L-2011-423, Supplemental Information Regarding Extended Power Uprate License Amendment Request - Revision to EPU LAR Proposed Technical Specifications

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Supplemental Information Regarding Extended Power Uprate License Amendment Request - Revision to EPU LAR Proposed Technical Specifications
ML11285A045
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 10/10/2011
From: Richard Anderson
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2011-423
Download: ML11285A045 (12)
v • d • e


Text

0 Florida Power & Light Company, 6501 S.

Ocean Drive, Jensen Beach, FL 34957 FPL October 10, 2011 L-2011-423 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Re: St. Lucie Plant Unit 1 Docket No. 50-335 Renewed Facility Operating License No. DPR-67 Supplemental Information Regarding Extended Power Uprate License Amendment Request - Revision to EPU LAR Proposed Technical Specifications

References:

(1) R. L. Anderson (FPL) to U.S. Nuclear Regulatory Commission (L-2010-259),

"License Amendment Request for Extended Power Uprate," November 22, 2010, Accession No. ML103560419.

(2) Email from T. Orf (NRC) to C. Wasik (FPL), "St. Lucie 2 EPU - draft RAIs Reactor Systems Branch and Nuclear Performance Branch (SRXB and SNPB),"

September 6, 2011.

By letter L-2010-259 dated November 22, 2010 [Reference I], Florida Power & Light Company (FPL) requested to amend Renewed Facility Operating License No. DPR-67 and revise the St. Lucie Unit I Technical Specifications (TS). The proposed amendment will increase the unit's licensed core thermal power level from 2700 megawatts thermal (MWt) to 3020 MWt and revise the Renewed Facility Operating License and TS to support operation at this increased core thermal power level. This represents an approximate increase of 11.85% and is therefore considered an Extended Power Uprate (EPU).

By email from the NRC Project Manager dated September 6, 2011 [Reference 2],

additional information related to reactor systems and nuclear performance was requested by the NRC staff in the Reactor Systems Branch and Nuclear Performance Branch (SRXB and SNPB) to support their review of the St. Lucie Unit 2 EPU LAR. The request for additional information (RAI) included two questions (TS-5 and TS-6) related to relocating the minimum reactor coolant flow parameter associated with the departure from nucleate boiling (DNB) to the Core Operating Limits Report (COLR).

an FPL Group company

St. Lucie Unit 1 L-2011-423 Docket No. 50-335 Page 2 of 2 Although RAI TS-5 and TS-6 are associated with the St. Lucie Unit 2 EPU LAR, these RAIs are also applicable to the St. Lucie Unit I EPU LAR. As such, FPL is providing supplemental information to revise the proposed TS changes associated with the relocation of the minimum reactor coolant flow DNB parameter to the COLR. Attachment 1 to this submittal provides the description and basis for the revision to the proposed TS changes. Attachment 2 provides the marked-up and clean pages for the proposed TS changes.

This submittal does not alter the significant hazards consideration or environmental assessment previously submitted by FPL letter L-2010-259 [Reference 1].

This submittal contains no new commitments and no revisions to existing commitments.

In accordance with 10 CFR 50.91 (b)(1), a copy of this letter is being forwarded to the designated State of Florida official.

Should you have any questions regarding this submittal, please contact Mr. Christopher Wasik, St. Lucie Extended Power Uprate LAR Project Manager, at 772-467-7138.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Executed on /a -- _--_ Ii Very truly yours, Richard L. Anderson, Site Vice President St. Lucie Plant Attachments (2) cc: Mr. William Passetti, Florida Department of Health

St. Lucie Unit 1 L-2011-423 Docket No. 50-335 Attachment 1 Page 1 of 3 Attachment I Technical Specifications Figure 2.1-1, Table 2.2-1, and Specification 3/4.2.5 Revision To Proposed Change Submitted By FPL Letter L-2010-259 Regarding Extended Power Uprate License Amendment Request For St. Lucie Unit 1 By letter L-2010-259 dated November 22, 2010, Florida Power & Light Company (FPL) requested to amend Renewed Facility Operating License No. DPR-67 and revise the St. Lucie Unit 1 Technical Specifications (TS). The proposed amendment will increase the unit's licensed core thermal power level from 2700 megawatts thermal (MWt) to 3020 MWt and revise the Renewed Facility Operating License and TS to support operation at this increased core thermal power level. This represents an approximate increase of 11.85% and is therefore considered an Extended Power Uprate (EPU). Included in the EPU LAR were changes to TS Figure 2.1-1 Reactor Core Thermal Margin Safety Limit - Four Reactor Coolant Pump Operating, TS Table 2.2-1 Reactor Protective Instrumentation Trip Setpoint Limits, and TS 3.2.5, Power Distribution Limits - DNB Parameters. FPL is modifying the proposed TS changes as described below:

Description of the Change EPU LAR Attachment 1, Section 3.1, Renewed Facility Operating License and Technical Specification Changes proposed the following changes: Item 6 - TS 2.1, SAFETY LIMITS -

FIGURE 2.1 REACTOR CORE THERMAL MARGIN SAFETY LIMIT - FOUR REACTOR COOLANT PUMP OPERATING, Item 7 - TS 2.2, LIMITING SAFETY SYSTEM SETTINGS -

TABLE 2.2 REACTOR PROTECTIVE INSTRUMENTATION TRIP SETPOINT LIMITS and Item 12 - TS 3.2.5, POWER DISTRIBUTION LIMITS - DNB PARAMETERS:

" Item 6 - TS 2.1, SAFETY LIMITS - FIGURE 2.1 REACTOR CORE THERMAL MARGIN SAFETY LIMIT - FOUR REACTOR COOLANT PUMP OPERATING - The note "VESSEL FLOW LESS MEASUREMENT UNCERTAINITIES - 365,000 GPM" was proposed to be changed to "REACTOR COOLANT SYSTEM TOTAL FLOW RATE -

SPECIFIED IN COLR TABLE 3.2-1."

  • Item 7. TS 2.2, LIMITING SAFETY SYSTEM SETTINGS - TABLE 2.2 REACTOR PROTECTIVE INSTRUMENTATION TRIP SETPOINT LIMITS - The footnote was proposed to be changed from "* Design reactor coolant flow with 4 pumps operating is 365,000 gpm" to "For minimum reactor coolant flow with 4 pumps operating, refer to COLR Table 3.2-1."
  • Item 12. TS 3/4.2.5, POWER DISTRIBUTION LIMITS - DNB PARAMETERS - The Limiting Condition for Operation (LCO) was proposed to be changed from "The following DNB related parameters shall be maintained within the limits shown on Table 3.2-1" to "The following DNB related parameters shall be maintained within the limits shown on Table 3.2-1 of the COLR" and Table 3.2-1 was proposed to be relocated to the COLR.

By email from the NRC Project Manager dated September 6, 2011, additional information was requested by the NRC staff in the Reactor Systems Branch (SRXB) and Nuclear Performance Branch (SNPB) to support their review of the St. Lucie Unit 2 EPU LAR. The request for additional information (RAI) included two questions related to the relocation to the core operating limits report (COLR) of the departure from nucleate boiling (DNB) parameters. The questions stated that based on NRC staff position delineated in letter from T.H. Essig (NRC) to A. Drake (Westinghouse Owners Group), Acceptance for Referencing of Licensing Topical

St. Lucie Unit 1 L-2011-423 Docket No. 50-335 Attachment 1 Page 2 of 3 Report WCAP-14483, "Generic Methodology for Expanded Core Operating Limits Report" TAC NO. M94338, dated January 19, 1999 (Accession No. ML020430092), the minimum reactor coolant flow parameter could not be relocated from the TS. Although the RAI addressed the St.

Lucie Unit 2 EPU LAR, the response is also applicable to the St. Lucie Unit 1 EPU LAR. As such, FPL is modifying the proposed TS as follows:

0 TS FIGURE 2.1 REACTOR CORE THERMAL MARGIN SAFETY LIMIT - FOUR REACTOR COOLANT PUMP OPERATING - The Note is changed from "REACTOR COOLANT SYSTEM TOTAL FLOW RATE - SPECIFIED IN COLR TABLE 3.2-1" to "REACTOR COOLANT SYSTEM TOTAL FLOW RATE - SPECIFIED IN LCO 3.2.5."

  • TS 2.2, LIMITING SAFETY SYSTEM SETTINGS - TABLE 2.2 REACTOR PROTECTIVE INSTRUMENTATION TRIP SETPOINT LIMITS - The footnote is revised to state:
  • TS 3/4.2.5, POWER DISTRIBUTION LIMITS - DNB PARAMETERS - The LCO is revised to state:

3.2.5 The following DNB related parameters shall be maintained within the limits:

a. Cold Leg Temperature as shown on Table 3.2-1 of the COLR,
b. Pressurizer Pressure* as shown on Table 3.2-1 of the COLR,
c. Reactor Coolant System Total Flow Rate - greater than or equal to 375,000 gpm, and
d. AXIAL SHAPE INDEX as shown on Figure 3.2-4 of the COLR.

Note that the marked up TS pages in Attachment 2 are markups of the pages submitted in the EPU LAR. For Table 2.2-1, the marked up page also contains a revision submitted by FPL Letter L-2011-341, dated August 25, 2011.

The EPU LAR contained marked up and clean pages for the TS Bases and the COLR for information only. The revised TS Bases and COLR pages are not included in this submittal.

Basis for the change:

The limits on the DNB related parameters ensure that each of the parameters is maintained within the normal steady-state envelope of operation assumed in the transient and accident analyses. The limits are consistent with the safety analyses assumptions and have been analytically demonstrated adequate to maintain a minimum departure from nucleate boiling ratio (DNBR) of greater than or equal to the DNBR limit for each DNB limited transient analyzed.

The nuclear steam supply system (NSSS) design parameters provide the reactor coolant system and secondary side system conditions (thermal power, temperatures, and pressures) that are used as the basis for the design transients, systems, structures, components, accidents, and fuel analyses and evaluation. These variables are validated every refueling cycle and are contained in the COLR to provide operating and analysis flexibility. The minimum reactor coolant flow parameter is maintained in the TS, but is relocated to the LCO from TS Table 3.2-1, DNB MARGIN LIMITS, which is being deleted.

The DNB margin limit for cold leg temperature is changed from < 549°F to < 551°F and reactor coolant flow rate is changed from > 365,000 gpm to > 375,000 gpm.

St. Lucie Unit 1 L-2011-423 Docket No. 50-335 Attachment 1 Page 3 of 3 TS Table 3.2-1 is being relocated to the COLR. The DNB parameters being relocated are determined for each refueling cycle core in the reload safety analysis. This change ensures that the DNB parameters are consistent with the values determined in the reload safety analysis.

Relocating the specific parameter limits to the COLR is consistent with the NRC staff position stated in letter T.H. Essig (NRC) to A. Drake (Westinghouse Owners Group), Acceptance for Referencing of Licensing Topical Report WCAP-14483, "Generic Methodology for Expanded Core Operating Limits Report" TAC NO. M94338, dated January 19, 1999 (Accession No. ML020430092). The relocation to the COLR is not required for EPU and is included as a TS enhancement.

The revision to the footnote on TS Table 2.2-1, Reactor Protective Instrumentation Trip Setpoint Limits, is a conforming change to ensure that the value for the reactor coolant flow limit is identified correctly.

No Sigqnificant Hazards Consideration This change eliminates the relocation of the reactor coolant flow limit from the TS to the COLR.

The reactor coolant flow limit is unchanged from the value in the EPU LAR. The limit will be maintained in TS LCO 3.5.2. In addition, the note on TS Figure 2.1-1 and the footnote on TS Table 2.2-1 are being revised to reference the TS and not the COLR for the reactor coolant flow requirement. As such, the conclusions of EPU LAR Attachment 1 Section 5.2, No Significant Hazards Consideration, Item B. Reactor Coolant Flow Rate and Departure From Nucleate Boiling (DNB) Parameters remain valid. Accordingly, the proposed change 1) does not involve a significant increase in the probability or consequences of an accident previously evaluated,

2) does not create the possibility of a new or different kind of accident from any previously evaluated, and 3) does not result in a significant reduction in a margin of safety.

Environmental Evaluation This change does not change any of the technical requirements for the DNB parameters. The change only maintains the reactor coolant flow limit in the TS, as opposed to relocating the limit to the COLR. The environmental considerations evaluation contained in the EPU LAR remain valid. Accordingly, the proposed license amendment is eligible for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 50.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed license amendment.

St. Lucie Unit 1 L-2011-423 Docket No. 50-335 Attachment 2 ATTACHMENT 2 Supplemental Response to NRC Reactor Systems Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request Marked-Up and Clean Technical Specification Pages This coversheet plus six pages

600 E=

UNACCEPTABLE OPERATION 580 L

,,0 560 PRESSURE IN PSIA

\2400 07E540 I-REACTOR OPERATION LIMITED TO LESS THAN

0) 580OF BY ACTUATION OF THE MAIN STEAM 2225 SAFETY VALVES o 520-REACTOR COOLANT SYSTEM TOTAL FLOW RATE -

SPECIFIED INC TL B FL3.2 T?. _1.. _

  • 2000 E

E LIMITS CONTAIN NO ALLOWANCE FOR INSTRUMENT ERROR OR FLUCTUATIONS 500

\, 1750 BASED ON THE AXIAL SHAPE ON FIGURE B2.1-1 THERMAL POWER LIMITED TO 480 A MAXIMUM OF 112% OF ACCEPTABLE OPERATION RATED THERMAL POWER BY THE HIGH POWER TRIP LEVEL 460 0 0.2 0.4 0.6 0.8 1 1.2 1.4 1.6 Fraction of Rated Thermal Power FIGURE 2.1-1: REACTOR CORE THERMAL MARGIN SAFETY LIMIT -

FOUR REACTOR COOLANT PUMPS OPERATING ST. LUCIE - UNIT 1 2-2 Amendment No. 48, 4-6, W5, 46-

TABLE 2.2-1 REACTOR PROTECTIVE INSTRUMENTATION TRIP SETPOINT LIMITS FUNCTIONAL UNIT TRIP SETPOINT ALLOWABLE VALUES

1. Manual Reactor Trip Not Applicable Not Applicable
2. Power Level - High (1)

Four Reactor Coolant Pumps Operating < 9.61% above THERMAL POWER, with < 9.61% above THERMAL POWER, and a minimum setpoint of 15% of RATED a minimum setpoint of 15% of RATED THERMAL POWER, and a maximum of THERMAL POWER and a maximum of

< 107.0% of RATED THERMAL < 107.0% of RATED THERMAL POWER. POWER.

3. Reactor Coolant Flow - Low (1) minimum r Four Reactor Coolant Pumps Operating > 95% of reactor coolant flow with 95% or L,, 4 pumps operating* 4 pumps operating*
4. :Pre *zer Pressure - High < 2400 psia < 2400 psia x-N-Y-'ý 34.78%
5. Containment uPre - High < 3.3 psig < 3.3 psig
6. Steam Generator Pressur ow (2) > 600 psia > 600 psia
7. Steam Generator Water Level - Lo* - Water Level - each steam > 41Q9o5 er Level - each steam

___rator generator

8. Local Power Density - High (3) Trip setpoint adjusted to not exceed the Trip set point adjusted to not exceed the limit lines of Figures 2.2-1 and 2.2-2. limit lines of Figures 2.2-1 and 2.2-2.

- .-.-.~ 4 _____________________________________________________________________

For m 35.0% tf

ST. LUCIE - UNIT 1 2-4 Amendment No. 3, 2-7, 32, 45, 405, 4-30, 445,46

POWER DISTRIBUTION LIMITS DNB PARAMETERS LIMITING CONDITION FOR OPERATIONI m 3.2.5 The following DNB r parameters shall be maintained within the limits S4e

a. Cold Leg Temperature
b. Pressurizer Pressure as shown on Table 3.2-1 of the COLR,
c. Reactor Coolant System Total Flow Rate < - greater than or equal to 375,000 gpm, and
d. A X IA L S H A P E IN D E X "I: - . o n_F 32 _

as shown on Fi0r.*.oteC.

APPLICABILITY: MODE 1.

ACTION:

With any of the above parameters exceeding its limit, restore the parameter to within its limit within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or reduce THERMAL POWER to < 5% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

DNB related suRvEILLANCE RE=UREMENTS--ý 4,2.5.1 Each of the rameters cf Tablc 3.2 1 shall be verified to be within their limits by instrument readout at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4,2.5.2 The Reactor Coolant System total flow rat shall be determined to be within its limit by measureme

  • at least once pe 1 months.
  • Limit not applicable during either a THERMAL POWER ramp increase in excess of 5% per minute of RATED THERMAL POWER or a THERMAL]

POWER step increase of greater than 10% of RATED THERMAL POWER.

- Not required to be performed until THERMAL POWER is > 90% of RATED THERMAL POWER.

ST. LUCIE - UNIT 1 3/4 2-13 Amendment No. 27, 4-0

600 UNACCEPTABLE OPERATION 580 L6 0 PRESSURE IN PSIA 560 REACTOR OPERATION LIMITED TO LESS THAN 2400 I-540 5800 F BY ACTUATION OF THE MAIN STEAM U

O SAFETY VALVES 2225 REACTOR COOLANT SYSTEM TOTAL FLOW RATE -

520 SPECIFIED IN LCO 3.2.5 0 2000 LIMITS CONTAIN NO ALLOWANCES FOR INSTRUMENT ERROR OR FLUCTUATIONS 500 x

BASED ONTHE AXIAL SHAPE ON FIGURE B2.1-1 Zi 1750 THERMAL POWER LIMITED TO A MAXIMUM OF 112%OF 480 ACCEPTABLE OPERATION RATED THERMAL POWER BY THE HIGH POWERTRIP LEVER 460 0 0.2 0.4 0.6 0.8 1 1.2 1.4 1.6 FRACTION OF RATED THERMAL POWER FIGURE 2.1-1: REACTOR CORE THERMAL MARGIN SAFETY LIMIT -

FOUR REACTOR COOLANT PUMPS OPERATING ST. LUCIE - UNIT 1 2-2 Amendment No. 48, 1-30, 446, 463,

TABLE 2.2-1 REACTOR PROTECTIVE INSTRUMENTATION TRIP SETPOINT LIMITS FUNCTIONAL UNIT TRIP SETPOINT ALLOWABLE VALUES

1. Manual Reactor Trip Not Applicable Not Applicable
2. Power Level - High (1)

Four Reactor Coolant Pumps Operating < 9.61% above THERMAL POWER, with < 9.61% above THERMAL POWER, and a minimum setpoint of 15% of RATED a minimum setpoint of 15% of RATED THERMAL POWER, and a maximum of THERMAL POWER and a maximum of

< 107.0% of RATED THERMAL < 107.0% of RATED THERMAL POWER. POWER.

3. Reactor Coolant Flow- Low (1)

Four> 95% of minimum reactor coolant flow > 95% of minimum reactor coolant flow with 4 pumps operating

  • with 4 pumps operating *
4. Pressurizer Pressure - High < 2400 psia < 2400 psia
5. Containment Pressure - High < 3.3 psig < 3.3 psig
6. Steam Generator Pressure - Low (2) > 600 psia > 600 psia
7. Steam Generator Water Level - Low > 35.0% Water Level - each steam > 34.78% Water Level - each steam generator generator
8. Local Power Density - High (3) Trip setpoint adjusted to not exceed the Trip set point adjusted to not exceed the limit lines of Figures 2.2-1 and 2.2-2. limit lines of Figures 2.2-1 and 2.2-2.

ST. LUCIE - UNIT 1 2-4 Amendment No. 3, 27-, 32, 46, 4-5, 439, 446, 462

POWER DISTRIBUTION LIMITS DNB PARAMETERS LIMITING CONDITION FOR OPERATION 3.2.5 The following DNB related parameters shall be maintained within the limits:

a. Cold Leg Temperature as shown on Table 3.2-1 of the COLR,
b. Pressurizer Pressure* as shown on Table 3.2-1 of the COLR,
c. Reactor Coolant System Total Flow Rate - greater than or equal to 375,000 gpm, and
d. AXIAL SHAPE INDEX as shown on Figure 3.2-4 of the COLR.

APPLICABILITY: MODE 1.

ACTION:

With any of the above parameters exceeding its limit, restore the parameter to within its limit within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or reduce THERMAL POWER to < 5% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.2.5.1 Each of the DNB related parameters shall be verified to be within their limits by instrument readout at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4.2.5.2 The Reactor Coolant System total flow rate shall be determined to be within its limit by measurement** at least once per 18 months.

Limit not applicable during either a THERMAL POWER ramp increase in excess of 5% per minute of RATED THERMAL POWER or a THERMAL POWER step increase of greater than 10% of RATED THERMAL POWER.

Not required to be performed until THERMAL POWER is > 90% of RATED THERMAL POWER.

ST. LUCIE - UNIT 1 3/4 2-13 Amendment No. 2-7, 4-5,

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