1 3/4 S-1 Amendment No . .w:>, ~. ~. -1.+G,

+oo.~. 234

L-2019-149 Attachment 2 Page 2 of 6

Until EDG 1B is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs lA, 2A, and 2B may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 1B operability or August 21, 2019, whichever occurs first.

ELECTRICAL POWER SYSTEMS ACTION (continued)

e. With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter: restore one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in the at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

Following restoration of one diesel generator unit, follow ACTION Statement b. with the time requirement of that ACTION Statement based on the time of initial loss of the remaining inoperable diesel generator.

f. With one Unit 1 startup transformer (1A or 1B) Inoperable and with a Unit 2 startup transformer (2A or 2B) connected to the same A or B offsite power circuit and administratively available to both units, then should Unit 2 require the use of the startup transformer administratively available to both units, Unit 1 shall demonstrate the OPERABILITY of the remaining A.G. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Restore the inoperable startup transformer to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

g. LCO 3.0.4.b is not applicable to diesel generators.

SURVEILLANCE REQUIREMENTS 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the onsite Class 1 E distribution system shall be:

a. Determined OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments, indicated power availability; and

b. Demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by transferring (manually and automatically) unit power supply from the auxiliary transformer to the startup transformer.

4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by:

1. Verifying fuel level in the engine-mounted fuel tank, )<-,

2. Verifying the fuel level in the fuel storage tank, x:

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine-mounted tank, ~)(.

ST. LUCIE - UNIT 1 3/4 8-3 Amendment No. 4-03, '14~. ~.

22ll, 22J. 2:!4, 247

L-2019-149 Attachment 2 Page 3 of 6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

4. Verifying the diesel starts from ambient condition and accelerates to approximately 900 rpm in less than or equal to 10 seconds**.

The generator voltage and frequency shall be 4160 +/-420 volts and 60 +/- 1.2 Hz within 1O seconds after the start signal**. The diesel generator shall be started for this test by using one of the following signals:

a) Manual/Local b) Simulated loss-of-offsite power by itself.

c) Simulated loss-of-offsite power in conjunction with an ESF actuation test signal.

d) An ESF actuation test signal by itself.

5. Verifying the generator is synchronized , loaded to greater than or equal to 3500 kW in accordance with the manufacturer's recommendations and operates within a load band of 3300 to 3500 kW*** for at least an additional 60 minutes, and *

6. Verifying the diesel generator is aligned to provide standby power to the associated emergency busses:!*--

b. By removing accumulated water:

1. From the engine-mounted fuel tank in accordance with the Surveillance Frequency Control Program and after each occasion when the diesel is operated for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and :1f-

2. From the storage tank in accordance with the Surveillance Frequency Control Pro ram.

Until EOG lB is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EOGs IA, 2A, and 2B may be suspended. Past due surveillances will be completed within 7 days of restoration of EOG lB operability or August 21, 2019, 1uhirho\1C. f" ,....,...,...,,,..!:" f i rc-t-The diesel generator start (10 sec.) from ambient conditions shall be performed in accordance with the Surveillance Frequency Control Program in these surveillance tests. All other diesel generator starts for the purposes of this surveillance testing may be preceded by an engine prelube period and may also include warmup procedures (e:g., gradual acceleration) as recommended by the manufacturer so* that mechanical stress and wear on the diesel generator is minimized.

- - The indicated load band is meant as guidance to avoid routine overloading . Variations in loads in excess of the band due to changing bus loads shall not invalidate this test.

ST. LUCIE - UNIT 1 3/4 8-4 Amendment No. 4+, <>J, 400, -4:!, 4-Jil, 223

L-2019-149 Attachment 2 Page 4 of 6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of the Diesel Fuel Oil Testing Program . .:.x-

d. DELETED

e. In accordance with the Surveillance Frequency Control Program during shutdown by:

1. DELETED

2. Verifying generator capability to reject a load of greater than or equal to 600 hp while maintaining voltage at 4160 +/-. 420 volts and frequency at 60 +/-. 1.2 Hz.

3. Simulating a loss of offsite power by itself, and:

a) Verifying deenergization of the emergency busses and load shedding from the emergency busses.

Until EDG 1B is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs lA, 2A, and 2B may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG lB operability or August 21, 2019, whichever occurs first.

ST. LUCIE - UNIT 1 3/4 8-5 Amendment No. aJ, 4-0J, 468, :!W, 223

L-2019-149 Attachment 2 Page 5 of 6

Until EDG lB is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs lA, 2A, and 2B may be suspended . Past due surveillances will be completed within 7 days of restoration of EDG lB operability or August 21, 2019, whichever occurs first.

ELECTRICA LA

1. Verifying fuel level in the engine-mounted fuel tank, %

2. Verifying the fuel level in the fuel storage tank, ¥

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine-mounted tank, ..'.f.-*

4. Verifying the diesel starts from ambient condition and accelerates to approximately 900 rpm in less than or equal to 10 seconds**. The generator voltage and frequency shall be 4160 +/- 420 volts and 60 +/- 1.2 Hz within 10 seconds after the start signal**. The diesel generator shall be started for this test by using one of the following signals:

a) Manual/Local.

b) Simulated loss-of-offsite power by itself.

c) Simulated loss-of-offsite power in conjunction with an ESF actuation test signal.

d) An ESF actuation test signal by itself.

5. Verifying the generator is synchronized, loaded to greater than or equal to 3685 kW in accordance with the manufacturer's recommendations, and operates within a load band of 3450 to 3685 kW..* for at least an additional 60 minutes, and :)I--

6.

Verifying the diesel generator is aligned associated emergency busses.

to provide standby power to the

b. By removing accumulated water:

1. From the engine-mounted fuel tank in accordance with the Surveillance Frequency Control Program and after each occasion when the diesel is operated for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and *~

2. From the storage tank in accordance with the Surveillance Frequency Control Program.

The diesel generator start (10 sec.) from ambient conditions shall be performed in accordance with the Surveillance Frequency Control Program in these surveillance tests. All other diesel generator starts for purposes of this surveillance testing may be preceded by an engine prelube period and may also include warmup procedures (e.g., gradual acceleration) as recommended by the manufacturer so that mechanical stress and wear on the diesel generator is minimized.

- - The indicated load band is meant as guidance to avoid routine overloading. Variations in loads in excess of the band due to changing bus loads shall not invalidate this test.

ST. LUCIE - UNIT 2 3/4 8-4 Amendment No . ~. DJ,:/$, 173

L-2019-149 Attachment 2 Page 6 of 6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (continued\

c. Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of the Diesel Fuel Oil Testing Program. -;?(

d. DELETED

e. In accordance with the Surveillance Frequency Control Program during shutdown by:

1. DELETED

2. Verifying generator capability to reject a load of greater than or equal to 453 kW while maintaining voltage at 4160 _:!: 420 volts and frequency at 60 _:!: 1.2 Hz.

3. Verifying the generator capability to reject a load of 3685 kW without tripping. The generator voltage shall not exceed 4784 volts during and following the load rejection.

Until EDG lB is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs lA, 2A, and 28 may be su spended. Past due surveillances will be completed within 7 days of restoration of EDG 1B operability or August 21, 2019, whichever occurs first.

ST. LUCIE - UNIT 2 3/4 8-5 Amendment No. ~9,-1--1-1 , '15S, 173

L-2019-149 Attachment 3 Page 1of6 Word Processed TS 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and

b. Two separate and independent diesel generator sets each with:

1. Engine-mounted fuel tanks containing a minimum of 152 gallons of fuel,

2. A separate fuel storage system containing a minimum of 19,000 gallons of fuel, and

3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With one offsite circuit of 3.8.1.1.a inoperable, except as provided in Action f.

below, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1 .1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program , or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

NOTE If the absence of any common-cause failure cannot be confirmed, Surveillance Requirement 4.8.1.1.2.a.4 shall be completed regardless of when the inoperable EOG is restored to OPERABILITY.

b. With one diesel generator of 3.8.1.1.b inoperable, demonstrate the OPERABILITY of the A.C. sources by performing Surveillance Requirement 4.8.1 .1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the EOG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EOG by performing Surveillance Requirement 4.8.1 .1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable EOG does not exist on the remaining E DG; restore the diesel generator to OPERABLE status within 14 days* or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Additionally, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from the discovery of concurrent inoperability of required redundant feature(s) (including the steam driven auxiliary feed pump in MODE 1, 2, and 3), declare required feature(s) supported by the inoperable EOG inoperable if its redundant required feature(s) is inoperable .

A one-time AOT extension for the inoperable 1B EOG allows 30 days to restore the EOG to OPERABLE status. Compensatory Measure within FPL Letter L-2019-149 dated July 24, 2019 will remain in effect during the extended AOT period. This extension expires on August 14, 2019 at 0736 hours0.00852 days 0.204 hours 0.00122 weeks 2.80048e-4 months EDT.

ST. LUCIE - UNIT 1 3/4 8-1 Amendment No. -WJ, ++2, -'1-38, +7G,

~.~. ~.~

L-2019-149 Attachment 3 Page 2 of 6 ELECTRICAL POWER SYSTEMS ACTION (continued)

e. With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A .C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; restore one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in the at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN .

Following restoration of one diesel generator unit, follow ACTION Statement b. with the time requirement of that ACTION Statement based on the time of initial loss of the remaining inoperable diesel generator.

f. With one Unit 1 startup transformer (1 A or 1B) inoperable and with a Unit 2 startup transformer (2A or 2B) connected to the same A or B offsite power circuit and administratively available to both units, then should Unit 2 require the use of the startup transformer administratively available to both units , Unit 1 shall demonstrate the OPERABILITY of the remaining A .C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Restore the inoperable startup transformer to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

g. LCO 3.0.4.b is not applicable to diesel generators.

SURVEILLANCE REQUIREMENTS 4 .8.1.1.1 Each of the above required independent circuits between the offsite transm ission network and the onsite Class 1E distribution system shall be:

a. Determined OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments, indicated power availability ; and

b. Demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by transferring (manually and automatically) unit power supply from the auxiliary transformer to the startup transformer.

4.8.1.1 .2 Each diesel generator shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by:

1. Verifying fuel level in the engine-mounted fuel tank,*

2. Verifying the fuel level in the fuel storage tank ,*

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine-mounted tank ,*

Until EOG 1 B is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs 1A, 2A, and 28 may be suspended . Past due surveillances will be completed within 7 days of restoration of EOG 1B operability or August 21, 2019 ,

whichever occurs first.

ST. LUCIE - UNIT 1 3/4 8-3 Amendment No. ~.~.~.

~.~. ~.~

L-2019-149 Attachment 3 Page 3 of 6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

4. Verifying the diesel starts from ambient condition and accelerates to approximately 900 rpm in less than or equal to 10 seconds**. The generator voltage and frequency shall be 4160 ~ 420 volts and 60 ~ 1.2 Hz within 10 seconds after the start signal**. The diesel generator shall be started for this test by using one of the following signals:

a) Manual/Local b) Simulated loss-of-offsite power by itself.

c) Simulated loss-of-offsite power in conjunction with an ESF actuation test signal.

d) An ESF actuation test signal by itself.

5. Verifying the generator is synchronized , loaded to greater than or equal to 3500 kW in accordance with the manufacturer's recommendations and operates within a load band of 3300 to 3500 kW*** for at least an additional 60 minutes, and*

6. Verifying the diesel generator is aligned to provide standby power to the associated emergency buss es.*

b. By removing accumulated water:

1. From the engine-mounted fuel tank in accordance with the Surveillance Frequency Control Program and after each occasion when the diesel is operated for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and*

2. From the storage tank in accordance with the Surveillance Frequency Control Program.

Until EOG 1B is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs 1A, 2A, and 2B may be suspended. Past due surveillances will be completed within 7 days of restoration of EOG 1B operability or August 21, 2019, whichever occurs first.

The diesel generator start (10 sec.) from ambient conditions shall be performed in accordance with the Surveillance Frequency Control Program in these surveillance tests . All other diesel generator starts for the purposes of this surveillance testing may be preceded by an engine prelube period and may also include warmup procedures (e.g ., gradual acceleration) as recommended by the manufacturer so that mechanical stress and wear on the diesel generator is minimized.

The indicated load band is meant as guidance to avoid routine overloading. Variations in loads in excess of the band due to changing bus loads shall not invalidate this test.

ST. LUCIE - UNIT 1 3/4 8-4 Amendment No. U , ~.

400.~.~.~

L-2019-149 Attachment 3 Page 4 of 6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of the Diesel Fuel Oil Testing Program .*

d. DELETED

e. In accordance with the Surveillance Frequency Control Program during shutdown by:

1. DELETED

2. Verifying generator capability to reject a load of greater than or equal to 600 hp while maintaining voltage at 4160 +/-. 420 volts and frequency at 60 +/-. 1.2 Hz.

3. Simulating a loss of offsite power by itself, and :

a) Verifying deenergization of the emergency busses and load shedding from the emergency busses .

Until EDG 1 Bis returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs 1A, 2A, and 28 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 1B operability or August 21, 2019, whichever occurs first.

ST. LUCIE - UNIT 1 3/4 8-5 Amendment No. :>a, 400, ~. ;w+,

~

L-2019-149 Attachment 3 Page 5 of 6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

1. Verifying fuel level in the engine-mounted fuel tank,*

2. Verifying the fuel level in the fuel storage tank,*

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine-mounted tank,*

4. Verifying the diesel starts from ambient condition and accelerates to approximately 900 rpm in less than or equal to 10 seconds**. The generator voltage and frequency shall be 4160 +/- 420 volts and 60 +/- 1.2 Hz within 10 seconds after the start signal**. The diesel generator shall be started for this test by using one of the following signals:

a) Manual/Local.

b) Simulated loss-of-offsite power by itself.

c) Simulated loss-of-offsite power in conjunction with an ESF actuation test signal.

d) An ESF actuation test signal by itself.

5. Verifying the generator is synchronized, loaded to greater than or equal to 3685 kW in accordance with the manufacturer's recommendations, and operates within a load band of 3450 to 3685 kW*** for at least an additional 60 minutes, and*

6. Verifying the diesel generator is aligned to provide standby power to the associated emergency busses. *

b. By removing accumulated water:

1. From the engine-mounted fuel tank in accordance with the Surveillance Frequency Control Program and after each occasion when the diesel is operated for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and*

2. From the storage tank in accordance with the Surveillance Frequency Control Program.

Until EDG 1B is returned to OPERABLE status, not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs 1A, 2A, and 28 may be suspended. Past due surveillances will be completed within 7 days of restoration of EDG 1B operability or August 21, 2019, whichever occurs first.

The diesel generator start (10 sec.) from ambient conditions shall be performed in accordance with the Surveillance Frequency Control Program in these surveillance tests. All other diesel generator starts for purposes of this surveillance testing may be preceded by an engine prelube period and may also include warmup procedures (e.g., gradual acceleration) as recommended by the manufacturer so that mechanical stress and wear on the diesel generator is minimized.

- - The indicated load band is meant as guidance to avoid routine overloading . Variations in loads in excess of the band due to changing bus loads shall not invalidate this test.

ST. LUCIE - UNIT 2 3/4 8-4 Amendment No. ;Ml, ~. +<I, .++d

L-2019-149 Attachment 3 Page 6 of 6 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

c. Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of the Diesel Fuel Oil Testing Program.*

d. DELETED

e. In accordance with the Surveillance Frequency Control Program during shutdown by:

1. DELETED

2. Verifying generator capability to reject a load of greater than or equal to 453 kW while maintaining voltage at 4160 .+/-. 420 volts and frequency at 60 .+/-. 1.2 Hz.

3. Verifying the generator capability to reject a load of 3685 kW without tripping . The generator voltage shall not exceed 4784 volts during and following the load rejection.

Until EOG 1Bis returned to OPERABLE status , not to exceed 0736 EDT on August 14, 2019, performance of this SR for EDGs 1A, 2A, and 28 may be suspended . Past due surveillances will be completed within 7 days of restoration of EOG 1B operability or August 21, 2019, whichever occurs first.

ST. LUCIE- UNIT 2 3/4 8-5 Amendment No. W,-44+, -'h'>a,

~

v t e Letter Sequence Other
EPID:L-2019-LLA-0152, (Approved, Closed)
Initiation Acceptance... Supplement, Supplement Administration Questions Answers Results Approval Other: L-2019-147, Exigent Technical Specification Amendment Request One-Time Allowed Outage Time Extension for Inoperable EDG, L-2019-149, Exigent Technical Specification Amendment Request RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG, ML19203A016, ML19203A018
MONTHYEAR2019-07-22 [Table View]

L-2019-149, Exigent Technical Specification Amendment Request RAI Reply One-Time Allowed Outage Time Extension for Inoperable EDG

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