ML082980434

Correction to Amendments Regarding Control Room Habitability, TDTF-448

ML082980434
Person / Time
Site:	Saint Lucie
Issue date:	10/24/2008
From:	Mozafari B Plant Licensing Branch II
To:	Stall J Florida Power & Light Co
Mozafari B, NRR/ADRO/DORL, 415-2020
References
TAC MD6174, TAC MD6175
Download: ML082980434 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 24, 2008 Mr. J. A. Stall Senior Vice president, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 1400 Juno Beach, Florida 33408-0420 SUB-JECT: ST. LUCIE PLANT, UNITS 1 AND 2 - CORRRECTION TO AMENDMENTS REGARDING CONTROL ROOM HABITABILITY, TSTF-448 (TAC NOS. MD6174 AND MD6175)

Dear Mr. Stall:

On September 30,2008, the Nuclear Regulatory Commission (NRC) issued Amendment No. 205 to Renewed Facility Operating License No. DPR-67 (DPR-67) and Amendment No. 153 to Renewed Facility Operating License NPF-16 (NPF-16) for the St. Lucie Plant, Units 1 and 2, respectively. This was in response to your application dated July 16,2007, as supplemented by letters dated May 20, and August 26, 2008, for implementation of the Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-448, Revision 3, "Control Room Habitability."

The NRC staff noted that affected license condition pages and the corresponding errata sheets for both DPR-67 and NPF-16 were inadvertently omitted. Also, a minor editorial error in the associated safety evaluation (SE) regarding the NUREG [NRC technical report designation]

used in support of this review was identified. This change does not affect the conclusion of the SE. The revised pages are enclosed and the corrections are identified by marginal lines.

We apologize for any inconvenience this may have caused.

Sincerely, df.~~/::::ct Plant Licensing Branch 11-2 Manager Division of Operating Reactor Licensing Office of Nuclear Reactor RegUlation Docket Nos. 50-335 and 50-389

Enclosures:

1. Revised Errata Sheets

2. Page 5 of Renewed Operating License DPR-67

3. Pages 6 and 7 of Renewed Operating License NPF-16

4. Revised Safety Evaluation page 2 cc w/enclosure: See next page

ML082980434 NRR-106 OFFICE LPL2-2/PM LPL2-2/LA LPL2-2/BC NAME EBrown for CSoia LJames for BMozafari TBoyce DATE 10/24/08 10/24/08 10/24/08 Florida Power and Light Company ST. LUCIE PLANT cc:

Mr. Eric Katzman Licensing Manager S1. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. J. Kammel Radiological Emergency Planning Administrator Division of Emergency Preparedness Department of Community Affairs 6000 Southeast Tower Drive Stuart, Florida 34997 Additional Distribution via ListServ

ATIACHMENT TO LICENSE AMENDMENT NO. 205 RENEWED FACILITY OPERATING LICENSE NO. DPR-67 DOCKET NO. 50-335 Replace the following pages of Renewed Operating License DPR-67 with the attached pages.

The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page 3 3 5 5 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page 3/47-20 3/47-20 3/47-20a 3/47-23 3/47-23 6-15f 6-15f 6-15g 6-15g Correction Letter dated October 24, 2008

-5 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 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.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight 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 1\10. 205 Correction Letter dated October 24, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 153 RENEWED FACILITY OPERATING LICENSE NO. NPF-16 DOCKET NO. 50-389 Replace the following pages of Renewed Operating License NPF-16 with the attached pages.

The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page 3 3 6 6 7

Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page 3/47-17 3/47-17 3/47-17a 3/47-19 3/47-19 6-15i 6-15i Correction Letter dated October 24, 2008

- 6 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 includes 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. 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, pius 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. t\lPF-16 Amendment No. 153 Correction Letter dated October 24, 2008

- 7 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.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight 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 0, Antitrust Conditions Date of Issuance: October 2,2003 Renewed License No. NPF-16 Amendment No. 153 Correction Letter dated October 24, 2008

-2 Licensees were requested to address existing TS as follows:

Provide confirmation that your TSs verifies the operability of the CRE boundary, and the assumed unfiltered inleakage rates of potentially contaminated air. If you currently have a differential pressure SR to demonstrate CRE boundary integrity, provide the basis for your conclusion that it remains adequate to demonstrate CRE integrity in light of the ASTM E741 testing results. If you conclude that your differential pressure SR is no longer adequate, provide a schedule for:

(1) revising the SR in your TSs to reference an acceptable surveillance methodology (e.g., ASTM E741); and (2) making any necessary modifications to your CRE [boundary] so that compliance with your new SR can be demonstrated.

If your facility does not currently have a TS SR for your CRE integrity, explain how and at what frequency you confirm your CRE integrity and why this is adequate to demonstrate CRE integrity.

To promote standardization and to minimize the resources that would be needed to create and process plant specific amendment applications in response to the concerns described in the generic letter (GL), the industry and the NRC proposed revisions to CRE habitability system requirements contained in the STSs, using the STS change traveler process. This effort culminated in Revision 3 to TSTF-448, which the NRC staff approved on January 17, 2007.

With consideration that the St. Lucie TSs are custom TSs and not STSs, the proposed changes are consistent with the traveler as incorporated into NUREG-1432, "Standard Technical Specifications, Westinghouse Plants." Specifically, the licensee proposed revising the actions and SRs in TS 3.7.7.1, "Control Room Emergency Ventilation System (CREVS)," for St. Lucie Unit 1, and TS 3.7.7, "Control Room Emergency Air Cleanup System (CREACS)," for St. Lucie Unit 2, as well as adding a new administrative controls program, TS 6.8.4.m, "Control Room Envelope Habitability Program," for both units. The purpose of the changes are to ensure that CRE boundary operability is maintained and verified through effective surveillance and programmatic requirements, and that appropriate remedial actions are taken in the event of an inoperable CRE boundary.

Some editorial and plant specific changes were incorporated into this safety evaluation resulting in minor deviations from the model safety evaluation text in TSTF-448, Revision 3. These deviations are considered administrative in nature, in that they have no material impact on TSTF-448, Revision 3.

2.0 REGULATORY EVALUATION

2.1 Control Room and Control Room Envelope NRC Regulatory Guide (RG) 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 0, May 2003, uses the term "control room envelope" in addition to the term "control room" and defines each term as follows:

Control Room: The plant area, defined in the facility licensing basis, in which actions can be taken to operate the plant safely under normal conditions and to maintain the reactor in a safe condition during accident situations. It encompasses the instrumentation and controls necessary for a safe shutdown of the plant and typically includes the critical Correction Letter dated October 24, 2008