L-2002-117, To Proposed License Amendments Re Consolidated Line Item Improvement Process from Florida Power & Light Company
| ML022330463 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/15/2002 |
| From: | Jernigan D Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2002-117 | |
| Download: ML022330463 (26) | |
Text
Florida Power & Light Company, 6501 South Ocean Drive, Jensen Beach, FL 34957 0
August 15, 2002 FPL L-2002-117 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments - Supplement 2 Consolidated Line Item Improvement Process TSTF-358 - Missed Surveillance Requirements By letter L-2001-250 dated November 21, 2001 and supplemented by L-2002-02 on January 25, 2002, Florida Power & Light Company (FPL) submitted a request to amend the Technical Specifications (TS) for St. Lucie Units 1 and 2. The request was to modify the TS requirements for a missed surveillance using the consolidated line item improvement process (CLIIP). Implementation of the CLIIP, for plants that have not adopted the Standard Technical Specifications (STS) format, requires relocation of a portion of the existing Surveillance Requirement (SR) 4.0.3 to SR 4.0.1 to closely conform with the STS. By this letter, FPL is submitting revised wording for the TS and the TS Bases for Surveillance Requirements 4.0.1 and 4.0.3. is a description of the additional conforming changes necessary to implement TSTF-358. Attachment 2 is a No Significant Hazards and Environmental Considerations for the additional conforming changes.
The generic CLIIP safety evaluation, No Significant Hazards Consideration, and Environmental Consideration referenced in the original FPL submittal L-2001-250 as supplemented by L-2002-02 bound the changes to implement TSTF-358 and still apply for the changes that were previously submitted. Attachment 3 includes marked up copies of the existing Unit 1 and Unit 2 SR 4.0.1 and SR 4.0.3 for TSTF-358 implementation and the additional conforming amendments. Attachment 4 includes informational copies of the proposed revisions to the Unit 1 and Unit 2 TS Bases for SR 4.0.1 and SR 4.0.3 for TSTF-358 and the additional conforming amendments. Attachment 5 includes copies of the retyped Unit 1 and Unit 2 TS pages.
The St. Lucie Facility Review Group and the Florida Power & Light Company Nuclear Review Board have reviewed the proposed amendments. In accordance with 10 CFR an FPL Group company
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Page 2 50.91 (b)(1), copies of the proposed amendments are being forwarded to the State Designee for the State of Florida.
If you should have any questions regarding this submittal, please contact George Madden at 772-467-7155.
I declare under penalty of perjury under the laws of the United States of America that I am authoriz d by FPL to make this request and that the foregoing is true and correct.
ery uly yours, Donald Jerniga Vice Presi St. Lucie Plant DEJ/GRM Attachments cc:
Mr. William A. Passetti, Florida Department of Health
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 1 Page 1 ATTACHMENT I DESCRIPTION OF AMENDMENT REQUESTS
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 1 Page 2 DESCRIPTION OF AMENDMENT REQUESTS
==
Introduction:==
The proposed license amendments (PLAs) to Facility Operating Licenses DPR-67 for St. Lucie Unit I and NPF-16 for St. Lucie Unit 2 proposed by FPL letter L-2001 250 dated November 21, 2001 and supplemented by FPL letter 2002-02 dated January 25, 2002 conform closely to the industry and NRC approved TSTF-358 Revision 6. Based on discussions with the NRC staff, plants that have not adopted the Standard Technical Specifications require plant specific conforming changes to implement TSTF-358. For St.
Lucie Units 1 and 2, the additional changes are administrative conforming amendments to Surveillance Requirement (SR) 4.0.1. The additional changes relocate existing requirements from SR 4.0.3 to SR 4.0.1. The proposed changes conform closely to the industry and NRC approved NUREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 2 and TSTF-358 Revision 6. The generic CLIIP safety evaluation, no significant hazards consideration, and environmental consideration referenced in the original FPL submittal L-2001-250, as supplemented by L-2002-02, bound the changes to implement TSTF-358 and still apply for the changes that were previously submitted.
Background:
By letter L-2001-250 dated November 21, 2001, Florida Power & Light Company (FPL) submitted a request to amend the Technical Specifications (TS) for St.
Lucie Units 1 and 2. The request was to modify the TS requirements for a missed surveillance using the consolidated line item improvement process (CLIIP). The proposed amendments were similar to NRC approved Industry Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-358 Revision 6, however, the proposed wording was not the same as the approved CLIIP. On December 20, 2001, the NRC Project Manager for St. Lucie notified FPL that editorial changes made to the proposed wording in Surveillance Requirement 4.0.3 were not sufficiently consistent with the CLIIP. FPL had changed the wording in Surveillance Requirement 4.0.3 from "risk evaluation" to "risk assessment" in the original submittal.
By letter L-2002-02 dated January 25, 2002, FPL submitted revised wording for Surveillance Requirement 4.0.3 and the Bases for Surveillance Requirement 4.0.3 to closely conform to the wording of TSTF-358 with the following exceptions. There are only two justified changes necessary from the wording in TSTF-358 Revision 6. These were discussed with the NRC Project Manager and considered necessary because of plant specific differences between the plant's TSs and the TSTF wording. Section 3.0.3 is changed to 4.0.3 and "Conditions" is changed to "ACTION(s)". The St. Lucie TS does not have "Conditions," only "Actions".
During the spring of 2002, the NRC was working with specific utilities to develop a model for implementing the TSTF-358 CLIIP for plants that had not converted to the Standard Technical Specifications.
In June, the staff determined that for plants that had not converted to the STS, there was not sufficient consistency between the plants to develop a model applicable to all the plants. The generic CLIIP safety evaluation, no significant hazards consideration, and environmental consideration referenced in the original FPL
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment I Page 3 submittal L-2001-250, as supplemented by L-2002-02, bound the changes to implement TSTF-358 and still apply for the changes that were previously submitted.
For St. Lucie Units 1 and 2 the conforming changes required to implement TSTF-358 include relocating two requirements from SR 4.0.3 to SR 4.0.1. These requirements relate to surveillance interval extensions such that failure to perform surveillance tests within the surveillance interval and the allowable extension of 25 percent as specified in SR 4.0.2 constitutes noncompliance with the operability requirements of the Limiting Condition for Operation. The second requirement is the exception that surveillance tests do not need to be performed on inoperable equipment. These requirements are relocated from SR 4.0.3 to SR 4.0.1 to closely conform to the STS.
Description of the Changes:
Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation.
Surveillance Requirements do not have to be performed on inoperable equipment.
The changes to SR 4.0.3 proposed by FPL letters L-2001-250, as supplemented by FPL letter L-2002-02, remain unchanged by this submittal.
Justification of the Changes: The changes are administrative conforming amendments necessary to implement TSTF-358. The proposed changes relocate requirements from SR 4.0.3 to SR 4.0.1. By making the proposed changes, the St.
Lucie Unit 1 and 2 SR 4.0.3 and SR 4.0.1 will closely conform to the STS NUREG-1432 SR 3.0.1 and SR 3.0.3.
The generic CLIIP safety evaluation, no significant hazards consideration, and environmental consideration referenced in the original FPL submittal L-2001-250, as supplemented by L-2002-02, bound the changes to implement TSTF-358 and still apply for the changes that were previously submitted.
St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 2 Page 1 ATTACHMENT 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 2 Page 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Description of Amendment Request The additional changes to proposed license amendments (PLAs) to Facility Operating Licenses DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2 are administrative conforming amendments to Surveillance Requirement (SR) 4.0.1. The additional changes relocate existing requirements from SR 4.0.3 to SR 4.0.1. The proposed changes conform closely to the industry and NRC approved NUREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 2. The generic CLIIP safety evaluation, no significant hazards consideration, and environmental consideration referenced in the original FPL submittal L-2001-250 as supplemented by L-2002-02 bound the changes to implement TSTF-358 and still apply for the changes that were previously submitted.
Determination of No Significant Hazards Consideration Pursuant to 10 CFR 50.92, a determination may be made that a proposed license amendments involve no significant hazards consideration if operation of the facility in accordance with the proposed amendments would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Each standard is discussed as follows.
(1) Operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed amendments are administrative in nature and they do not affect assumptions contained in plant safety analyses, the physical design and/or operation of the plant, nor do they affect Technical Specifications that preserve safety analysis assumptions. These proposed changes do not change the existing administrative controls on performance of Surveillance Requirements. The changes only relocate the existing requirements to SR 4.0.1 to closely conform to the Standard Technical Specifications. Further, the proposed changes do not alter the design, function, or operation of any plant component. Therefore, operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.
St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 2 Page 3 (2) Operation of the facility in accordance with the proposed amendments would not create the possibility of a new or different kind of accident from any accident previously evaluated.
The changes being proposed are administrative in nature and do not introduce a new mode of plant operation or surveillance requirement, nor involve a physical modification to the plant. Therefore, the design, function, or operation of any plant component is not altered. The changes propose to relocate specific controls from SR 4.0.3 to SR 4.0.1 to closely conform to the Standard Technical Specifications. Therefore, operation of the facility in accordance with the proposed amendments would not create the possibility of a new or different kind of accident from any accident previously evaluated.
(3) Operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.
The proposed changes conform closely to the industry and NRC approved TSTF-358 and relates to the relocation of TS specific controls for Surveillance Requirements from SR 4.0.3 to SR 4.0.1. The specific controls are not changed only relocated to closely conform to the Standard Technical Specifications. Therefore, operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.
Based on the above discussion and the supporting evaluation of Technical Specification changes, FPL has determined that the proposed license amendments involve no significant hazards consideration. The generic CLIIP no significant hazards consideration referenced in the original FPL submittal L-2001-250, as supplemented by L-2002-02, bound the changes to implement TSTF-358 and still apply for the changes that were previously submitted.
Environmental Consideration FPL has reviewed the proposed Technical Specification changes against the criteria of 10 CFR 51.22 for environmental considerations. The proposed changes are administrative conforming amendments.
FPL concludes that the proposed Technical Specifications changes meet the criteria set forth in 10 CFR 51.22(c)(1 0) for a categorical exclusion from the requirements for an environmental impact statement or environmental assessment, as this request proposes changes to recordkeeping, reporting, or administrative procedures or requirements. Therefore, pursuant to 10 CFR 51.22(b) an environmental impact statement or an environmental assessment is not required.
The generic CLIIP environmental consideration referenced in the original FPL submittal L-2001-250, as supplemented by L-2002-02, bound the changes to implement TSTF-358 and still apply for the changes that were previously submitted.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 2 Page 4 Conclusion The generic CLIIP safety evaluation, no significant hazards consideration, and environmental consideration referenced in the original FPL submittal L-2001-250, as supplemented by L-2002-02, bound the changes to implement TSTF-358 and still apply for the changes that were previously submitted.
FPL concludes, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 3 Page 1 ATTACHMENT 3 ST. LUCIE UNITS I AND 2 MARKED UP TECHNICAL SPECIFICATION PAGES Unit I TS Page 3/4 0-2 Unit 2 TS Page 3/4 0-2
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 3 Page 2 REVISED SURVEILLANCE REQUIREMENT INSERT 1 (Completely replaces existing SR 4.0.3)
If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.
When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 3 Page 3 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for Individual Limiting Conditions for Operation unless otherwise stated In an Individual Surveillance Requirement.
t4 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance Interval 4.0.
Failure to perform a Surveillance Requirement within the allowed surveillance Interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY reauirements for a Limitinq Condition for Operation.
e irnUi Entry Into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the Surveillance Requirement(s) associated with the Umiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.
4.0.5 Surveillance Requirements for inservice Inspection of ASME Code Class 1, 2 and 3 components shall be applicable as follows:
- a.
Inservice Inspection of ASME Code Class 1, 2 and 3 components shall be performed In accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50 55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (i).
- b.
deleted Amendment No 25,40.0,08.
408,153 ST. LUCIE - UNIT I 314 0-2
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 3 Page 4 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Umiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. A, d; 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.
- 4.
ailure to perform a Surveillance Requirement within the allowable surveillance interval, (defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY 7 "b-e-p-er'formed on inoperable eq..,uipment-Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.
4.0.5 Surveillance Requirements for inservice inspection of ASME Code Class 1, 2 and 3 components shall be applicable as follows:
- a.
Inservice inspection of ASME Code Class 1. 2 and 3 components shall be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50 55a(g) (6) (I.
- b.
deleted
- c.
deleted Amendment No 33,48, 91 I
ST. LUCIE - UNIT 2 aI 3/4 0-2
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 1 ATTACHMENT 4 ST. LUCIE UNITS I AND 2 MARKED UP TECHNICAL SPECIFICATION BASES PAGES Unit I Bases 4.0.1 4.0.3 Unit 2 Bases 4.0.1 4.0.3 FOR INFORMATION ONLY
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 2 REVISED BASES INSERT 1 (Completely replaces existing the Bases for SR 4.0.1)
SR 4.0.1 establishes the requirement that Surveillance Requirements (SR) must be met during the MODES or other specified conditions in the applicability for which the requirements of the Limiting Condition for Operation apply, unless otherwise specified in the individual SRs. This Specification is to ensure that SRs are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits.
Failure to meet a SR within the specified frequency, in accordance with SR 4.0.2, constitutes a failure to meet a Limiting Condition for Operation.
Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when either:
- a. the systems or components are known to be inoperable, although still meeting the SRs, or
- b. the requirements of the SR(s) are known to be not met between required SR performances.
SRs do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated Limiting Condition for Operation are not applicable, unless otherwise specified. The SRs associated with a SPECIAL TEST EXCEPTION (STE) are only applicable when the STE is used as an allowable exception to the requirements of a Specification.
Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a given MODE or other specified condition.
SRs, including SRs invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply.
SRs have to be met and performed in accordance with SR 4.0.2, prior to returning equipment to OPERABLE status.
Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE. This includes ensuring applicable SRs are not failed and their most recent performance is in accordance with SR 4.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 3 Some examples of this process follow.
- a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.
- b. High pressure safety injection (HPSI) maintenance during shutdown that requires system functional tests at a specified pressure. Provided other appropriate testing is satisfactorily completed, startup can proceed with HPSI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing.
REVISED BASES INSERT 2 (Completely replaces existing the Bases for SR 4.0.3)
SR 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a SR has not been completed within the specified frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater, applies from the point in time that it is discovered that the SR has not been performed in accordance with SR 4.0.2, and not at the time that the specified frequency was not met.
This delay period provides adequate time to complete SRs that have been missed. This delay period permits the completion of a SRs requirement before complying with required ACTION(s) or other remedial measures that might preclude completion of the SR.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the SR, the safety significance of the delay in completing the required SR, and the recognition that the most probable result of any particular SR being performed is the verification of conformance with the requirements.
When a SR with a frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 4.0.3 allows for the full delay period of up to the specified frequency to perform the SR.
However, since there is not a time interval specified, the missed SR should be performed at the first reasonable opportunity.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 4 SR 4.0.3 provides a time limit for, and allowances for the performance of, a SR that becomes applicable as a consequence of MODE changes imposed by required ACTION(s).
Failure to comply with the specified frequency for a SR is expected to be an infrequent occurrence. Use of the delay period established by SR 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified frequency is provided to perform the missed surveillance, it is expected that the missed SR will be performed at the first reasonable opportunity.
The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the surveillance as well as any plant configuration changes required or shutting the plant down to perform the SR) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the SR. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed SRs for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the course of action. All cases of a missed SR will be placed in the licensee's Corrective Action Program.
If a SR is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the completion times of the required ACTION(s) for the applicable Limiting Condition for Operation begin immediately upon expiration of the delay period. If a surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the completion times of the required ACTION(s) for the applicable Limiting Condition for Operation begin immediately upon the failure of the surveillance.
Completion of the SR within the delay period allowed by this specification, or within the completion time of the ACTIONS, restores compliance with SR 4.0.1.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 5 SECTION NO,
TrITLE.
TECHNICAL SPECIFICATIONS PAGE:
3.0 & 4.0 BASES ATTACHMENT 2 OF ADM-25.04 REVISION NO..
LIMITING CONDITIONS FOR OPERATION 8 of 11 AND SURVEILLANCE REQUIREMENTS 0
ST. LUCIE UNIT 1 314.0 APPLICABILITY (continued)
BASES (continued)
,H e-.'
4.0.1 This sp-ecification estab is es the requi ement that surveillances must be performed during the OPERATIONAL MODES or other conditions for whic the requirements of the Limtn' odtosfo prto pl unless otherwise' stated in an individual Surveillance Requirement. The purpose of this specification is to ensure that surveillances are performed to verify the operational status of systems and components and that parameters are withinj specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditio for Operation are applicable. Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test exception is se sanalwble exc tion requirements of as p*
4.0.2 This specification establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance Interval.
It is not intended that this provision be used repeatedly as a convenience to extend the surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 6 SECTION NO:
TIrT TECHNICAL SPECIFICATIONS PAGE.
3.0 & 4.0 BASES ATTACHMENT 2 OF ADM-25.04 REVISION NO..
LIMITING CONDITIONS FOR OPERATION 9 of 11 AND SURVEILLANCE REQUIREMENTS 0
ST. LUCIE UNIT 1 314.0 APPLICABILITY (continued)
BASES (continued) 2 4.0.3 his ecification establishes the-ai ure to perform a Surveillance Requi uiwithint te allowed surveillance Interval, defined by the provisions of Spec ificati 4.0.2, as a condition that constitutes a failure to ft the SOPERABILIT uirements for a Limiting Condition for Oe ation. Under the provisions of this s lification, systems and component s~re assumed to be OPERABLE when Sur *e1ance Requirements have en satisfactorily I
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St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 7 SECTION NO:
TITLE TECHNICAL SPECIFICATIONS PAGE 3.0 & 4.0 BASES ATTACHMENT 2 OF ADM-25.04 REVISION NO" LIMITING CONDITIONS FOR OPERATION 10 of 11 AND SURVEILLANCE REQUIREMENTS 0
ST. LUCIE UNIT 1 314.0 APPLICABILITY (continued)
BASES (continued) 4.03 (continued)
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CINrqieet nd *forn copeigSrelac eiensta r
plcble when an exception to th eurmnso iiain04i loe.I urveillnce-is not com e dwti h hural n
tetm limits of the ACTION reurlS tnamitara ialattatie heasuvillance is performed th tim t'h CINrqieet plcble at the time that the Ssurveillanc s terminated.
Sure neRqieet onthv ob perfo :ed on inoperable eq metbeas teATINreurmet hefn remedial measures t ap l.H w v r h S r ela c e urem ents ha~e to be m et to
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 8 SECTION NO:
TITLE TECHNICAL SPECIFICATIONS PAGE 3.0 & 4.0 BASES ATTACHMENT 2 OF ADM-25.04 REVISION NO:
LIMITING CONDITIONS FOR OPERATION 8 of 10 0
AND SURVEILLANCE REQUIREMENTS ST. LUCIE UNIT 2 3/4.0 APPLICABILITY (continued) 4.0.1 his s ification esta ishes the req ement that surveillances must be 4 performedcatIng the OPERATIONAL MODES or other conditionsedm itrahlh thef Srequirements o le<Limiting Conditions for Operation, applyý u lsotherwise
]
stated in an individuurveillance Requirement. The pm se of this io specifithno s to ensure t rveillances are su rmve to verify thean operational status of systems an d pon and that parameters are within
,cn d u ci n g t s
i c e r
iy w h e n th e p la n t is in a srMODE ia otr smenane aties. It a ovi ed Limiting Conditions for Oderat*n the leafurei t hare perto be a perforach rfeln te f are specfie wiRATIONAn MODnt which the requirnt erv I
i at tis povision be userationd not apply conenen e
to pext fend.
The Surveillance Int iervl eyn tht spcfe for sunless rtha ae n
sgou ociagsd wita o Sp~ecifiae xetion 402ibased onl enginebern wudgent n the rpecogniTet eion tha 4.0.2 This specification establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified within an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend the surveillance Intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that most probable result of any particular surveillance being performed Is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 9 SECTION NO:
TITLE TECHNICAL SPECIFICATIONS PAGE 3.0 & 4.0 BASES ATTACHMENT 2 OF ADM-25.04 REVISION NO:
LIMITING CONDITIONS FOR OPERATION 9 of 10 AND SURVEILLANCE REQUIREMENTS 0
ST. LUCIE UNIT 2 314.0 APPLICABILITY (continued)
BASES (continued)
-7
]*;
2.,
4.0.3 s a is es failureho nerform a Surveillance Req Iv ment pfm win the speifed tillance interval, defined by the provisions of v
iSpecif tion 4.0.2, as a condition that constitutes a failuro t e oPheRB ILITY a
refo irements for a Limiting Condition for Operu hn.
Under th e Survision of this specification, systems and componentslarie assumed to beN rOPERABLe when Surveillance Requirements have beenatisfactorily ATperformed wqieints specifro time interval. However, thing in this provision is to be constc d as Implying that systems or comp ents are OPERABLE when they are nd or known to be Inoperable al ugh still meeting the Surveillance Req ements. This specification lof the ACTION requirements are as licable when Surveillan rements o
eatino 4.0 completed within the alowed surveillance inrval and byat the time limits of th ACTION requirements'a pply from the poli iei is identified that a surveillance has not bee' performed a o
tte time that the allowed surveillance interval was ceeded. i mpletion of the Surveillance o
Requiref ent within the allowable o
e limits of the ACTIOuN a l h
24hurs rashtdo s reqire toi requiroemicatisn 4
eHoweg.,
S hcisoen3.
, a 24-oural ce fisr to have perormed t hel al tsuiacritrvl dfned by the provisio f
ImSpelemention the a I
tirments i PRovIdes aequirements of a t
Limiting Condition for 0pei io ubject to enfotcement actipo.
If the pp o
sallowa ncte e limis tof pr It trhe uiometn ar less tha bef or a shutdo is required to c ply with ACTION requirements, o
s-re.g.,
iac. he b3a for allowace includves o
permit a delay i Implemti the require*einc.
is provises an adeu ate time i fori the co mpeio of Srveillance Requirements athavent becen aplberfasmea The pups fti llwnei opritteopeino a surveillan~ce befone a o M changes impoy w
ACION requirements or befor othemprl'udtg Sur e R eqrem sare ae w
n a ompletion of tsurveirem entrs fof S
t is alloweid. Ifasurv ion of plant conditins
'qaepannaalbltofernNthe time required to perf tem wth s
tre2-
- rance, thes etie imofithe d la n
com ents areqpicle surveillance is rfa tiorme limit for the c2 allowanc a Surveillance Requirements c e applicable as amt conselec fMD hne mpsdb CINrqeets and for Scompftn uvilnc eurmnstataeapial
. nanexception th eurmet'fSpcfctin404 salwe.I ur illa~nce is not
\\ com-ltdwtith 4hualoactetmlmits of theA TION
\\req =irements are applicable at that time. When a surveillance is erformed
\\witlin the 24-hour allowance and the Surveillance Requirements are not met, th time limits of the ACTION requirements are applicable at the time that the u eillance is terminated.
St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 4 Page 10 SECTION NO:
TITLE TECHNICAL SPECIFICATIONS PAGE:
3.0 & 4.0 BASES ATTACHMENT 2 OF ADM-25.04 REVISION NO:
LIMITING CONDITIONS FOR OPERATION 10 of 10 0
AND SURVEILLANCE REQUIREMENTS ST. LUCIE UNIT 2 314.0 APPLICABILITY (continued)
BASES (continued)
Srelac Seurrnhv to be performed o le eqimn beas"heATOhrqiee remedial measures deosrt tmal qipethsben rtsre totOo_
4.0.4 This specification establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL MODE or other condition or operation specified In the Applicability statement. The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which these systems and components ensure safe operation of the facility.
This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well as startup.
Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plant startup or following a plant outage.
When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower MODE of operation.
4.0.5 This specification ensures that inservice inspection of ASME Code Class 1, 2 and 3 components will be performed In accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a. Relief from any of the above requirements has been provided In writing by the Commission and is not part of these Technical Specifications.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 5 Page 1 ATTACHMENT 5 ST. LUCIE UNITS I AND 2 RETYPED TECHNICAL SPECIFICATION PAGES Unit 1 TS Page 3/4 0-2 Unit 2 TS Page 3/4 0-2
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 5 Page 2 APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. Surveillance Requirements do not have to be performed on inoperable equipment 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.
4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition of Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed If the Surveillance is not performed within the delay period, the ULmiting Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.
When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be taken 4.0.4 Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.
4.0.5 Surveillance Requirements for inservice inspection of ASME Code Class 1, 2 and 3 components shall be applicable as follows:
- a.
Inservice inspection of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50 55a(g) (6) (i).
- b.
deleted ST. LUCIE - UNIT 1 3/4 0-2 Amendment No. 25,40, g0, 48, 409, 453,
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-117 Attachment 5 Page 3 APPLICABILITY
.SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to perform a Surveillance Requirement within the allowable surveillance interval, defined by Specification 4 0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. Surveillance Requirements do not have to be performed on inoperable equipment.
4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified surveillance interval.
4 0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition of Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the Limiting Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.
When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be taken.
4.0.4 Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements 4.0 5 Surveillance Requirements for inservice inspection of ASME Code Class 1, 2 and 3 components shall be applicable as follows:
- a.
Inservice inspection of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (i)
- b.
deleted
- c.
deleted Amendment No. 33, 48, 4-.,
ST. LUCIE - UNIT 2 314 0-2