L-2023-126, Enclosure 1: Contents of Improved Technical Specifications (ITS) Submittal

Enclosure 1: Contents of Improved Technical Specifications (ITS) Submittal

ML23275A127
Person / Time
Site:	Saint Lucie
Issue date:	10/02/2023
From:	Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML23275A109	List: L-2023-126, Enclosure 1: Contents of Improved Technical Specifications (ITS) Submittal ML23275A110 ML23275A111 ML23275A112 ML23275A113 ML23275A114 ML23275A115 ML23275A116 ML23275A117 ML23275A118 ML23275A119 ML23275A120 ML23275A121 ML23275A122 ML23275A123 ML23275A124 ML23275A125 ML23275A126
References
L-2023-126
Download: ML23275A127 (1)

Text

St. Lucie Plant Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 1 ENCLOSURE 1 CONTENTS OF THE ST. LUCIE PLANT, UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL (17 TOTAL PAGES, INCLUDING COVER SHEETS)

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 Table of Contents Executive Summary ..................................................................................................... 1 Volume Titles ............................................................................................................... 3 Volume 1...................................................................................................................... 4 Volume 2...................................................................................................................... 4 Volumes 3 through 16 .................................................................................................. 5 CTS Markup and Discussion of Changes (DOCs) ..................................................... 5 R2 Designator - Category ............................................................................................... 6 Type and Category Descriptions................................................................................ 7 R2 ii

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 Executive Summary The proposed changes from the St. Lucie Plant (PSL) Unit 1 and Unit 2 current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) are based on Revision 5.0 of NUREG 1432, Standard Technical Specifications -

Combustion Engineering Plants. There are no additional NRC approved generic changes (Technical Specification Task Force (TSTF) change travelers) since approval of NUREG-1432, Revision 5, to address in this license amendment request as of September 15, 2021. Additionally, there are no linked PSL submittals associated with this ITS license amendment request. Technical Specification Task Force (TSTF)-GG-13-01, Improved Technical Specifications Conversion Guidance, Revision 0, was used to prepare the content of the license amendment request.

• The Battery Monitoring and Maintenance Program is included to provide for battery restoration and maintenance per the guidance of IEEE 450-2010, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications. The Notice of Availability for TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360," (76FR54510) references the model application and safety evaluation for plant-specific adoption of TSTF-500, Revision 2 (NRC ADAMS Accession No. ML111751792). PSL has verified the applicable information specified in Section 2.2 of the TSTF-500 model application, including applicable Updated Final Safety Analysis Report (UFSAR) R2 information. FPL has verified the following information in support of PSL adoption of TSTF-500, Revision 2:

• A letter has been obtained from the manufacturer of the batteries used at PSL Units 1 and 2 verifying the acceptability of using float current monitoring instead of specific gravity monitoring as a reliable and accurate indication of the state-of-charge of the battery and that this will hold true over the life of the battery.

• Measurement equipment used to monitor float current has the necessary accuracy and capability to measure electrical currents in the expected range.

• Spare battery chargers are available and appropriately sized to support each battery. Each 125 VDC battery charger is a full capacity charger. Typically, two battery chargers are operated in parallel to supply the battery and carry the DC loads. However, either connected battery charger can meet full DC bus load demand and recharge its associated battery. In addition, an additional full capacity swing battery charger can be connected to either DC bus.

• Maintaining battery connection resistances below the battery manufacturer specifications keeps the battery bounded by the battery performance data that was used to qualify the cells. The connection resistance readings are maintained within 20% of the baseline resistance values determined during installation for optimum performance of the battery system. IEEE 450-2010 supports this methodology.

Commitments associated with TSTF-500 are provided in Enclosure 5. A description of the UFSAR changes associated with TSTF-500 are provided in Enclosure 6.

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St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 Commitments and UFSAR revision packages associated with TSTF-500 will be completed prior to implementation of the ITS Amendment.

Several risk informed initiatives incorporated into the Improved Standard Technical Specifications (ISTS) and associated Bases specified in NUREG-1432, Rev. 5.0, have been previously approved and incorporated into the PSL Unit 1 and Unit 2 Technical Specifications. Therefore, information related to the NRC reviewer notes provided in the ISTS and ISTS Bases associated with these risk informed initiatives are provided in the license amendment request (LAR) submittals, FPL responses to NRC staff R2 requests for additional information, and accompanying safety evaluations associated with these risk informed license amendments.

PSL adopted a Surveillance Frequency Control Program (SFCP) on June 22, 2015, in License Amendments 223 and 173, for Unit 1 and Unit 2 respectively (NRC ADAMS Accession No. ML15127A066). In the NRC safety evaluation accompanying the SFCP amendments, the NRC concluded that the adoption of TSTF-425, Revision 3, and risk-informed methodology of NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1, as referenced in the Administrative Controls section of the Technical Specifications, satisfies the key principles of risk-informed decisionmaking applied to the relocated Surveillance frequencies as delineated in Regulatory Guide 1.177, Revision 1, and Regulatory Guide 1.174, Revision 2.

Changes to Surveillance frequencies listed in the SFCP are made in accordance with NEI 04-10, Revision 1, as specified in CTS Chapter 6 (ITS Chapter 5).

PSL adopted TSTF-422, "Change in Technical Specifications End States (CE NPSD-1186)," Revision 2, with application of site-specific variations and deviations from TSTF-422, on August 30, 2016, in License Amendments 234 and 184, for Unit 1 and Unit 2 respectively (NRC ADAMS Accession No. ML16210A374). As stated in several NRC reviewer notes in the ISTS Bases, the adoption of a MODE 4 end state requires the licensee to make commitments to follow the guidance established in Section 11 of NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Nuclear Management and Resource Council, Revision [4F] and in Revision 2 of WCAP-16364-NP, "Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422)." FPL conducts risk assessments using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide (RG) 1.160 R2 endorses the guidance in Section 11 of NUMARC 93-01, Revision 4A. As stated in the safety evaluation accompanying the TSTF-422 End-State amendments, FPL also reviewed the supporting Topical Report WCAP-16364-NP, Revision 2. The NRC staff concluded that PSL's commitment to RG 1.160 guidance is acceptable for application R2 of TSTF-422.

PSL adopted TSTF -505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b" to include Risk Informed Completion Times (RICTs) for selected Technical Specification systems. License Amendments 247 and 199, were issued on July 2, 2019, for Unit 1 and Unit 2 respectively, to incorporate the RICTs and an associated administrative program (NRC ADAMS Accession No. ML19113A099).

In the NRC safety evaluation accompanying the RICT amendment, the NRC found that E1-2

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 the PSL probabilistic risk assessment (PRA) maintenance and change process R2 ensures that the configuration risk management program models used in the RICT calculations will continue to use PRA methods acceptable to the NRC and that the PRA model will be updated as necessary to reflect the as-built and as-operated plant. The NRC also found that appropriate programmatic and procedural controls for the RICT Program are consistent with the guidance of NEI 06-09, Revision 0-A. Controls to calculate RICTs are provided in the CTS Chapter 6 (ITS Chapter 5) and implemented R2 in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines." The LAR submittal, FPL responses to NRC staff requests for additional information, and safety evaluation accompanying the RICT amendment address the implementation of the RICT program to perform a contemporaneous assessment of the overall impact on safety of proposed plant configurations prior to performing and during performance of maintenance activities that remove equipment from service as stated in several NRC reviewer notes in the ISTS Bases. of the submittal for the conversion of the PSL Unit 1 and Unit 2 CTS to the ITS provides the proposed changes to the CTS, discussion of changes for the proposed CTS changes, the PSL Unit 1 and Unit 2 ITS and ITS Bases, as marked up utilizing NUREG-1432, and justification for deviations from the NUREG. Enclosure 2 consists of the following sixteen volumes:

Volume Titles

1. Application of Selection Criteria to the St. Lucie Plant Technical Specifications

2. Generic Determination of No Significant Hazards Considerations and Environmental Assessment

3. ITS Chapter 1.0, Use and Application

4. ITS Chapter 2.0, Safety Limits

5. ITS Section 3.0, Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR) Applicability

6. ITS Section 3.1, Reactivity Control Systems

7. ITS Section 3.2, Power Distribution Limits

8. ITS Section 3.3, Instrumentation

9. ITS Section 3.4, Reactor Coolant System

10. ITS Section 3.5, Emergency Core Cooling Systems (ECCS)

11. ITS Section 3.6, Containment Systems

12. ITS Section 3.7, Plant Systems

13. ITS Section 3.8, Electrical Power Systems

14. ITS Section 3.9, Refueling Operations

15. ITS Chapter 4.0, Design Features

16. ITS Chapter 5.0, Administrative Controls E1-3

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 Volume 1 is provided to assist the Nuclear Regulatory Commission (NRC) in the review and approval of Volumes 2 through 16. Below is a brief description of the content of each of the volumes in this submittal.

Volume 1 Volume 1 provides details concerning the application of the selection criteria to the individual PSL Unit 1 and Unit 2 CTS. Each CTS Specification is evaluated, and a determination is made as to whether the CTS Specification meets the criteria in 10 CFR 50.36(c)(2)(ii) for retention in the proposed ITS.

Volume 2 Volume 2 contains generic evaluations required by 10 CFR 50.91(a), which support a finding of No Significant Hazards Consideration (NSHC). Based on the inherent similarities in the NSHC evaluations, generic evaluations for a finding of NSHC have been provided for the following categories of CTS changes:

• Administrative Changes

• More Restrictive Changes

• Relocated Specifications

• Removed Detail Changes

• Less Restrictive Changes - Category 1 - Relaxation of LCO Requirements

• Less Restrictive Changes - Category 2 - Relaxation of Applicability

• Less Restrictive Changes - Category 3 - Relaxation of Completion Time

• Less Restrictive Changes - Category 4 - Relaxation of Required Action

• Less Restrictive Changes - Category 5 - Deletion of Surveillance Requirement

• Less Restrictive Changes - Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria

• Less Restrictive Changes - Category 7 - Relaxation of Surveillance Frequency

• Less Restrictive Changes - Category 8 - Deletion of Surveillance Requirement Shutdown Performance Requirements

• Less Restrictive Changes - Category 9 - Deletion of Reporting Requirements For less restrictive changes not covered by a generic Less Restrictive Change category, specific NSHC evaluations have been provided in the applicable Chapter, Section, or Specification in Volumes 3 through 16. Additionally, specific NSHC evaluations have been provided for changes that have been identified beyond the CTS and the ISTS consistent with the guidance of TSTF-GG-13-01.

In addition, Volume 2 contains an evaluation of environmental consideration in accordance with 10 CFR 51.21. It has been determined that the proposed license amendment meets the eligibility criteria for categorical exclusion set forth in E1-4

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 10 CFR 51.22(b), and no environmental impact statement or environmental assessment need be prepared in connection with the proposed license amendment.

Volumes 3 through 16 Volumes 3 through 16 provide the details and justification to support the proposed changes. Each volume corresponds to a Chapter, Section, or Specification of NUREG-1432. Volumes 3, 4, and 15 are arranged by ITS Chapter. Volumes 5 and 16 are arranged by ITS Section. Volumes 6 through 14 are arranged by ITS Specification.

Each volume contains the required information to review the conversion to ITS, and include the following:

• Individual Chapter, Section, or Specification, as applicable, in ITS order.

• Relocated/Deleted CTS Specifications (if applicable); and

• ISTS Specifications not adopted in the PSL Unit 1 and Unit 2 ITS (if applicable).

The information for each Chapter, Section, and Specification, as applicable, is organized as follows:

CTS Markup and Discussion of Changes (DOCs)

This section contains a markup of the CTS pages, either for CTS pages associated with an Individual ITS Specification or for Relocated/Deleted CTS Specifications, and the DOCs from the CTS. Other CTS license amendment requests under NRC review, as described in Enclosure 4 of this submittal, are not linked to this license amendment request and have not been incorporated in the proposed change.

The CTS markup pages for each ITS Specification are normally in numerical order.

However, more than one CTS Specification is sometimes used in the generation of an ITS Specification. In this case, the CTS pages that are the major contributor to the ITS Specification are shown first, followed by the remaining associated CTS pages in numerical order.

The left-hand margin of the CTS markup pages includes a cross-reference to the equivalent ITS requirement. The upper right-hand corner of the CTS markup pages is annotated with the ITS Specification number to which it applies. Items on the CTS markup pages that are addressed in other proposed ITS Chapters, Sections, or Specifications are annotated with the appropriate reference.

The CTS markup pages are annotated with an alphanumeric designator to identify the differences between the CTS and the proposed ITS. The designator corresponds to a DOC, which provides the description and justification of the change to the CTS. The DOCs are located directly following the associated CTS markup for each Chapter, Section, or Specification, as applicable.

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St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 Each proposed change to the CTS is designated as one of the following DOC categories:

Designator Category A ADMINISTRATIVE CHANGES - Changes to the CTS that do not result in new requirements or change operational restrictions or flexibility.

These changes are supported in aggregate by a single generic NSHC.

M MORE RESTRICTIVE CHANGES - Changes to the CTS that result in added restrictions or reduced flexibility. These changes are supported in aggregate by a single generic NSHC.

R RELOCATED SPECIFICATIONS - Changes to the CTS that relocate specifications that do not meet the selection criteria of 10 CFR 50.36(c)(2)(ii). These changes are supported in aggregate by a single generic NSHC.

LA REMOVED DETAIL CHANGES - Changes to the CTS that eliminate detail and relocate the detail to a licensee controlled document.

Typically, this involves details of system design and function, or procedural detail on methods of conducting a Surveillance Requirement.

These changes are supported in aggregate by a single generic NSHC.

In addition, the generic type of removed detail change is identified in italics at the beginning of the DOC. The following is a list of the type of R2 removed detail changes:

• Type 1 - Removing Details of System Design and System Description, Including Design Limits

• Type 2 - Removing Descriptions of System Operation

• Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements R2

• Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program

• Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program

• Type 6 - Removal of Cycle-Specific Limits from the Technical Specifications to the Core Operating Limits Report L LESS RESTRICTIVE CHANGES - Changes to the CTS that result in reduced restrictions or added flexibility. These changes are supported either in aggregate by a generic NSHC that addresses a particular category of less restrictive change, or by a specific NSHC if the change is not covered by one of the generic categories of less restrictive changes. If the less restrictive change is covered by a generic NSHC, E1-6

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 the category of the change is identified in italics at the beginning of the DOC.

The DOCs are numbered sequentially within each letter designator for each ITS Chapter, Section, or Specification. Where a proposed change is applicable to only Unit 1 or Unit 2, it is identified as such at the beginning of the DOC in bold text.

The CTS Bases pages are replaced in their entirety by the proposed PSL Unit 1 and Unit 2 ITS Bases. Therefore, the CTS Bases markup pages are not provided in the ITS submittal.

Type and Category Descriptions R2 Type Descriptions The following is a summary description of each LA-DOC type. Changes to the PSL CTS involving the removal of specific detailed information from individual specifications evaluated to be Types 1 through 6 are as described below:

Type 1 - Removing Details of System Design and System Description, Including Design Limits The design of the facility is required to be described in the UFSAR by 10 CFR 50.34.

In addition, the quality assurance requirements of Appendix B to 10 CFR Part 50 require that plant design be documented in controlled procedures and drawings and maintained in accordance with an NRC-approved Quality Assurance Topical Report (QATR). The regulation of 10 CFR 50.59 specifies controls for changing the facility as described in the UFSAR. The regulation of 10 CFR 50.54(a) specifies criteria for changing the QATR. The Technical Requirements Manual (TRM) is a licensee-controlled document, which is also subject to 10 CFR 50.59. Additionally, the ITS Bases contain descriptions of system design. ITS 5.5.11, "Technical Specification (TS) Bases Control Program," specifies controls for changing the Bases. Removing details of system design is acceptable because the associated CTS requirements being retained without these details within the Technical R2 Specifications (TSs) are adequate to ensure safe operation of the facility.

In addition, retaining such details in TSs is unnecessary to ensure proper control of changes. Cycle-specific design limits are contained in the Core Operating Limits Report (COLR) in accordance with NRC Generic Letter (GL) 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," dated October 3, 1988. ITS 5.6, "Reporting Requirements," includes the programmatic requirements for the COLR.

Type 2 - Removing Descriptions of System Operation The plans for normal and emergency operation of the facility are required to be described in the UFSAR by 10 CFR 50.34. ITS 5.4.1.a and 5.4.1.d will require written procedures to be established, implemented, and maintained for plant E1-7

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 operating procedures required by the QATR and for all programs specified in ITS 5.5, "Programs and Manuals," respectively. The ITS Bases also contain descriptions of system operation. Controls specified in 10 CFR 50.59 apply to changes in procedures as described in the UFSAR and TRM. The TS Bases Control Program of ITS 5.5.11 specifies controls for changing the Bases. Removing details of system operation is acceptable because the associated CTS requirements being retained without these details within the TSs are adequate to ensure safe operation of the facility. In addition, retaining such details in ITS is unnecessary to ensure proper control of changes.

Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements Details for performing TS SRs or for regulatory reporting are more appropriately specified in the plant procedures. Changes to procedural details include those associated with limits retained in the ITS. For example, ITS 5.4.1 requires written procedures covering activities that include all programs specified in Specification 5.5 to be established, implemented, and maintained.

Prescriptive procedural information in a TS requirement is unlikely to contain all procedural considerations necessary for the plant operators to comply with TS and all regulatory reporting requirements, and referral to plant procedures is, therefore, required in any event. Therefore, it is acceptable to relocate Type 3 details from the CTS to licensee-controlled documents.

Type 4 - Removal of LCO, SR, or other TS requirement to the TRM, UFSAR, R2 ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program Certain CTS administrative requirements are redundant with respect to current regulations and thus are relocated to the UFSAR or other appropriate licensee-controlled documents. The Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (Federal Register 58 FR 39132) allows licensees to relocate to licensee-controlled documents any CTS requirements that do not meet any of the criteria for mandatory inclusion in the TS.

Examples of the proposed changes include moving details out of the CTS and into the TS Bases, the UFSAR, the Containment Leakage Rate Testing (CLRT)

Program, the TRM, and other documents under regulatory control such as the Offsite Dose Calculation Manual (ODCM), the Quality Assurance Program (QAP),

the Inservice Testing (IST) Program, the Inservice Inspection (ISI) Program, and the SFCP. The removal of this information is considered to be less restrictive administratively, because it is no longer controlled by the TS change process.

Typically, the information moved is descriptive in nature and its removal conforms to NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants."

Changes made in accordance with the provisions of licensee-controlled documents are subject to the specific requirements of those documents. For example, 10 CFR 50.54(a) governs changes to the QAP, while ITS 5.5.11 governs changes to the ITS E1-8

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 Bases. Therefore, it is acceptable to relocate Type 3 details from the CTS to licensee-controlled documents.

To the extent that information has been relocated to licensee-controlled documents, such information is not required to prevent the possibility of an abnormal situation or event giving rise to an immediate threat to public health and safety. Further, where such information is contained in LCOs and associated requirements in the TS, the information does not fall within any of the four criteria set forth in 10 CFR 50.36(c)(2)(ii) as discussed in the Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors. Accordingly, existing detailed information, such as generally described above, may be removed from the CTS and not included in the ITS.

Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program Licensees have the option to retain SR Frequencies within the TSs or adopt TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control -

RITSTF [Risk-Informed TSTF] Initiative 5b." TSTF-425 is a Traveler that is incorporated in NUREG-1432, Revision 5, that requires a formal technical review.

PSL has previously adopted TSTF-425 and has relocated most periodic frequencies of TS SRs to the licensee-controlled SFCP. ITS 5.5.16, "Surveillance Frequency Control Program," describes the requirements for the program to control changes to the relocated Surveillance Frequencies. Surveillance test requirements remain in the TSs. The SFCP ensures that SRs specified in the TS are performed at intervals sufficient to assure the associated LCOs are met. These changes are designated as a less restrictive removal of detail change, because the Surveillance Frequencies R2 are being removed from the TSs.

Type 6 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report The NRC documented in GL 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," that cycle-specific parameter limits are not necessary to be included in the TSs to provide adequate protection of public health and safety.

The methodologies used to develop the parameters in the COLR have obtained approval by the NRC in accordance with GL 88-16. The removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.3, "Core Operating Limits Report." ITS 5.6.3 ensures the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, emergency core cooling system limits, and nuclear limits such as shutdown margin (SDM), transient analysis limits, and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change because information relating to cycle-specific parameter limits is being removed from the TSs.

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St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 Category Descriptions The following is a summary description of each L-DOC category:

Less restrictive changes include deletions of and relaxations to portions of the PSL CTS requirements that are being retained in the PSL ITS. When requirements have been shown to give little or no safety benefit, the relaxation or removal of such requirements from the CTS may be appropriate. In most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new NRC staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups comments on ISTS. Generic relaxations contained in NUREG-1432, Revision 5.0 (ISTS), are generally acceptable because the relaxations are consistent with current licensing practices and the Commission's regulations.

Category 1 - Relaxation of LCO Requirement Certain CTS LCOs specify limits on operational and system parameters beyond those necessary to ensure meeting safety analysis assumptions and, therefore, are considered overly restrictive. The CTS also contain operating limits that have been shown to give little or no safety benefit to the operation of the plant. The ITS, consistent with the guidance in the ISTS, would delete or revise such operating limits.

These changes reflect the ISTS approach to provide LCO requirements that specify the protective conditions required to meet safety analysis assumptions for required R2 features. These conditions replace the lists of specific devices used in the CTS to describe the requirements needed to meet the safety analysis assumptions.

TS changes represented by this category allow operators to more clearly focus on issues important to safety. The resultant ITS LCOs maintain an adequate degree of protection consistent with the safety analysis. These changes also improve focus on issues important to safety and provide reasonable operational flexibility without adversely affecting the safe operation of the plant. Changes involving the relaxation of LCOs are consistent with the guidance established by the ISTS taking into consideration the PSL current licensing bases (CLB).

Category 2 - Relaxation of Applicability The CTS require compliance with an LCO during the applicable Mode(s) or other conditions specified in a Specifications Applicability statement. CTS Applicability tends to be more generalized for reactor conditions. ITS takes into consideration the ISTS which adds a level of detail to the applicable conditions that are consistent with the application of the plant safety analyses assumptions for operability of the required features.

Further, where CTS Applicability requirements are inconsistent with the applicable accident analyses assumptions for a system, subsystem, or component specified in E1-10

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 the LCO, changes are proposed to the LCO to establish a consistent set of requirements in the ITS. These modifications or deletions are acceptable because, during the operational or other conditions specified in the ITS Applicability requirements, the LCOs are consistent with the applicable safety analyses.

Changes involving relaxation of applicability requirements are consistent with the guidance established by the ISTS, taking into consideration the PSL CLB.

Category 3 - Relaxation of Completion Time Upon discovery of a failure to meet an LCO, the TSs specify time limits for completing Required Actions of the associated TS Conditions. Required Actions establish remedial measures that must be taken within specified Completion Times.

Completion Times specify limits on the duration of plant operation in a degraded condition. Incorporating longer Completion Times is acceptable because such Completion Times continue to be based on the operability status of redundant TS required features, the capacity and capability of remaining TS required features, provision of a reasonable time for repairs or replacement of required features, vendor developed standard repair times, and the low probability of a design bases accident (DBA) occurring during the repair period. Changes involving relaxation of Completion Times are consistent with the guidance established by the Commission, taking into consideration the PSL CLB. These changes are generally made to conform to NUREG-1432 and have been evaluated to not be detrimental to plant safety.

Category 4 - Relaxation of Required Action R2 LCOs specify the lowest functional capability or performance level of equipment that is deemed adequate to ensure safe operation of the facility. When an LCO is not met, the TSs specify actions to restore the equipment to its required capability or performance level, or to implement remedial measures providing an equivalent level of protection. These actions minimize the risk associated with continued operation while providing time to repair inoperable features. Some of the Required Actions are modified to place the plant in a MODE in which the LCO does not apply. Adopting Required Actions from NUREG-1432 is acceptable because the Required Actions take into account the operability status of redundant systems of required features, the capacity and capability of the remaining features, and the compensatory attributes of the Required Actions as compared to the LCO requirements.

Compared to CTS required actions, certain proposed ITS actions would result in extending the period during which the licensee may continue to operate the plant with specified equipment inoperable. Upon expiration of this period, further action, which may include shutting down the plant, is required. These ITS actions provide measures that adequately compensate for the inoperable equipment and are commensurate with the safety importance of the inoperable equipment, plant design, and industry practice. Therefore, these action requirements will continue to ensure safe operation of the plant. Changes involving relaxations of action requirements are consistent with the guidance established by the ISTS, taking into consideration the PSL CLB.

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St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 Category 5 - Deletion of Surveillance Requirement The CTS requires maintaining LCO specified structures, systems, and components (SSCs) operable by meeting SRs in accordance with specified SR frequencies. This includes conducting tests to demonstrate that such SSCs are operable and that LCO-specified parameters are within specified limits. When the test acceptance criteria and any specified conditions for the conduct of the test are met, the equipment is deemed operable. The changes of this category relate to deletion of CTS SRs, deletion of acceptance criteria, and deletion of the conditions required for performing the SR.

The ITS eliminates unnecessary CTS SRs that do not contribute to verification that equipment can perform its required functions to meet an LCO. Deleting the SRs, including acceptance criteria and/or conditions for performing the SRs, for these items is consistent with the objective of the ISTS, without reducing confidence that the equipment is operable. Appropriate equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its safety functions. For example, the CTS contain SRs that are not included in the ISTS for a variety of reasons. These SRs include measuring values and parameters that are not necessary to meet ISTS LCO requirements. In addition, the ISTS may not include reference to specific acceptance criteria contained in the CTS, because these acceptance criteria are not necessary to meet ISTS LCO requirements or are defined in other licensee-controlled documents.

The deletion of SRs is acceptable because appropriate testing standards are retained for determining that the LCO required features are operable as defined by the ISTS. R2 Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria Prior to placing the plant in a specified operational Mode or other condition stated in the Applicability of an LCO, and in accordance with the specified SR time interval thereafter, the CTS requires establishing the operability of each LCO-required component by meeting the SRs associated with the LCO. This usually entails performance of tests to demonstrate the operability of the LCO-required components, or the verification that specified parameters are within LCO limits. A successful demonstration of operability requires meeting the specified acceptance criteria, as well as any specified conditions, for the conduct of the test. Relaxations of CTS SRs can include relaxing both the acceptance criteria and the conditions of performance.

For example, the ITS allows some SRs to verify operability under actual or test conditions. Adopting the ITS allowance for these conditions is acceptable because required features cannot distinguish between an "actual" signal or a "test" signal.

Also included are changes to CTS SRs that are replaced in the ITS with separate and distinct testing requirements that, when combined, provide operability verification of all components required in the LCO for the features specified in the CTS. Changes that provide exceptions to SRs to allow for variations that do not affect the results of the test are also included in this category.

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St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 These relaxations of CTS SRs optimize test requirements for the affected safety systems and increase operational flexibility. The CTS SR relaxations are consistent with the guidance established by the ISTS in consideration of the PSL CLB.

Category 7 - Relaxation of Surveillance Frequency Prior to placing the plant in a specified operational Mode or other condition stated in the applicability of an LCO, and in accordance with the specified SR time interval (frequency) thereafter, the CTS requires establishing the operability of each LCO required component by meeting the SRs associated with the LCO. This usually entails performance of tests to demonstrate the operability of the LCO-required components, or the verification that specified parameters are within LCO limits. A successful demonstration of operability requires meeting the specified acceptance criteria, as well as any specified conditions, for the conduct of the test, at a specified frequency based on the reliability and availability of the LCO-required components.

Category 7 relaxations of CTS SRs include extending the interval between the SRs.

Increasing the time interval between Surveillance tests in the ITS results in decreased equipment unavailability due to testing. Relaxation of Surveillance Frequency can also include the addition of Surveillance Notes that allow testing to be delayed until appropriate unit conditions for the test are established, or exempt testing in certain Modes or specified conditions in which the testing cannot be performed.

Reduced testing is also acceptable where operating experience or other R2 deterministic criteria have demonstrated that these components usually pass the Surveillance when performed at the specified interval, thus the Surveillance Frequency is acceptable from a reliability standpoint. Surveillance Frequency changes to incorporate alternate train testing have also been shown to be acceptable where other qualitative or quantitative test requirements are required that are established predictors of system performance.

These CTS SR frequency relaxations are consistent with the guidance established by the ISTS taking into consideration the PSL CLB.

Category 8 - Deletion of Surveillance Requirement Shutdown Performance Requirement The CTS require maintaining LCO specified SSCs operable by meeting SRs in accordance with specified SR frequencies. This includes conducting tests to demonstrate that such SSCs are operable and that LCO specified parameters are within specified limits. When the test acceptance criteria and any specified conditions for the conduct of the test are met, the equipment is deemed operable.

The changes of this category relate to deletion of CTS SRs required to be performed during shutdown conditions.

Category 8 changes do not include the restriction on unit conditions. The control of the unit conditions, appropriate to perform a test, is an issue for procedures and scheduling, which give proper regard for surveillance performance and the effect on E1-13

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 the safe operation of the plant and has been determined by the NRC staff to be unnecessary as a TS restriction. As indicated in NRC-issued Generic Letter (GL) 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991, allowing this control of unit conditions for test performance is consistent with the vast majority of other TS Surveillances that do not dictate unit conditions for the Surveillance. This change is R2 designated as less restrictive because the Surveillance may be performed at plant conditions other than shutdown.

New Surveillance Frequencies have been evaluated to ensure that an acceptable level of equipment reliability is provided. The performance of the Surveillances will continue to be limited to conditions where an assessment has determined that plant safety will either be maintained or enhanced.

ISTS Markup and Justification for Deviations (JFDs)

This section contains a markup of the NUREG-1432, Volume 1, ISTS pages, either for ISTS pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the PSL ITS, and JFDs from the ISTS. The ISTS pages are annotated with a numeric designator to identify the differences between the ISTS and the proposed ITS. The designator corresponds to a JFD, which provides the justification for the difference. Where a JFD is applicable to only Unit 1 or Unit 2, it is identified as such at the beginning of the JFD in bold text. The JFDs are located directly following the associated ISTS markup for each Chapter, Section, or Specification, as applicable.

The left-hand margin of the ISTS markup pages includes a cross-reference to the equivalent CTS requirement.

ISTS Bases Markup and JFDs This section contains a markup of the NUREG-1432, Volume 2, ISTS Bases pages, either for ISTS Bases pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the PSL Unit 1 and 2 ITS, and JFDs from the ISTS Bases. The ISTS Bases pages are annotated with a numeric designator to identify the differences between the ISTS Bases and the proposed ITS Bases. The designator corresponds to a JFD, which provides the justification for the difference. Where a JFD is applicable to only Unit 1 or Unit 2, it is identified as such at the beginning of the JFD in bold text. The Bases JFDs are located directly following the associated ISTS Bases markup for each Chapter, Section, or Specification, as applicable. The volumes for ITS Chapters 1.0, 4.0, and 5.0 do not include this section, because NUREG-1432 does not include any Bases for these Chapters.

Determination of NSHC This section contains the determination in accordance with 10 CFR 50.91(a)(1) using the criteria of 10 CFR 50.92(c) to support a finding of NSHC. For changes covered by a generic NSHC, the generic NSHCs are in Volume 2. For less restrictive changes not covered by a generic less restrictive category or have been determined to be a change beyond the CTS and the ITS, a specific NSHC evaluation has been performed. Each E1-14

St Lucie Plant, Units 1 and 2 L-2023-126 R2 Dockets 50-335 and 50-389 Enclosure 1 evaluation is annotated to correspond to the DOC discussed in the specific NSHC evaluation. For ITS Chapters, Sections, or Specifications for which the changes are covered by a generic NSHC evaluation, a statement that there are no specific NSHCs is provided.

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St. Lucie Plant Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 3 ENCLOSURE 3 LICENSEE IDENTIFIED CHANGES THAT MAY REQUIRE TECHNICAL BRANCH REVIEW (2 TOTAL PAGES, INCLUDING COVER SHEETS)

LICENSEE IDENTIFIED CHANGES THAT MAY REQUIRE TECHNICAL BRANCH REVIEW Changes included in the Improved Technical Specifications (ITS) conversion submittal that are not consistent with the Current Technical Specifications (CTS) and are not the result of adopting the Improved Standard Technical Specifications (ISTS) as described in NUREG-1432, Rev. 5.0. The following is a list of changes identified in Enclosure 2 that meet this criterion in the St. Lucie Plant (PSL), Unit 1 and Unit 2 ITS conversion submittal, but do not involve a design change to the plant:

1. Change to Engineered Safety Features Actuation System (ESFAS) Main Steam Isolation Signal (MSIS) manual and automatic actuation logic Applicability and action change to match the supported systems Technical Specifications actions.

The change is not technical in nature, but rather aligns the MSIS instrumentation actions with the supported system actions. (Refer to Enclosure 2, Volume 8, ITS Section 3.3.4, Discussion of Change (DOC) L01)

2. Add risk informed completion time (RICT) to Unit 1 ESFAS automatic actuation logic and Unit 2 ESFAS MSIS manual actuation. The change is supported by the existing RICT Program and configuration risk management program previously approved in License Amendments 247 and 199, for Unit 1 and Unit 2, respectively.

Unit 2 ESFAS automatic actuation logic already applies RICT and both Unit 1 and Unit 2 already apply RICT to manual actuation channels. (Refer to Enclosure 2, Volume 8, ITS 3.3.4 DOCs L04 and L05)

3. Add previously approved program requirements in the Unit 2 Reactor Coolant Pump (RCP) Flywheel Program in addition to the current requirements based on the RCP Flywheel material. In addition, RCP Flywheel Program are proposed for the Unit 1 Technical Specifications and include the same requirements based on RCP flywheel material. Both testing methods have been previously approved by the NRC for PSL. (Refer to Enclosure 2, Volume 16, ITS 5.5, DOCs M01 and L02)

4. The periodic frequency of selected Surveillances in ITS Section 5.5 are proposed to be relocated to the Surveillance Frequency Control Program (SFCP). This deviation from ISTS Rev. 5 and Technical Specification Task Force (TSTF)

Traveler TSTF-425 has been previously approved for at least three (3) plants. PSL currently has an approved SFCP. (Refer to Enclosure 2, Volume 16, ITS 5.5, DOC LA01)

E3-1

St. Lucie Plant Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 4 ENCLOSURE 4 DISPOSITION OF EXISTING LICENSE AMENDMENT REQUESTS (2 TOTAL PAGES, INCLUDING COVER SHEETS)

St. Lucie Plant Units 1 and 2 L-2023-126 Docket Nos. 50-335 and 50-389 Enclosure 4 R2 DISPOSITION OF EXISTING LICENSE AMENDMENT REQUESTS The following License Amendment Requests are under NRC review. The following R2 table describes the request, and its effect on the ITS conversion, and its disposition.

DISPOSITION OF EXISTING LICENSE AMENDMENT REQUESTS Submittal Description of Change Affected ITS Affected Disposition Date Submittal CTS Specifications Pages December Permit the application of ITS 3.8.7 Unit 1 pg. NRC approved by 21, 2020 risk-informed completion ITS 3.8.9 3/4 8-8 Amendments 252/207 times (RICT) for the Unit 2 pg. Unit 1/ Unit 2 120-Volt AC Instrument Bus 3/4 8-15 respectively) (ADAMS requirements, consistent Accession No.

with TSTF-505, Revision 2, ML21342A209)

"Provide Risk-Informed January 14, 2022, Extended Completion changes incorporated Times RITSTF Initiative in ITS conversion 4b". submittal.

Subsequent License Renewal Application seeking to extend the term of each operating license by 20 years beyond its current expiration date.

August 3, This application also seeks Currently with the None None 2021 renewal of the source NRC for review R2 material, special nuclear material, and by-product material licenses that are subsumed in or combined with each of the Facility Operating Licenses License Amendment October 4, Request for Common Currently with the None None 2022 Emergency Plan Consistent NRC for review.

with NUREG-0654 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization December Currently with the and Treatment of None None 2, 2022 NRC for review.

Structures, Systems and Components for Nuclear Power Reactors" E4-1

St. Lucie Plant Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 5 ENCLOSURE 5 REGULATORY COMMITMENTS (2 TOTAL PAGES, INCLUDING COVER SHEETS)

REGULATORY COMMITMENTS No. Commitments for TSTF-500 Due Date/Event 1 Revise or develop plant procedures, as applicable, Upon Implementation to address the following:

• minimum required procedural time to measure battery float current is at least 30 seconds or as recommended by the float current measurement instrument manufacturer. This minimum float current measurement time is required to provide a more accurate battery float current reading.

• routinely monitor battery room temperature such that a room temperature excursion could reasonably expect to be detected and corrected prior to the average battery electrolyte temperature dropping below the minimum electrolyte temperature.

• verification of the selection of the pilot cell or cells when performing the Surveillance that verifies the float voltage of each connected battery cell.

• ensure that the modified performance discharge test completely encompasses the load profile of the battery service test and that it adequately confirms the intent of the service test to verify the battery capacity to supply the design basis load profile.

2 Relocate the following requirements to the Battery Monitoring and Maintenance Program and Upon Implementation implementing procedures:

• Battery cell resistance limits in existing Surveillance

• Monitoring of battery parameters (i.e., specific gravity, electrolyte level, cell temperature, float voltage, connection resistance, and physical condition)

St. Lucie Plant Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 6 ENCLOSURE 6 LIST OF REQUIRED UPDATED FINAL SAFETY ANALYSIS REPORT (UFSAR)

DESCRIPTIONS FOR TSTF 500 (2 TOTAL PAGES, INCLUDING COVER SHEETS)

LIST OF REQUIRED UPDATED FINAL SAFETY ANALYSIS REPORT (UFSAR)

DESCRIPTIONS FOR TSTF-500 The following table identifies UFSAR descriptions for the 125 VDC batteries required by St. Lucie Plant (PSL), Units 1 and Unit 2, as part of the adoption of TSTF-500, DC Electrical Rewrite - Update to TSTF-360, Revision 2. These changes will be included with the required implementation date in the Issuance of Amendment letter.

REQUIRED UFSAR DESCRIPTION DUE DATE/EVENT PSL will change or verify that the UFSAR: Upon implementation

1. Describes how a 5 percent design margin for the batteries (applies to all) corresponds to a 2 amp float current value indicating that the battery is 95 percent charged.

2. States that long term battery performance is supported by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer.

3. Describes how the batteries are sized with correction margins that include temperature and aging and how these margins are maintained.

4. States the minimum established design limit for battery terminal float voltage.

5. States the minimum established design limit for electrolyte level.

6. States the minimum established design limit for electrolyte temperature.

7. Describes how each battery is designed with additional capacity above that required by the design duty cycles to allow for temperature variations and other factors.

8. Describes normal DC system operation, i.e., powered from the battery chargers with the batteries floating on the system, and a loss of normal power to the battery charger describing how the DC load is automatically powered from the station batteries.

St. Lucie Plant Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 ENCLOSURE 7 ST LUCIE PLANT, UNITS 1 AND 2 PROPOSED REVISIONS TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSES DPR-67 AND NPF-16 (30 TOTAL PAGES, INCLUDING COVER SHEETS)

St Lucie Plant, Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 Table of Contents Discussion of Proposed Revisions to St Lucie Plant Units 1 and 2 Operating Licenses ...................................................................................... E7-1 Proposed Revision to St. Lucie Plant Unit No. 1 Subsequent Renewed Facility Operating License No. DPR-67 ......................................... A-1 Proposed Revision to St. Lucie Plant Unit No. 2 Subsequent Renewed Facility Operating License No. NPF-16 ......................................... B-1 ii

St Lucie Plant, Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 Discussion of Proposed Revisions to St. Lucie Plant Units 1 and 2 Operating Licenses Converting the St Lucie Plant (PSL) Unit 1 and Unit 2 Technical Specifications to the Improved Technical Specifications (ITS) includes the relocation of certain Technical Specifications previously included in Appendix A of the PSL Units 1 and 2 operating licenses to other licensee-controlled documents. The conversion to the ITS also includes the addition of some Surveillance Requirements (SRs), more restrictive changes to the acceptance criteria of selected SRs, and Frequency interval changes to selected SRs. As a result, Florida Power &

Light Company (FPL) proposes a revision to the PSL Unit 1 and Unit 2 subsequent renewed operating licenses to include a license condition regarding implementation of relocated Technical Specification requirements and a schedule for new and revised SRs.

Additionally, a number of license conditions have been satisfied at PSL and are no longer required. As a result, FPL proposes to delete these license conditions.

Attachments A and B of this enclosure provide proposed revisions to Subsequent Renewed Facility Operating Licenses DPR-67 (Unit 1) and NPF-16 (Unit 2), respectively.

The following provides a discussion of each license condition proposed for deletion with a justification for acceptability.

St. Lucie Plant - Unit 1 License Conditions License Condition 3.C, "Updated Final Safety Analysis Report License Condition C states, "The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on March 28, 2003, describes certain future activities to be completed before the period of extended operation. The licensee shall complete these activities no later than March 1, 2016 (Unit 2) and April 6, 2023 (Unit 1), and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on March 28, 2003, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following issuance of this renewed license. Until that update is complete, FPL may make changes to the programs described in such supplement without prior Commission approval, provided that FPL evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section."

FPL has notified that NRC that implementation is complete and the referenced activities can be verified by NRC inspection (Reference 1). Therefore, the subject license condition is no longer necessary and can be deleted.

E7-1

St Lucie Plant, Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 Transition License Conditions of License Condition 3.E.

License Condition E, Fire Protection, specifies three transition license conditions that were required to be completed before achieving full compliance with 10 CFR 50.48(c) for the PSL Fire Protection Program (FPP).

• Transition License Condition #1 prevented risk informed changes to the FPP until Transition License Conditions #2 and #3 were completed unless approved by the NRC beforehand or the change was demonstrated to have no more than a minimal risk impact.

• Transition License Condition #2 required the completion of the facility modifications as described in Table S-1, "Plant Modifications Committed," Attachment S, of Florida Power

& Light letter L-2017-058, dated May 2, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup of SL 1-28 (spring 2018) and SL2-24 (fall 2018) refueling outages after issuance of the SE. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

• Transition License Condition #3 required implementing the items listed in Attachment S, Table S-2, "Implementation Items," of FPL letter L-2015-211 dated August 21, 2015, with the exception of items 18 and 20, within 12 months after NRC approval unless that falls within a scheduled outage window, then in that case, completion will occur 60 days after startup from that scheduled outage. Implementation Item 18 is an exception because it is associated with modifications in Table S-1 and will be completed in accordance with Transition License Condition 2) above. Item 20 is also an exception because it is required to be completed prior to self-approval and will be completed prior to the startup of SL2-24 (fall 2018).

These three transient license conditions are no longer necessary since the required facility modifications have been completed and the applicable items specified by Transition License Condition #3 have been completed. As such, these transition license conditions can be deleted.

License Condition 3.H, Control Room Habitability Upon implementation of Amendment No. 205, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.7.1.e, in accordance with TS 6.8.4.m, the assessment of CRE habitability as required by Specification 6.8.4.m.c.(ii), and the measurement of CRE pressure as required by Specification 6.8.4.m.d, shall be considered met.

Following implementation:

(a) The first performance of SR 4.7.7.1.e, in accordance with Specification 6.8.4.m.c(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.8.4.m.c(ii),

shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01, or E7-2

St Lucie Plant, Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.8.4.c.d, shall be within 36 months in a staggered test basis, plus the 138 days allowed by SR 4.0.2, as measured from June 30, 2006, which is the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

These Control Room Habitability license conditions are no longer necessary since the required testing has been completed. As such, these license conditions can be deleted.

License Condition 3.I, RODEX2 Safety Analysis RODEX2 has been specifically approved for use for St. Lucie Unit 1 licensing basis analyses. Upon NRCs approval of a generic supplement to the RODEX2 code and associated methods that accounts for thermal conductivity degradation (TCD), FPL will within six months:

(a) Demonstrate that St. Lucie Unit 1 safety analyses remain conservatively bounded in licensing basis analyses when compared to the NRC-approved generic supplement to the RODEX2 methodology, or (b) Provide a schedule for the re-analysis using the NRC-approved generic supplement to the RODEX2 methodology for any of the affected licensing basis analyses.

This license condition is no longer necessary since the subject safety analyses have been demonstrated to remain conservatively bounded by the licensing basis using a methodology acceptable to the NRC.

Therefore, this license condition can be deleted.

St. Lucie Plant - Unit 2 License Conditions License Condition 3.C, "Updated Final Safety Analysis Report License Condition C states, "The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on March 28, 2003, describes certain future activities to be completed before the period of extended operation. The licensee shall complete these activities no later than March 1, 2016 (Unit 2) and April 6, 2023 (Unit 1), and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on March 28, 2003, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following issuance of this renewed license. Until that update is complete, FPL may make changes to the programs described in such supplement without prior Commission approval, provided that FPL evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section."

FPL has notified that NRC that implementation is complete and the referenced activities can be verified by NRC inspection (Reference 2). Therefore, the subject license condition is no longer necessary and can be deleted.

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St Lucie Plant, Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 Transition License Conditions of License Condition 3.E.

License Condition 3.E, Fire Protection, specifies three transition license conditions that were required to be completed before achieving full compliance with 10 CFR 50.48(c) for the PSL Fire Protection Program (FPP).

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk informed changes to Florida Power & Light Company fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2) above; (2) The licensee shall implement the modifications to its facility, as described in Table S-1 , "Plant Modifications Committed," Attachment S, of Florida Power & Light letter L-2017-058, dated May 2, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup of SL1-28 (spring 2018) and SL2-24 (fall 2018) refueling outages after issuance of the SE. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications; and (3) The licensee shall implement the items listed in Attachment S, Table S-2, "Implementation Items," of FPL letter L-2015-211 dated August 21, 2015, with the exception of items 18 and 20, within 12 months after NRC approval unless that falls within a scheduled outage window, then in that case, completion will occur 60 days after startup from that scheduled outage.

Implementation Item 18 is an exception because it is associated with modifications in Table S-1 and will be completed in accordance with Transition License Condition 2) above. Item 20 is also an exception because it is required to be completed prior to self-approval and will be completed prior to the startup of SL2-24 (fall 2018).

These three transient license conditions are no longer necessary since the required facility modifications have been completed and the applicable items specified by Transition License Condition #3 have been completed. As such, these transient license conditions can be deleted.

License Condition 3.M, Control Room Habitability Upon implementation of Amendment No. 153, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.7.e, in accordance with TS 6.15, the assessment of CRE habitability as required by Specification 6.15.c.(ii), and the measurement of CRE pressure as required by Specification 6.15.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.7.e, in accordance with Specification 6.15.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.15.c.(ii),

shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

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St Lucie Plant, Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 (c) The first performance of the periodic measurement of CRE pressure, Specification 6.15.d, shall be within 36 months in a staggered test basis, plus the 138 days allowed by SR 4.0.2, as measured from November 13, 2006, which is the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

This license condition is no longer necessary since the required testing and initial assessment have been completed. Therefore, this license condition can be deleted.

References

1. FPL Letter from Christopher Costanzo to U. S. Nuclear Regulatory Commission dated September 30, 2015, "Completion of License Renewal Activities before Period of Extended Operation Phase 2 Inspection Readiness," (ADAMS Accession No. ML15282A479)

2. FPL Letter from Daniel DeBoer to U. S. Nuclear Regulatory Commission dated June 28, 2017, "Completion of License Renewal Activities before Period of Extended Operation Phase 2 Inspection Readiness," ML17179A425 E7-5

St Lucie Plant, Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 ATTACHMENT A PROPOSED REVISION TO ST LUCIE PLANT UNIT NO. 1 SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-67 A-1

FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-335 ST. LUCIE PLANT UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-67 The U.S. Nuclear Regulatory Commission (the Commission) having previously made the findings set forth in License No. DPR-67 issued March 1, 1976, has now found that:

a. The application to renew License No. DPR-67 filed by the Florida Power and Light Company (FPL or the licensee), complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter 1, and all required notifications to other agencies or bodies have been duly made;

b. Actions have been identified and have been or will be taken with respect to (1) managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21(a)(1), and (2) time-limited aging analyses that have been identified to require review under 10 CFR 54.21(c), such that there is reasonable assurance that the activities authorized by this renewed license will continue to be conducted in accordance with the current licensing basis, as defined in 10 CFR 54.3, for St. Lucie Plant Unit No.1, and that any changes made to the plants current licensing basis in order to comply with 10 CFR 54.29(a) are in accord with the Act and the Commissions regulations;

c. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission;

d. There is reasonable assurance: (i) that the activities authorized by this renewed operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission;

e. FPL is technically and financially qualified to engage in the activities authorized by this renewed operating license in accordance with the rules and regulations of the Commission;

f. FPL has satisfied the applicable provisions of 10 CFR Part 140, Financial Protection Requirements and Indemnity Agreements, of the Commissions regulations;

g. The renewal of this operating license will not be inimical to the common defense and security or to the health and safety of the public; and

h. After weighing the environmental, economic, technical, and other benefits of the facility against environmental and other costs and considering available alternatives, the Renewed License No. DPR-67 Enclosure 1

issuance of Renewed Facility Operating License No. DPR-67, subject to the conditions for protection of the environment set forth herein, is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

On the basis of the foregoing findings regarding this facility, Facility Operating License No. DPR-67, issued March 1, 1976, is superseded by Renewed Facility Operating License No. DPR-67, which is hereby issued to FPL to read as follows:

1. This renewed license applies to the St. Lucie Plant, Unit No. 1, a pressurized water nuclear reactor, and associated steam generators and electrical generating equipment (the facility). The facility is located on the licensees site on Hutchinson Island in St. Lucie County, Florida, and is described in the Updated Final Safety Analysis Report, as supplemented and amended, and the Environmental Report, as supplemented and amended.

2. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses FPL:

A. Pursuant to Section 104b of the Act and 10 CFR Part 50, Licensing of Production and Utilization Facilities, to possess, use, and operate the facility as a utilization facility at the designated location on the St. Lucie site in accordance with the procedures and limitations set forth in this renewed license; B. Pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report as supplemented and amended; C. Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; D. Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material, without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and E. Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

3. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all Renewed License No. DPR-67

applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A. Maximum Power Level FPL is authorized to operate the facility at steady state reactor core power levels not in excess of 3020 megawatts (thermal).

B. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 252 253 are hereby incorporated in the renewed license. FPL shall operate the facility in accordance with the Technical Specifications.

Appendix B, the Environmental Protection Plan (Non-Radiological), contains environmental conditions of the renewed license. If significant detrimental effects or evidence of irreversible damage are detected by the monitoring programs required by Appendix B of this license, FPL will provide the Commission with an analysis of the problem and plan of action to be taken subject to Commission approval to eliminate or significantly reduce the detrimental effects or damage.

C. DeletedUpdated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on March 28, 2003, describes certain future activities to be completed before the period of extended operation. FPL shall complete these activities no later than March 1, 2016, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on March 28, 2003, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following issuance of this renewed license. Until that update is complete, FPL may make changes to the programs described in such supplement without prior Commission approval, provided that FPL evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

D. Sustained Core Uncovery Actions Procedural guidance shall be in place to instruct operators to implement actions that are designed to mitigate a small-break loss-of-coolant accident prior to a calculated time of sustained core uncovery.

Renewed License No. DPR-67 Amendment No. 252

E. Fire Protection Florida Power & Light Company (FPL) St. Lucie Plant Unit 1 shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated March 22, 2013 and May 2, 2017, and supplements dated June 14, 2013, February 24, 2014, March 25, 2014, April 25, 2014, July 14, 2014, August 27, 2014, September 10, 2014, October 10, 2014, March 10, 2015, April 1, 2015, April 20, 2015, May 12, 2015, August 21, 2015, and October 22, 2015, and as approved in the safety evaluation report (SE) dated March 31, 2016 and October 23, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10-7/year (yr) for CDF and less than 1 x 10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

Renewed License No. DPR-67 Amendment No. 231,242

Other Changes that May Be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program.

Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified, fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3.8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.10); and,

• "Passive Fire Protection Features" (Section 3.11)

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC SE dated March 31, 2016 to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Renewed License No. DPR-67 Amendment No. 231

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk informed changes to Florida Power & Light Company fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2) above; (2) The licensee shall implement the modifications to its facility, as described in Table S-1 , "Plant Modifications Committed," Attachment S, of Florida Power

& Light letter L-2017-058, dated May 2, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup of SL 1-28 (spring 2018) and SL2-24 (fall 2018) refueling outages after issuance of the SE. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications; and (3) The licensee shall implement the items listed in Attachment S, Table S-2, "Implementation Items," of FPL letter L-2015-211 dated August 21, 2015, with the exception of items 18 and 20, within 12 months after NRC approval unless that falls within a scheduled outage window, then in that case, completion will occur 60 days after startup from that scheduled outage.

Implementation Item 18 is an exception because it is associated with modifications in Table S-1 and will be completed in accordance with Transition License Condition 2) above. Item 20 is also an exception because it is required to be completed prior to self-approval and will be completed prior to the startup of SL2-24 (fall 2018).

Renewed License No. DPR-67 Amendment No. 231, 242

F. Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: Florida Power and Light &

FPL Energy Seabrook Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan - Revision 3, submitted by letter dated May 18, 2006. St. Lucie shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The St. Lucie CSP was approved by License Amendment No. 211 as supplemented by a Clarification approved by License Amendment Nos. 214 and 222.

G. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment Renewed License No. DPR-67 Amendment No. 202, 211, 214, 222, 231

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders H. DeletedControl Room Habitability Upon implementation of Amendment No. 205, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.7.1.e, in accordance with TS 6.8.4.m, the assessment of CRE habitability as required by Specification 6.8.4.m.c. (ii), and the measurement of CRE pressure as required by Specification 6.8.4.m.d, shall be considered met.

Following implementation:

(a) The first performance of SR 4.7.7.1.e, in accordance with Specification 6.8.4.m.c(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.8.4.m.c(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.8.4.c.d, shall be within 36 months in a staggered test basis, plus the 138 days allowed by SR 4.0.2, as measured from June 30, 2006, which is the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

I. DeletedRODEX2 Safety Analyses RODEX2 has been specifically approved for use for St. Lucie Unit 1 licensing basis analyses. Upon NRCs approval of a generic supplement to the RODEX2 code and associated methods that accounts for thermal conductivity degradation (TCD), FPL will within six months:

(a) Demonstrate that St. Lucie Unit 1 safety analyses remain conservatively bounded in licensing basis analyses when compared to the NRC-approved generic supplement to the RODEX2 methodology, or (b) Provide a schedule for the re-analysis using the NRC-approved generic supplement to the RODEX2 methodology for any of the affected licensing basis analyses.

Renewed License No. DPR-67 Amendment No. 213, 214, 231

J. FPL is authorized to implement the Risk Informed Completion Time Program as approved in License Amendment No. 247 and 252 subject to the following conditions:

1. Deleted

2. The risk assessment approach and methods, shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant; and reflect the operating experience of the plant as specified in RG 1.200.

Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRC for generic use. If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRC approval via a license amendment.

K. Improved Technical Specifications Implementation License Conditions

1. Relocation of Certain Technical Specification Requirements License Amendment 253 authorizes the relocation of certain Technical Specifications previously included in Appendix A to other licensee-controlled documents. Implementation of this amendment shall include relocation of the requirements to the specified documents, as described in Table R, Relocated Specifications and Removed Detail Changes, attached to the NRC staffs Safety Evaluation, which is enclosed in this amendment.

2. Schedule for New and Revised Surveillance Requirements (SRs)

The schedule for performing SRs that are new or revised in License Amendment 253 shall be as follows:

a. For SRs that are new in this amendment, the first performance is due at the end of the first Surveillance interval, which begins on the date of implementation of this amendment.

b. For SRs that existed prior to this amendment, whose intervals of performance are being reduced, the first reduced Surveillance interval begins upon completion of the first Surveillance performed after implementation of this amendment.

c. For SRs that existed prior to this amendment, whose intervals of performance are being extended, the first extended Surveillance interval begins upon completion of the last Surveillance performed prior to implementation of this amendment.

Renewed License No. DPR-67 Amendment No. 213, 231, 247, 252, 253

d. For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance subject to the modified acceptance criteria is due at the end of the first Surveillance interval that began on the date the Surveillance was last performed prior to the implementation of this amendment.

4. This renewed license is effective as of the date of issuance and shall expire at midnight on March 1, 2036.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:

1. Appendix A, Technical Specifications

2. Appendix B, Environmental Protection Plan Renewed License No. DPR-67 Amendment No. 213, 231, 247, 252, 253

St Lucie Plant, Units 1 and 2 L-2023-126 Dockets 50-335 and 50-389 Enclosure 7 ATTACHMENT B PROPOSED REVISION TO ST LUCIE PLANT UNIT NO. 2 SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. NFP-16 B-1

FLORIDA POWER AND LIGHT COMPANY ORLANDO UTILITIES COMMISSION OF THE CITY OF ORLANDO. FLORIDA AND FLORIDA MUNICIPAL POWER AGENCY DOCKET NO. 50-389 ST. LUCIE PLANT UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-16 The U.S. Nuclear Regulatory Commission (the Commission) having previously made the findings set forth in License No. NPF-16 issued April 6, 1983, has now found that:

a. The application to renew License No. NPF-16 filed by the Florida Power and Light Company, Orlando Utilities Commission of the City of Orlando, Florida and Florida Municipal Power Agency (licensees), complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions regulations set forth in 10 CFR Chapter 1, and all required notifications to other agencies or bodies have been duly made;

b. Actions have been identified and have been or will be taken with respect to (1) managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21(a)(1), and (2) time-limited aging analyses that have been identified to require review under 10 CFR 54.21(c), such that there is reasonable assurance that the activities authorized by this renewed license will continue to be conducted in accordance with the current licensing basis, as defined in 10 CFR 54.3, for St. Lucie Plant Unit No. 2, and that any changes made to the plants current licensing basis in order to comply with 10 CFR 54.29(a) are in accord with the Act and the Commissions regulations;

c. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission;

d. There is reasonable assurance: (i) that the activities authorized by this renewed operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission; Renewed License No. NPF-16 Enclosure 2

e. Florida Power & Light Company (FPL) 1 is technically and financially qualified to engage in the activities authorized by this renewed operating license in accordance with the rules and regulations of the Commission;

f. FPL has satisfied the applicable provisions of 10 CFR Part 140, Financial Protection Requirements and Indemnity Agreements, of the Commissions regulations;

g. The renewal of this operating license will not be inimical to the common defense and security or to the health and safety of the public;

h. After weighing the environmental, economic, technical, and other benefits of the facility against environmental and other costs and considering available alternatives, the issuance of Renewed Facility Operating License No. NPF-16, subject to the conditions for protection of the environment set forth herein, is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

On the basis of the foregoing findings regarding this facility, Facility Operating License No. NPF-16, issued April 6, 1983, is superseded by Renewed Facility Operating License No. NPF-16, which is hereby issued to the licensees to read as follows:

1. This renewed license applies to the St. Lucie Plant, Unit No. 2, a pressurized water nuclear reactor, and associated steam generators and electrical generating equipment (the facility). The facility is located on the licensees' site on Hutchinson Island in St. Lucie County, Florida, and is described in the Updated Final Safety Analysis Report, as supplemented and amended, and the Environmental Report, as supplemented and amended.

2. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses:

A. Pursuant to Section 103 of the Act and 10 CFR Part 50, Florida Power & Light Company, Orlando Utilities Commission of the City of Orlando, Florida and Florida Municipal Power Agency to possess, use, and operate the facility as a utilization facility at the designated location on the St. Lucie site in accordance with the procedures and limitations set forth in this renewed license; B. Pursuant to the Act and 10 CFR Part 70, FPL to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report as supplemented and amended; C. Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed 1 Florida Power & Light Company is authorized to act as agent for the Orlando Utilities Commission of the City of Orlando, Florida and Florida Municipal Power Agency and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

Renewed License No. NPF-16

neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; D. Pursuant to the Act and 10 CFR Parts 30, 40, and 70, FPL to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material, without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and E. Pursuant to the Act and 10 CFR Parts 30 and 70, FPL to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A. Maximum Power Level FPL is authorized to operate the facility at steady state reactor core power levels not in excess of 3020 megawatts (thermal).

B. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 207208 are hereby incorporated in the renewed license. FPL shall operate the facility in accordance with the Technical Specifications.

Renewed License No. NPF-16 Amendment No. 2087

Appendix B, the Environmental Protection Plan (Non-Radiological), contains environmental conditions of the renewed license. If significant detrimental effects or evidence of irreversible damage are detected by the monitoring programs required by Appendix B of this license, FPL will provide the Commission with an analysis of the problem and plan of action to be taken subject to Commission approval to eliminate or significantly reduce the detrimental effects or damage.

C. DeletedUpdated Final Safety Analysis Report FPL's Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on March 28, 2003, describes certain future activities to be completed before the period of extended operation. FPL shall complete these activities no later than April 6, 2023, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on March 28, 2003, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following issuance of this renewed license. Until that update is complete, FPL may make changes to the programs described in such supplement without prior Commission approval, provided that FPL evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

D. Antitrust Conditions FPL shall comply with the antitrust conditions in Appendices C and D to this renewed license.

E. Fire Protection Florida Power & Light Company (FPL) St. Lucie Plant Unit 2 shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated March 22, 2013 and May 2, 2017, and supplements dated June 14, 2013, February 24, 2014, March 25, 2014, April 25, 2014, July 14, 2014, August 27, 2014, September 10, 2014, October 10, 2014, March 10, 2015, April 1, 2015, April 20, 2015, May 12, 2015, August 21, 2015, and October 22, 2015, and as approved in the safety evaluation report (SE) dated March 31, 2016 and October 23, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Renewed License No. NPF-16 Amendment No. 153, 181, 193, 208

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10-7/year (yr) for CDF and less than 1 x 10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

Other Changes that May Be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program.

Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to NFPA 805, Chapter 3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified, fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical Renewed License No. NPF-16 Amendment No. 181

arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3.8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.10); and,

• "Passive Fire Protection Features" (Section 3.11)

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC SE dated March 31, 2016 to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk informed changes to Florida Power & Light Company fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2) above; (2) The licensee shall implement the modifications to its facility, as described in Table S-1 , "Plant Modifications Committed," Attachment S, of Florida Power

& Light letter L-2017-058, dated May 2, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup of SL 1-28 (spring 2018) and SL2-24 (fall 2018) refueling outages after issuance of the SE. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications; and (3) The licensee shall implement the items listed in Attachment S , Table S-2, "Implementation Items," of FPL letter L-2015-211 dated August 21, 2015, with the exception of items 18 and 20, within 12 months after NRC approval unless that falls within a scheduled outage window, then in that case, completion will occur 60 days after startup from that scheduled outage.

Implementation Item 18 is an exception because it is associated with modifications in Table S-1 and will be completed in accordance with Transition License Condition 2) above. Item 20 is also an exception because it is required to be completed prior to self-approval and will be completed prior to the startup of SL2-24 (fall 2018).

Renewed License No. NPF-16 Amendment No. 181, 193, 208

F. Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: Florida Power and Light &

FPL Energy Seabrook Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan - Revision 3, submitted by letter dated May 18, 2006. St. Lucie shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The St. Lucie CSP was approved by License Amendment No. 160 as supplemented by a Clarification approved by License Amendment Nos. 164 and 172.

G. Before engaging in additional construction or operational activities which may result in a significant adverse environmental impact that was not evaluated or that is significantly greater than that evaluated in the Final Environmental Statement dated April 1982, FPL shall provide written notification to the Office of Nuclear Reactor Regulation.

H. DELETED I. FPL shall notify the Commission, as soon as possible but not later than one hour, of any accident at this facility which could result in an unplanned release of quantities of fission products in excess of allowable limits for normal operation established by the Commission.

J. FPL shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

K. The use of ZIRLO' clad fuel at St. Lucie Unit 2 will be subject to the following restrictions:

FPL will limit the fuel duty for St. Lucie Unit 2 to a baseline modified Fuel Duty Index (mFDI) of 600 with a provision for adequate margin to account for variations in core design (e.g., cycle length, plant operating conditions, etc). This limit will be applicable until data is available demonstrating the performance of ZIRLO' cladding at Combustion Engineering 16x16 plants.

FPL will restrict the mFDI of each ZIRLO' clad fuel pin to 110 percent of the baseline mFDI of 600.

For a fraction of the fuel pins in a limited number of assemblies (8), FPL will restrict the fuel duty of ZIRLO' clad fuel pins to 120 percent of the baseline mFDI of 600.

Renewed License No. NPF-16 Amendment No. 150, 160, 164, 172, 181

FPL shall not lift the ZIRLO' mFDI restriction discussed above without either NRC approval of a supplement to CENPD-404-P-A that includes corrosion data from two Combustion Engineering plants (not at the same site) or NRC approval of St. Lucie Unit 2 plant-specific corrosion data.

L. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders M. DeletedControl Room Habitability Upon implementation of Amendment No. 153, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.7.e, in accordance with TS 6.15, the assessment of CRE habitability as required by Specification 6.15.c.(ii), and the measurement of CRE pressure as required by Specification 6.15.d, shall be considered met. Following implementation:

(a) The first performance of SR 4.7.7.e, in accordance with Specification 6.15.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01.

(b) The first performance of the periodic assessment of CRE habitability, Specification 6.15.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from September 2003, the date of the most recent successful tracer gas test, as stated in FPL letters to Renewed License No. NPF-16 Amendment No. 153, 181, 208

NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6. 15.d, shall be within 36 months in a staggered test basis, plus the 138 days allowed by SR 4.0.2, as measured from November 13, 2006, which is the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

N. FATES38 Safety Analyses (Westinghouse Fuel Only)

FATES3B has been specifically approved for use for St. Lucie Unit 2 licensing basis analyses based on FPL maintaining the more restrictive operational/design radial power fall-off curve limits as specified in Attachment 4 to FPL Letter L-2012-121, dated March 31, 2012 as compared to the FATES3B analysis radial power fall-off curve limits. The radial power fall-off curve limits shall be verified each cycle as part of the Reload Safety Analysis Checklist (RSAC) process.

O. FPL is authorized to implement the Risk Informed Completion Time Program as approved in License Amendment No. 199 and 207 subject to the following conditions:

1. Deleted

2. The risk assessment approach and methods, shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant; and reflect the operating experience of the plant as specified in RG 1.200.

Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRC for generic use. If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRC approval via a license amendment.

P. Improved Technical Specifications Implementation License Conditions

1. Relocation of Certain Technical Specification Requirements License Amendment 208 authorizes the relocation of certain Technical Specifications previously included in Appendix A to other licensee-controlled documents. Implementation of this amendment shall include relocation of the requirements to the specified documents, as described in Table R, Relocated Specifications and Removed Detail Changes, attached to the NRC staffs Safety Evaluation, which is enclosed in this amendment.

2. Schedule for New and Revised Surveillance Requirements (SRs)

The schedule for performing SRs that are new or revised in License Amendment 208 shall be as follows:

Renewed License No. NPF-16 Amendment No. 163, 181, 199, 207, 208

a. For SRs that are new in this amendment, the first performance is due at the end of the first Surveillance interval, which begins on the date of implementation of this amendment.

b. For SRs that existed prior to this amendment, whose intervals of performance are being reduced, the first reduced Surveillance interval begins upon completion of the first Surveillance performed after implementation of this amendment.

c. For SRs that existed prior to this amendment, whose intervals of performance are being extended, the first extended Surveillance interval begins upon completion of the last Surveillance performed prior to implementation of this amendment.

d. For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance subject to the modified acceptance criteria is due at the end of the first Surveillance interval that began on the date the Surveillance was last performed prior to the implementation of this amendment.

Renewed License No. NPF-16 Amendment No. 208

4. This renewed license is effective as of the date of issuance and shall expire at midnight on April 6, 2043.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY J. E. Dyer, Director Office of Nuclear Reactor Regulation Attachments:

1. Appendix A, Technical Specifications

2. Appendix B, Environmental Protection Plan

3. Appendix C, Antitrust Conditions

4. Appendix D, Antitrust Conditions Daye of Issuance: October 2, 2003 Renewed License No. NPF-16 Amendment No. 163, 181, 182, 199