L-2013-160, Application for Technical Specification Change Regarding Moderator Temperature Coefficient (Mtc) Surveillance for Startup Test Activity Reduction (STAR) Program Using the Consolidated Line Item Improvement Process

From kanterella
(Redirected from ML13144A166)
Jump to navigation Jump to search

Application for Technical Specification Change Regarding Moderator Temperature Coefficient (Mtc) Surveillance for Startup Test Activity Reduction (STAR) Program Using the Consolidated Line Item Improvement Process
ML13144A166
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 05/21/2013
From: Jensen J
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2013-160
Download: ML13144A166 (22)


Text

,..

0 May 21, 2013 L-2013-160 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) program Using the Consolidated Line Item Improvement Process.

Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requests to amend Facility Operating License DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2.

The proposed amendment would modify Technical Specification (TS) requirements for moderator temperature coefficient (MTC) surveillance requirements (SR) associated with implementation of WCAP-1601 1-P-A, "Startup Test Activity Reduction Program."

The license amendment request is provided in the enclosure.

FPL requests approval of the proposed amendment in one year, with the amendment being implemented within 90 days of approval.

The license amendments proposed by FPL have been reviewed by the St. Lucie Plant Onsite Review Group. In accordance with 10 CFR 50.91(b)(1), a copy of these proposed license amendments is being forwarded to the State Designee for the State of Florida.

Please contact Mr. Eric Katzman, Licensing Manager at 772-467-7734 if there are any questions about this submittal.

65o1Sda Power & Company desht 6501 S. Ocean Drive, Jensen. Beach, FL 34957 "7~~~~................

..--............. " :*'- *i ...... _.: " . .-.

  • L-2013-160 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Sincerely, Site Vice President St. Lucie Plant

Enclosure:

Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) program Using the Consolidated Line Item Improvement Process cc: Ms. Cynthia Becker, Chief- Florida Bureau of Radiation Control

L-2013-160 Enclosure Page 1 of 20 Enclosure Evaluation of the Proposed Change Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) program Using the Consolidated Line Item Improvement Process 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

S ATTACHMENTS:

1. Proposed Technical Specification Change Markups
2. Word Processed Technical Specification Changes
3. Proposed Technical Specification Bases Changes (Information Only)

L-2013-160 Enclosure Page 2 of 20 1.0

SUMMARY

DESCRIPTION The proposed amendment would modify the Technical Specifications (TS) moderator temperature coefficient (MTC) surveillance requirements (SR) associated with the implementation of WCAP- 16011-P-A, "Startup Test Activity Reduction Program."

The changes are consistent with the Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-486 Revision 2 as included in NUREG-1432, Revision 4.0, Standard Technical Specifications - Combustion Engineering Plants (CE STS). The FederalRegister Vol. 72, No.

172 notice published on September 6, 2007 announced the availability of this TS improvement through the consolidated line item improvement process (CLIIP).

FPL has reviewed the NRC staffs evaluation and has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to St.

Lucie Units 1 and 2, and justify this amendment for the incorporation of the changes to the St.

Lucie Units 1 and 2 TSs.

2.0 DETAILED DESCRIPTION 2.1 Proposed TS Changes Technical Specifications - Section 3.1.1.4, Moderator Temperature Coefficient This License Amendment Request revises Units 1 and 2 Technical Specifications SR 4.1.1.4.1 and 4.1.1.4.2, associated with TS 3.1.1.4, "ModeratorTemperature Coefficient ". The proposed changes are consistent with the NRC-approved Revision 2 of TSTF-486.

The Technical Specification Surveillance Requirements (SRs) 4.1.1.4.1 and 4.1.1.4.2 are proposed to be revised as shown in Attachment 1.

SR 4.1.1.4.1 currently requires MTC to be within its limits by confirmatory measurements, with the MTC measured values extrapolated and/or compensated to permit direct comparison with the MTC limits.

SR 4.1.1.4.2 currently provides the frequencies and thermal power requirements for determining the MTC during each fuel cycle. This includes prior to initial operation above 5% of rated thermal power after refueling, at any thermal power within 7 effective full power days (EFPD) of initially reaching a rated thermal power equilibrium boron concentration (of 800 ppm for Unit 2),

and at any thermal power within 7 EFPDs of reaching 300 ppm equilibrium boron concentration.

Based on the NRC-approved Revision 2 of TSTF-486, "Revise MTC Surveillancefor Startup Test Activity Reduction (STAR) Program (WCAP-16011), "the proposed changes for both Units include:

L-2013-160 Enclosure Page 3 of 20 Surveillance Requirement 4.1.1.4.1:

Delete the current TS requirements in its entirety and replace with the following:

  • Designate this SR as a test of the MTC upper limit, specified in Limiting Condition for Operation (LCO) 3.1.1.4.

" Add beginning of cycle (BOC) upper limit surveillance requirement prior to entering Mode I after each fuel loading.

" Add a requirement to verify MTC to be within the upper limit within 7 EFPD of reaching 40 EFPD core burnup. This verification is only required if the MTC measured prior to entering Mode 1 is determined using an adjusted predicted MTC.

Surveillance Requirement 4.1.1.4.2:

Delete the current TS requirements in its entirety and replace with the following:

  • Designate this SR as a test of the MTC lower limit, specified in the Core Operating Limits Report (COLR).

" Add a requirement to verify MTC to be within the lower limit within 7 EFPD of reaching 2/3 of expected core burnup.

" Add a note to be consistent with the STS stating: "If the MTC is more negative than the lower limit specified in the COLR when extrapolatedto the end of cycle, 4.1.1.4.2 miay be repeated Shutdown must occur priorto exceeding the mininnm allowable boron concentrationat which MTC is projected to exceed the lower limit." provides the clean revised TS sheets.

2.2 TS Bases Changes As stated currently in the Bases for Units 1 and 2 TS 3/4.1.1.4, the need for measuring MTC to be within its prescribed limits is to ensure that the assumptions in the accident and transient analyses remain valid. This TS amendment revises the MTC Bases of Section 3/4.1.1.4 to add text consistent with TSTF-486, and the CE Standard Technical Specifications, related to the revised MTC surveillance requirements. Marked up sections of the TS Bases are located in .

3.0 TECHNICAL EVALUATION

3.1 MTC Surveillance WCAP-1601 1-P-A describes the methods to be used for the implementation of reduction in the startup testing requirements. The NRC approved WCAP-16011-P-A on January 14, 2005, for referencing in license applications for participating Combustion Engineering (CE)-designed PWRs to the extent specified and under the limitations stated in the topical report and NRC evaluation. St. Lucie Units 1 and 2 are included in the list of participating CE plants.

L-2013-160 Enclosure Page 4 of 20 CE STS SR 3.1.3.1 (analog) was revised to make test frequencies consistent with WCAP-1601 1-P-A, when the alternate MTC verification method is used to verify that the MTC is within the upper limit during startup testing. TSTF-486 has the requirement to perform BOC hot full power (HFP) MTC verification to be within the upper limit, only when MTC, determined prior to entering Mode 1, is verified using the adjusted predicted MTC. The surveillance frequencies (prior to Mode 1, and within 7 EFPD of reaching 2/3 of expected core burnup) are consistent with WCAP-1601 1-P-A and TSTF-486, and applicable to the proposed St. Lucie SR 4.1.1.4.1.

Therefore, they are considered acceptable.

CE STS SR 3.1.3.2 has a note which indicates that if the MTC is more negative than the lower limit specified in the COLR when extrapolated to EOC, the surveillance may be repeated. The note also.adds that shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit. This note is consistent with TSTF-486, and therefore, is considered acceptable for the proposed St. Lucie SR 4.1.1.4.2.

3.2 TS Bases Changes The revision to the St. Lucie TS Bases for Section 3/4.1.1.4 adds text corresponding to the revised surveillance requirements. The additional text is from CE STS Bases that contains the information related to the requirements to be met for verifying the MTC upper limit using predicted adjusted MTC. Also text is added to state the reason for performing the MTC tests specified in SRs 4.1.1.4.1 and 4.1.1.4.2.

The additions above demonstrate that the TS amendments are consistent with TSFT-486, are applicable to the St. Lucie Units, and therefore, are acceptable to include in the St. Lucie TS Bases.

3.3 Optional Changes and Variations The proposed changes to the St. Lucie Units 1 and 2 Technical Specifications satisfy the intent of TSTF-486. The primary difference between CE STS (analog) and this license amendment is found in the proposed SR 4.1.1.4.2, which does not include the MTC measurements within 7 EFPD of reaching 40 EFPD core burnup to be extrapolated for comparison to the lower MTC limit. This extrapolation is not necessary for lower limit comparison, as the surveillance at 2/3 of core burnup will be performed and available for extrapolation to verify the lower MTC limit.

The extrapolation of MTC measured within 7 EFPD of reaching 40 EFPD will not add any additional technical value for comparison to the MTC lower limit and therefore, this deviation is considered acceptable.

4.0 REGULATORY EVALUATION

In 10 CFR 50.36, the NRC established the regulatory requirements related to the content of the Technical Specifications. Pursuant to 10 CFR 50.36, the TS are required to include items in the following five specific categories related to station operation:

L-2013-160 Enclosure Page 5 of 20 (1) Safety limits, limiting safety system settings, and limiting control settings (2) Limiting conditions for operation (LCOs)

(3) Surveillance requirements (SRs)

(4) Design features (5) Administrative controls Although the proposed changes modify the MTC surveillance requirements, the MTC surveillance requirements continue to remain in the Technical Specifications. None of the other categories are impacted by the proposed amendment.

4.1 No Significant Hazards Consideration (NSHC) Determination The standards used to arrive at a determination that a request for amendment involves a NSHC are included in 10 CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (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.

Pursuant to the requirements of 10 CFR 50.91(a), an analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes for St. Lucie Units 1 and 2 revise the MTC Technical Specification SR 4.1.1.4.1 and 4.1.1.4.2 for each Unit, to implement the requirements of the topical report WCAP-16011-P-A, STAR Program.

The MTC is not an initiator to any accident previously evaluated. Therefore, there is no significant increase in the probability of any accident previously evaluated. The MTC is an input to the accident analyses used to predict plant behavior in the event of an accident. The MTC limits specified in the Technical Specifications/COLR remain unchanged. WCAP-1601 1-P-A demonstrated, and the NRC concurred, that the modified MTC verification is adequate to ensure that MTC stays within the limits. The consequences of an accident after adopting TSTF-486 are no different than the consequences of an accident prior to adoption. Likewise, the deviations from the implementation of TSTF-486 requirements being adopted in this license amendment do not have any effect on the probability of occurrence or consequences of accidents previously evaluated.

L-2013-160 Enclosure Page 6 of 20 Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

No new or different accidents will result from implementation of the proposed changes.

The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing nonnal plant operation. In addition, the changes do not impose any new or different operating requirements or eliminate any existing requirements. The changes do not alter limits and assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

TSTF-486 provides the means and requirements for CE-designed plants to implement the previously approved WCAP-1601 1-P-A for MTC verification at startup. MTC is a parameter controlled in the licensee's TS/COLR, including surveillance requirements. As stated previously, WCAP-1601 1-P-A describes methods to reduce the requirements for startup testing. The proposed changes to the TS, supported by TSTF-486, have been reviewed and found to be consistent with WCAP-1601 1-P-A. The changes in the license amendment which deviate from TSTF-486 requirements are justified to be acceptable and do not affect the margin of safety. The MTC limits are unaffected and an acceptable method will be used to verify the MTC to be within its limit. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the previous discussion of the amendment request, it is detennined that the proposed amendment does 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 previously evaluated; or (3) involve a significant reduction in a margin of safety; the amendment does not involve a significant hazards consideration.

4.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on September 6, 2007 for this TS improvement, FPL verified the applicability of TSTF-486 to St. Lucie Units 1 and 2, and will establish Technical Specification Bases for TS 3.1.1.4 consistent with TSTF-486, Revision 2, as applicable.

The proposed TS changes modify the St. Lucie Units 1 and 2 Technical Specification SRs 4.1.1.4.1 and 4.1.1.4.2 by revising the frequencies to verify the MTC upper and lower limits.

L-2013-160 Enclosure Page 7 of 20 These changes require verifying that MTC is within the upper limit each fuel cycle prior to entering Mode 1 after each fuel loading, and within 7 EFPD of reaching 40 EFPD of core burnup only when the MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC. Also, the SRs established require verifying that MTC is within the lower limit specified in the COLR each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup.

The proposed TS amendment for SR 4.1.1.4.2 slightly deviates from TSTF-486 requirements as provided in Section 3.3. The deviation from TSTF-486 requirements is considered acceptable and does not represent a technical issue.

The TS Bases are also modified to describe the bases for the revised surveillance requirements utilizing the suggested changes in WCAP-16011-P-A.

5.0 ENVIRONMENTAL EVALUATION A review has determined that this TS amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. The NRC has previously issued a proposed finding that similar amendments to the CE STS involve no significant hazards considerations, and there was no public comment on the finding.

Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the proposed amendments.

6.0 CONCLUSION

S TSTF-486 provides standardized wording for plants implementing the requirements of WCAP-16011-P-A for alternate MTC verification at startup such as St. Lucie Units 1 and 2. The proposed changes are consistent with WCAP-1601 1-P-A, and therefore, the proposed changes are considered acceptable.

This evaluation concludes, on the basis of 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.

L-2013-160 Enclosure Page 8 of 20 Attachment I Proposed Technical Specification Change Markups Unit 1 Page 3/4.1-5 Page 3/4.1-6 Unit 2 Page 3/4.1-5 Attachment 1

L-2013-160 Enclosure Page 9 of 20 REACTIVITY:CONTROL SYSTEMS MODERATOR TEMPERATURE COEFFICIENT UMI"ING CONDITION FOR OPERATION 3-1 1A The moderator temperature coefficient (MTC).shall be maintained within the limits specifed in cheOLR. The maximum positive limit shall beý.

a.. Less positive than +7 pcmr/F whenever THERMAL POWER is < 70% of.:

RATED THERMAL POWER, and

b. Less positive than +2 pcmflF whenever THERMAL POWER"is > 70% of RATED THERMAL POWER-APPLICABILITY:. MODES 1 AND 2*#.

ACTION:

With the moderator temperature coefficient outside any one. of the: abov lim-.its, be in HOT STANDBY w!thin 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

,I.- .- ...,. . . .

  • Wiltl K- > 1:0.
  1. See Special Test Exception 3.10.2.

' t Only required to be performed when MTG determined prior to enteiing MODE 1: is veiffied

]

using adjusted'predicted MTC;.

4:1.1.4.1 Verify MTMis~witip the upper Ilinift specified in LCD .. 14

a. Prioruto enteringMODE 1-after each fuel, l0-oading, and
b. Each fuel'cycle within 7 effective full power days (EFPD) of reaching-40 EFPD W're bwUmupA ST. LUCIE - uNrr i 3/4 1-5 Amendment No-.42, @3, 89,150 Attachment 1

L-2013-160 Enclosure Page 10 of 20 REACTIVITY CONTROL SYSTEMS actcrrnincdl at th c follovwing frcguznoizs aq

.. dur, ac.. FU el-eyelet izc - xnirtc rLJCOI:QRAAInrAc "I-idiAnl II

-16YEER.

G" 4-F-F=PD Q"F HUM 130FOR 66F1eefiVs4#:'Ht6Z4"iý MAL ROW ER, vW, i3ý D THEP.NAL.1 GWER A FiUFR beF eFi deFieeFitf-;A ý;ý Q Ff-4.-1.1 .4.2"-! .Verfy MTC Is Within tlh* lower flimit spe- ifi e'd in thehC'LRF Each fuel cycle within 7 EFPD ot reaching 2/3 of expected core bumup.

.It MTG is more negative than, the lower limidt 'spedclfed in the COLR when

.1 extrapo.ed to the end, of.ycle, 4.1.142 himay. be repeated. Shutdown mu-t occur pi6rIto .eceeding the minjmumýailowable' boron concentration at Which MTC is projected toexceed the lower limit

.STLUCIE:- UNT [1 ýX 1-6 Amen rnent No.:27 Attachment 1

L-2013-160 Enclosure Page 11 of 20 REACTIVITY CONTROL SYSTEMS MODERATOR TEMPERATURE COEFFICIENT LIMmNG CONDMON FOR OPERATION 3-1.1.4 The maderatorktmpenit.ure ocoefficient [MINTC) shall beý maintaned, wiAthin. the limits specilfedin the COUR: .The maxium- mupper Emit shall be +5. pcm/'-F. ats 70% of RATED THERMAL POWER;.with a" inear -armp from +5 pc-rrF-at 70%9 of RATED "H.ERmAL.

POWER to 0 pcrnF ad- 1(K% RATED THERMAL POWER_

APPUCABIUTY: MODES.1 AND 2'#.

ACTION:

With ihe moderator temperature coefficlernt outside any oneof the ab&%,ejimits,:be -in af least HOT STANDBY'wvhin B houis_

SURVEILLANCE RFOUIREMENTS CCYN N~C N 'CT'('TN Y N V, X VV T. VNNVV Y VV' V V

-<IAlA TheMT M shalt be determrinedttodbe 1within.its limits bycohfim-atory meai~irem~rrfens;TC t

'N,, measurerd vafuesshaJ be extrapola ed inadnic compensated to permit dire5tjmanson

( 4- 11.A.2 'The Mt~shal[ be dekenm-ned at th folloring fr6quencies ii.

' "  :.ondibrnfltrgi

  • c* esci.i .uel cyc-e: "

RAL POW-ER

a. Priar t6 jnitial6p-'Tý,nabove 5%of RATE.--4ERMAL. POWER, fter each ,"*

b: At any THERMALOWER. w 7. EFP.D aftereacing:a RTED ThERMAL POWER eqtlibnum bcwnce.nrii&i of.80w r, .

c. At any TWE.V*AArkOWER. hthin 7 EFPDadcet hng a RA'TED THERMAL POWER e..* ,m baron concent6aion, of 300 WiqrkerrffGreater than or equat to LU.C.- 4 r'*.eea3pecialTe-t.Ex~cepticn3A10.2and3Al5.

INSERT*1 7 ST. IuCiE - u*i 2 . 34 15 fmaeixmt-H. ,3. i Attachment 1

L-2013-160 Enclosure Page 12 of 20 INSERT 1 4.1.1.4.1 Verify MTC is within the upper limit specified in LCO 3.1.1.4.

a. Prior to entering MODE 1 after each fuel loading, and
b. Each fuel cycle within 7 effective full power days (EFPD) of reaching 40 EFPD core burnup. **

4.1.1.4.2*** Verify MTC is within the lower limit specified in the COLR.

Each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup.

  1. See Special Test Exception 3.10.2 and 3.10.5.
  • With Keff greater than or equal to 1.0.
    • Only required to be performed when MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC.
      • IF MTC is more negative than the lower limit specified in the COLR when extrapolated to the end of cycle, 4.1.1.4.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.

Attachment 1

L-2013-160 Enclosure Page 13 of 20 Attachment 2 Word Processed Technical Specification Changes Unit I Page 3/4.1-5 Page 3/4.1-6 Unit 2 Page 3/4.1-5 Attachment 2

L-2013-160 Enclosure Page 14 of 20 REACTIVITY CONTROL SYSTEMS MODERATOR TEMPERATURE COEFFICIENT LIMITING CONDITION FOR OPERATION 3.1.1.4 The moderator temperature coefficient (MTC) shall be maintained within the limits specified in the COLR. The maximum positive limit shall be:

a. Less positive than +7 pcmiF whenever THERMAL POWER is < 70% of RATED THERMAL POWER, and
b. Less positive than +2 pcm/F whenever THERMAL POWER is > 70% of RATED THERMAL POWER.

APPLICABILITY: MODES 1 AND 2*#.

ACTION:

With the moderator temperature coefficient outside any one of the above limits, be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.1.4.1 Verify MTC is within the upper limit specified in LCO 3.1.1.4.

a. Prior to entering MODE 1 after each fuel loading, and
b. Each fuel cycle within 7 effective full power days (EFPD) of reaching 40 EFPD core burnup.**

With Keff > 1.0.

Only required to be performed when MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC.

  1. See Special Test Exception 3.10.2.

ST. LUCIE - UNIT 1 3/4 1-5 Amendment No. 27-,63,46, 4.50 Attachment 2

L-2013-160 Enclosure Page 15 of 20 REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (continued) 4.1.1.4.2*** Verify MTC is within the lower limit specified in the COLR.

Each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup.

If MTC is more negative than the lower limit specified in the COLR when extrapolated to the end of cycle, 4.1.1.4.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.

ST. LUCIE - UNIT 1 3/4 1-6 Amendment No. 2-7 Attachment 2

L-2013-160 Enclosure Page 16 of 20 REACTIVITY CONTROL SYSTEMS MODERATOR TEMPERATURE COEFFICIENT LIMITING CONDITION FOR OPERATION 3.1.1.4 The moderator temperature coefficient (MTC) shall be maintained within the limits specified in the COLR. The maximum upper limit shall be +5 pcm/°F at _*70% of RATED 0

THERMAL POWER, with a linear ramp from +5 pcm/ F at 70% of RATED THERMAL POWER to 0 pcm/°F at 100% RATED THERMAL POWER.

APPLICABILITY: MODES 1 AND 2*#.

ACTION:

With the moderator temperature coefficient outside any one of the above limits, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.1.4.1 Verify MTC is within the upper limit specified in LCO 3.1.1.4.

a. Prior to entering MODE 1 after each fuel loading, and
b. Each fuel cycle within 7 effective full power days (EFPD) of reaching 40 EFPD core burnup. **

4.1.1.4.2*** Verify MTC is within the lower limit specified in the COLR.

Each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup.

See Special Test Exception 3.10.2 and 3.10.5.

With Kefr greater than or equal to 1.0.

Only required to be performed when MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC.

..* If MTC is more negative than the lower limit specified in the COLR when extrapolated to the end of cycle, 4.1.1.4.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.

ST. LUCIE - UNIT 2 3/4 1-5 Amendment No. 4-4, 25, 56,2, 439 Attachment 2

L-2013-160 Enclosure Page 17 of 20 Attachment 3 Proposed Technical Specification Bases Changes (Information Only)

Attachment 3

L-2013-160 Enclosure Page 18 of 20 SECTION.NO.: TITLE TECHNICAL SPECIFICATIONS PA.E..

3/4.1 BASES ATTACHMENT 3 OF ADM-25-04 4of 41 REVISION NO_: REACTIVITY CONTROL SYSTEMS 3 ST_ LUCIEUNrI 1 314.1 REACTIVITY CONTROL. SYSTEMS (continued): L~

BASES (contiLnued) 314.1.1 BORATION CONTROL (continued)*

314.11.4 MODERATOR TEMPERATURE COEFFICIENT (MTC)

The'liniting values of the MT-C:ensure thatthe assubmptions for the MTC used.in the accident and transient analyses remain valid through each fuel Cyde. Determination.of M-C at the-.specified conditions.ensures.that the maximum positive and/or negative Values of thie MTC wmill not exceed the limiting values, 314.1.1.5: MINIMUM TEMP ERATURE FOR CRITICALITY The MTC is expe tted to be slightly negative at operatng conditions_.

However. at the Iginning of the.fuel cycle, the MTC may be.slightly positive at operati ig conditions andsince t.will become more positive,at lower temperature :-this speciflcati*n is provided to restrict reactor operatio.n when T1 'is'significantly bielow the normal operating temperature_

fNSERT"A....j Attachment 3

L-2013-160 Enclosure Page 19 of 20 SECTON NO: TITLE: TECHN'ICAL SPECIFICATIONS PAGE.

3/4.1 BASES ATTACHMENT 3 OF ADM-25. -04 of 99 REVISION NO.: REACTIVITY CONTROL SYSTEMS ."

5 ST.LUCIE UNIT-2.

314.1 REACTIVITY CONTROL SYSTEMS (continued)

BASES (continued) 314.1.1 BORATION CONTROL (continued) 314.1.1.4 MODERATOR TEMPERATURE COEFFICIENT The limitations on moderator temperature coefricient (MTC) are provided to ensure-that the assumptions used in the-accident and transient analysis remain valid through: each fuel cycle. The.surveillance irequirements for measurement of the MTC during.each fuel cyce are adequate to confirm the MTC value since, this coefficient changes slowly due principally to the reduction in RCS boron concentration associated with fuel burmup. The confirmation that the measured M-TC value is. Within its limit provides asstuances that the coefficient .will be maintained within acceptable values.

throGghout: each fuel cyde-.

3/4.1.1.5 MINIMUM TEMPFOATUREIFOR CRITICALITY This specification ensures that the reactor-will not be made critical with the

.Reactor:CoolantSystemr aive'age temperature less :than. 515'F- This limitation is required to ensure (1) the moderator temperature~coeflicient is within its analyzed temperaturý range (2) the protective instrumentation. is within its normal operating range, (.3) the pressurizer is capable of. being in*tin OPEFRAB.LE status with a steat bubble, and (4) the reactor pressure vessel.

is, above its minimum RTh6-r tetnperature.

.. INSERTA Attachment 3

L-2013-160 Enclosure Page 20 of 20 Insert A For fuel cycles that meet the applicability requirements in WCAP-1601 I-P-A Rev. 0, "Startup Test Activity Reduction Program," (STAR) and specifically, the acceptance criteria to substitute the measured value of MTC at hot zero power (HZP) with an alternate MTC value, SR 4.1.1.4.1 may be met prior to entering MODE 1 after each fuel loading by confirmation that the predicted MTC, when adjusted for the measured RCS boron concentration, is within the most positive (least negative) MTC limit specified in the LCO. If the adjusted predicted MTC value is used to meet the SR prior to entering MODE 1, a confirmation by measurement that MTC is within the upper MTC limit must be performed in MODE 1 within 7 Effective Full Power Days (EFPD) after reaching 40 EFPD of core burnup. The applicability requirements in WCAP-16011-P-A ensure core designs are not significantlydifferent from those used to benchmark predictions and require that the measured RCS boron concentration meets specific test criteria. This provides assurance that the MTC obtained from the adjusted predicted MTC is accurate.

For fuel cycles that do not meet the applicability requirements in WCAP-16011-P-A, the verification of MTC required prior to entering Mode 1 after each fuel cycle loading is performed by calculation of the MTC based on measurement of the isothermal temperature coefficient. In this case, measurement of MTC within 7 EFPD after reaching 40 EFPD of core burnup is not required.

The requirements for MTC measurement prior to operation > 5% and/or within 7 EFPDs of reaching 40 EFPD core burnup satisfy the confirmatory check on the most positive (least negative) MTC value.

The requirement for measurement, within 7 EFPD of reaching 2/3 core burnup, satisfies the confirmatory check of the most negative MTC value. The measurement is performed at any THERMAL POWER, so that the projected EOC MTC may be evaluated before the reactor actually reaches the EOC condition. MTC values may be extrapolated and compensated to permit direct comparison to the MTC limits specified in the COLR.

SR 4.1.1.4.2 is modified by a Note, which indicates that if the extrapolated MTC is more negative than the lower limit specified in the COLR, the Surveillance may be repeated, and the shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit. An evaluation to determine this minimum boron concentration is necessary to ensure the MTC limit used in the safety analyses is not violated.

Attachment 3