Text

St, Lucie Nuclear Plant, Units 1 and 2, License Amendment Request, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler -523, Generic Letter 2008-01, Managing Gas Accumulation, Using Th
	ML14198A074
Person / Time
Site:	Saint Lucie
Issue date:	07/14/2014
From:	Jensen J; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, L-2014-029
	Download: ML14198A074 (64)
	v • d • e

0July FPL.

14, 2014 L-2014-029 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 St, Lucie Nuclear Plant Units 1 and 2 Docket Nos. 50-335 and 50-389 Renewed Facility Operating Licenses Nos. DPR-67 and NPF-16 License Amendment Request, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler -523, "Generic Letter 2008-01, Managing Gas Accumulation," Using the Consolidated Line Item Improvement Process References

1. Letter (L-2008-221) from G. L. Johnson (FPL) to Document Control Desk (NRC), "Nine Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"

October 14, 2008 (ADAMS Accession No. ML082900487)

Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) is submitting a request for amendment to the Technical Specifications for St. Lucie Nuclear Plant (St. Lucie), Units 1 and 2.

The proposed amendment would modify TS requirements to address NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in TSTF-523, Revision 2 "Generic Letter 2008-01, Managing Gas Accumulation." FPL committed to submit this proposed change in Reference 1.

Attachment 1 provides a description and assessment of the proposed change. Attachment 2 provides the existing St. Lucie Unit 1 TS pages marked up to show the proposed change.

Attachment 3 provides the St. Lucie Unit 1 revised (clean) TS pages. Attachment 4 provides the existing St. Lucie Unit 1 TS Bases pages marked to show the proposed change.

Attachment 5 provides the existing St. Lucie Unit 2 TS pages marked up to show the proposed change. Attachment 6 provides the St. Lucie Unit 2 revised (clean) TS pages.

Attachment 7 provides the existing St. Lucie Unit 2 TS Bases pages marked to show the proposed change. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specification Bases Control Program. They are provided in Attachments 4 and 7 for information only.

Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2014-029 Page 2 of 2 Approval of the proposed amendment is requested within one year of submittal. Once approved the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application is being sent to the designated State of Florida Official.

This application has been reviewed by the St. Lucie Onsite Review Group.

This letter satisfies FPL's commitment made in Reference 1 and makes no new commitments or changes to any other existing commitments.

If you have any questions or require additional information, please contact Eric Katzman at 772-467-7734.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on\\3 I1, 2014.

icie Nuclear Plant Attachments: Description and Assessment

2. Proposed St. Lucie Unit 1 TS Changes (marked-up pages)

3. Proposed St. Lucie Unit 1 TS Changes (clean/typed pages)

4. Proposed St. Lucie Unit 1 TS Bases Changes (marked-up pages) -

For information only

5. Proposed St. Lucie Unit 2 TS Changes (marked-up pages)

6. Proposed St. Lucie Unit 2 TS Changes (clean/typed pages)

7. Proposed St. Lucie Unit 2 TS Bases Changes (marked-up pages) -

For information only cc: Ms. Cindy Becker, Florida Department of Health

L-2014-029 Attachment 1 Page 1 of 5 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment I St. Lucie Nuclear Plant Description and Assessment

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration 3.2 Applicable Regulatory Requirements/Criteria 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

L-2014-029 Attachment 1 Page 2 of 5 ATTACHMENT I DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. The changes are being made to address the concerns discussed in NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," [Reference 2].

The proposed amendment is consistent with Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" [Reference 3].

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Florida Power & Light Company (FPL) has reviewed the model safety evaluation published January 15, 2014 as part of the Federal Register Notice of Availability, "TSTF-523, Generic Letter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process" (79 FR 2700) [Reference 4]. This review included the NRC staffs evaluation, as well as the information provided in TSTF-523. As described in the subsequent paragraphs, FPL has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC staff are applicable to St. Lucie Units 1 and 2 and justify this amendment for incorporation of the changes to the St. Lucie Technical Specifications (TS).

2.2 Optional Changes and Variations FPL is proposing the following variations or deviations from the TS changes described in TSTF-523, Revision 2 [Reference 3], or the applicable parts of the NRC staffs model safety evaluation.

St. Lucie Units 1 and 2 each have their own TS that differ in some areas. However, for the TS being changed in this proposal, the numbers and titles for the Unit 1 and Unit 2 TS are identical.

The St. Lucie TS utilize different numbering, format, and titles than NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants," [Reference 5] on which TSTF-523 was based. Specifically, the numbering and title differences are provided in the table below.

NUREG-1432 St. Lucie Standard Technical Specifications Units I and 2 Combustion Engineering Plants Technical Specifications 3.4.6, RCS Loops - MODE 4 3/4.4.1.3, Reactor Coolant System - Hot Shutdown 3.4.7, RCS Loops - MODE 5 Loops Filled 3/4.4.1.4.1, Reactor Coolant System - Cold I Shutdown - Loops Filled

L-2014-029 Attachment 1 Page 3 of 5 NUREG-1432 St. Lucie Standard Technical Specifications Units 1 and 2 Combustion Engineering Plants Technical Specifications 3.4.8, RCS Loops - MODE 5 Loops Not Filled 3/4.4.1.4.2, Reactor Coolant System - Cold Shutdown - Loops Not Filled 3.5.2, ECCS - Operating 3/4.5.2, ECCS Subsystems - Operating 3.6.6, Containment Spray and Cooling Systems 3/4.6.2, Depressurization and Cooling Systems -

Containment Spray and Cooling Systems 3.9.4, SDC and Coolant Circulation - High Water 3/4.9.8.1, Shutdown Cooling and Coolant Level Circulation - High Water Level 3.9.5, SDC and Coolant Circulation - Low Water 3/4.9.8.2, Shutdown Cooling and Coolant Level Circulation - Low Water Level These differences are administrative and do not affect the applicability of TSTF-523 to St. Lucie.

TSTF-523 and the model safety evaluation discuss the applicable regulatory requirements and guidance including 10 CFR 50, Appendix A, General Design Criteria (GDC). St. Lucie Unit 1 was not licensed to 10 CFR 50, Appendix A, GDC. However, the St. Lucie Updated Final Safety Analysis Report (UFSAR) Section 1.3, Conformance with the General Design Criteria, provides a discussion of the St. Lucie Unit 1 design with respect to each of the GDC. This difference does not alter the conclusion that the proposed change is applicable to St. Lucie Unit 1.

St. Lucie Unit 2 was licensed and conforms to 10 CFR 50, Appendix A, General Design Criteria.

3.0 REGULATORY SAFETY ANALYSIS 3.1 No Significant Hazards Consideration Determination Florida Power & Light Company (FPL) requests adoption of Technical Specification Task Force Traveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications (STS), into the St. Lucie Units 1 and 2 Technical Specifications (TS). The proposed change revises or adds Surveillance Requirements (SRs) to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

FPL has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1: Does the Proposed Change Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?

Response: No

L-2014-029 Attachment 1 Page 4 of 5 The proposed change revises or adds SRs that require verification that the Emergency Core Cooling Systems (ECCS), Residual Heat Removal (RHR) System, Shutdown Cooling (SDC)

System, and Containment Spray (CS) System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable of performing their assumed safety function and are not rendered inoperable due to gas accumulation. Thus, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does 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?

Response: No The proposed change revises or adds SRs that require verification that the ECCS, RHR System, SDC System, and CS System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change does 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 normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

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?

Response: No The proposed change revises or adds SRs that require verification that the ECCS, RHR System, SDC System, and CS System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change adds new requirements to manage gas accumulation in order to ensure that the subject systems are capable of performing their assumed safety functions. The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected. The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis. Therefore, there are no changes being made to any safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

L-2014-029 Attachment 1 Page 5 of 5 Therefore, the proposed change does not involve a significant reduction in a margin of safety.

3.2 Applicable Regulatory Requirements/Criteria Based on the above, FPL concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed 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 Part 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets 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 be prepared in connection with the proposed change.

5.0 REFERENCES

1. Letter (L-2008-221) from G. L. Johnson (FPL) to Document Control Desk (NRC), "Nine Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"

October 14, 2008 (ADAMS Accession No. ML082900487)

2. Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," January 11, 2008, (ADAMS Accession No. ML072910759)

3. Technical Specifications Task Force (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," February 23, 2013, (ADAMS Accession No. ML13053A075)

4. Federal Register Notice of Availability, "TSTF-523, Generic Letter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process," published January 15, 2014 (79 FR 2700)

5. NUREG-1432, Revision 4, "Standard Technical Specifications - Combustion Engineering Plants," April 2012 (ADAMS Accession No. ML12102A169)

L-2014-029 Attachment 2 Page 1 of 8 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 2 St. Lucie Unit 1 Technical Specifications Changes Marked Up Pages 3/4 4-1c 3/4 4-1d 3/4 4-1e 3/4 5-4 3/4 6-15a 3/4 9-8 3/4 9-8a

L-2014-029 Attachment 2 Page 2 of 8 REACTOR COOLANT SYSTEM HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required reactor coolant pump(s), if not in operation, shall be determined to be OPERABLE once per 7 days by verifying correct breaker align-ments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying the secondary side water level to be > 10% of narrow range indica-tion at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.3.3 At least one reactor coolant or shutdown cooling loop shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.3.4 Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.*

1* Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

ST. LUCIE - UNIT 1 3/4 4-1c Amendment No. 5&

L-2014-029 Attachment 2 Page 3 of 8 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and in operation* and either:

a. One additional shutdown cooling loop shall be OPERABLE, or

b. The secondary side water level of at least two steam generators shall be greater than 10% of narrow range indication.

APPLICABILITY: MODE 5 with reactor coolant loops filled ACTION:

a. With less than the above required loops OPERABLE or with less than the required steam generator level, within one (1) hour initiate corrective action to return the required loops to OPERABLE status or to restore the required level.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and within one (1) hour initiate corrective action to return the required shutdown loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be determined to be within limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.1.3 Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided 1) no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and

2) core outlet temperature is maintained at least 10 OF below saturation temperature.

One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other shutdown cooling loop is OPERABLE and in operation.

1. A reactor coolant pump shall not be started with two idle loops unless the secondary water temperature of each steam generator is less than 309F above each of the Reactor Coolant System cold leg temperatures.

ST. LUCIE- UNIT 1 3/4 4-1 d Amendment No. &G,1-,.,

403,44L.,

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L-2014-029 Attachment 2 Page 4 of 8 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two shutdown cooling loops shall be OPERABLEf and at least one shut-down cooling loop shall be in operation*.

APPLICABILITY: MODE 5 with reactor coolant loops not filled.

ACTION:

a. With less than the above required loops OPERABLE, within one (1) hour initiate corrective action to return the required loops to OPERABLE status.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and within one (1) hour initiate corrective action to return the required shutdown cooling loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.2.1 Verify shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

One shutdown cooling loop may be Inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other shutdown cooling loop is OPERABLE and in operation.

The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided 1) no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and 2) core outlet temperature is maintained at least 10F below saturation temperature.

ST. LUCIE - UNIT 1 3M44-1e Amendment No. 66, 4-3, ff9

L-2014-029 Attachment 2 Page 5 of 8 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position

1. V-3659 1. Mini-flow 1. Open isolation

2. V-3660 2. Mini-flow 2. Open Isolation d0)

b. At least once per 31 days by:

QCL

1. Verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or C W otherwise secured in position, is in its correct position.

c. By a visual inspection which verifies that no loose debris (rags, SU) trash, clothing, etc.) is present In the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

0 75 W E M) 1. For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and

>o c)i

2. At least once daily of the areas affected within containment by the containment entry and during the final entry when CONTAINMENT INTEGRITY is established.

d. At least once per 18 months by:

1. Verifying proper operation of the open permissive interlock (OPI) and the valve open/high SDCS pressure alarms for isolation valves V3651, V3652, V3480, V3481.

2. A visual inspection of the containment sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

I Not required to be met for system vent flow paths opened under administrative control. I ST. LUCIE - UNIT 1 3/4 5-4 Amendment No. 00, 420,

-420

L-2014-029 Attachment 2 Page 6 of 8 SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is positioned to take suction from the RVVT on a Containment Pressure

- High High test signal.

b. By verifying that each spray pump develops the specified discharge pressure when tested pursuant to the Inservice Testing Program.

Ic. At least once per 31 days, by verifying containment spray system locations susceptible to gas accumulation are sufficiently filled with water.

1" Not required to be met for system vent flow paths opened under administrative control.I ST. LUCIE - UNIT 1 314 6-15Sa Amendment No. 4..4..-4. 1$04-

L-2014-029 Attachment 2 Page 7 of 8 REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation*.

APPLICABILITY: MODE 6 when the water level above the top of irradiated fuel assemblies seated within the reactor pressure vessel is greater than or equal to 23 feet.

ACTION:

a. With less than one shutdown cooling loop in operation, suspend all operations involving an increase in reactor decay heat load or operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3.9.1.

Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

b. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.8.1 At least one shutdown cooling loop shall be verified to be in operation and circulating reactor coolant at a flow rate of greater than or equal to 3000 gpm at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

The shutdown cooling loop may be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period during the performance of CORE ALTERATIONS in the vicinity of reactor pressure vessel hot legs, provided no operations are perrrmtted that would cause .

introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.9.1.

ST. LUCIE - UNIT 1 3/4 9-8 Amendment No. 66, 4ý

L-2014-029 Attachment 2 Page 8 of 8 REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and at least one shutdown cooling loop shall be in operation.'

APPLICABILITY: MODE 6 when the water level above the top of irradiated fuel assemblies seated within the reactor pressure vessel is less than 23 feet.

ACTION:

a. vVWth less than the required shutdown cooling loops OPERABLE, within one (1) hour 1) initiate corrective action to return the required loops to OPERABLE status, or 2) establish greater than or equal to 23 feet of water above irradiated fuel assemblies seated within the reactor pressure vessel.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3.9.1. and within one (1) hour initiate corrective action to return the required shutdown cooling loop to operation. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

c. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.8.2 At least one shutdown cooling loop shall be verified to be in opera-tion and circulating reactor coolant at a flow rate of greater than or equal to 3000 gpm at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.9.8.2.1 Verity shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

One required shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing, provided that the other shutdown cooling loop is OPERABLE and in operation.

4' ST. LUCIE - UNIT 1 3/4 9-8a Amendment No. 46,. 4-3,4.

4 0R...

Attachment 3 L-2014-029 Page 1 of 8 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 3 St. Lucie Unit 1 Technical Specifications Changes Retyped/Clean Pages 3/4 4-1c 3/4 4-1d 3/4 4-1e 3/4 5-4 3/4 6-15a 3/4 9-8 3/4 9-8a

Attachment 3 L-2014-029 Page 2 of 8 REACTOR COOLANT SYSTEM HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required reactor coolant pump(s), if not in operation, shall be determined to be OPERABLE once per 7 days by verifying correct breaker align-ments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying the secondary side water level to be > 10% of narrow range indica-tion at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.3.3 At least one reactor coolant or shutdown cooling loop shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.3.4 Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days. *

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

ST. LUCIE - UNIT 1 3M44-1 c Amendment No. ý6

Attachment 3 L-2014-029 Page 3 of 8 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and in operation* and either:

a. One additional shutdown cooling loop shall be OPERABLE#, or

b. The secondary side water level of at least two steam generators shall be greater than 10% of narrow range indication.

APPLICABILITY: MODE 5 with reactor coolant loops filled ACTION:

a. With less than the above required loops OPERABLE or with less than the required steam generator level, within one (1) hour initiate corrective action to return the required loops to OPERABLE status or to restore the required level.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and within one (1) hour initiate corrective action to return the required shutdown loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be determined to be within limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.1.3 Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided 1) no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and

2) core outlet temperature is maintained at least 10=F below saturation temperature.

One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other shutdown cooling loop is OPERABLE and in operation.

1. A reactor coolant pump shall not be started with two idle loops unless the secondary water temperature of each steam generator is less than 301F above each of the Reactor Coolant System cold leg temperatures.

ST. LUCIE - UNIT 1 314 4-1d Amendment No. ,9,84. 49.4-79, 49.7

Attachment 3 L-2014-029 Page 4 of 8 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two shutdown cooling loops shall be OPERABLE# and at least one shut-down cooling loop shall be in operations.

APPLICABILITY: MODE 5 with reactor coolant loops not filled.

ACTION:

a. With less than the above required loops OPERABLE, within one (1) hour initiate corrective action to return the required loops to OPERABLE status.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and within one (1) hour initiate corrective action to return the required shutdown cooling loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.2.1 Verify shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other shutdown cooling loop is OPERABLE and in operation.

The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided 1) no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and 2) core outlet temperature is maintained at least 10 *F below saturation temperature.

ST. LUCIE - UNIT 1 3/4 4-1 e Amendment No. 5W,403,479

Attachment 3 L-2014-029 Page 5 of 8 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position

1. V-3659 1. Mini-flow 1. Open isolation

2. V-3660 2. Mini-flow 2. Open isolation

b. At least once per 31 days by:

1. Verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.*

2. Verifying ECCS train locations susceptible to gas accumulation are sufficiently filled with water.

c. By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

1. For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and

2. At least once daily of the areas affected within containment by the containment entry and during the final entry when CONTAINMENT INTEGRITY is established.

d. At least once per 18 months by:

1. Verifying proper operation of the open permissive interlock (OPI) and the valve open/high SDCS pressure alarms for isolation valves V3651, V3652, V3480, V3481.

2. A visual inspection of the containment sump arnd verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

Not required to be met for system vent flow paths opened under administrative control.

ST. LUCIE- UNIT 1 3/4 5-4 Amendment No. 00, 420,

Attachment 3 L-2014-029 Page 6 of 8 SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is positioned to take suction from the RWT on a Containment Pressure

-- High High test signal.*

b. By verifying that each spray pump develops the specified discharge pressure when tested pursuant to the Inservice Testing Program.

c. At least once per 31 days, by verifying containment spray system locations susceptible to gas accumulation are sufficiently filled with water.

Not required to be met for system vent flow paths opened under administrative control.

ST. LUCIE - UNIT 1 3/4 6-15a Amendment No. 4,34-,445,494

Attachment 3 L-2014-029 Page 7 of 8 REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation*.

APPLICABILITY: MODE 6 when the water level above the top of irradiated fuel assemblies seated within the reactor pressure vessel is greater than or equal to 23 feet.

ACTION:

a. With less than one shutdown cooling loop in operation, suspend all operations involving an increase in reactor decay heat load or operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3.9.1.

Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

b. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.8.1 At least one shutdown cooling loop shall be verified to be in operation and circulating reactor coolant at a flow rate of greater than or equal to 3000 gpm at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

The shutdown cooling loop may be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period during the performance of CORE ALTERATIONS in the vicinity of reactor pressure vessel hot legs, provided no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.9.1.

ST. LUCIE - UNIT 1 3/4 9-8 Amendment No. W5,47-

Attachment 3 L-2014-029 Page 8 of 8 REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and at least one shutdown cooling loop shall be in operation.*

APPLICABILITY: MODE 6 when the water level above the top of irradiated fuel assemblies seated within the reactor pressure vessel is less than 23 feet.

ACTION:

a. With less than the required shutdown cooling loops OPERABLE, within one (1) hour 1) initiate corrective action to return the required loops to OPERABLE status, or 2) establish greater than or equal to 23 feet of water above irradiated fuel assemblies seated within the reactor pressure vessel.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3.9.1. and within one (1) hour initiate corrective action to return the required shutdown cooling loop to operation. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

c. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.8.2 At least one shutdown cooling loop shall be verified to be in opera-tion and circulating reactor coolant at a flow rate of greater than or equal to 3000 gpm at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.9.8.2.1 Verify shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

One required shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing, provided that the other shutdown cooling loop is OPERABLE and in operation.

ST. LUCIE - UNIT t 3149Ma Amendment No. W0,403, 479,4-9

L-2014-029 Attachment 4 Page 1 of 12 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 4 St. Lucie Unit 1 Technical Specifications Bases Changes Marked Up Pages For Information Only

L-2014-029 Attachment 4 Page 2 of 12 SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PAGEL.

3/4.4 BASES ATTACHMENT 6 OF ADM-25.04 3 df'36 R VISCNN.: REACTOR COOLANT SYSTEM ST. LUCIE UNIT 1 BASES F OR SECTION 314.4 77,'

3/4.4 REACTOR COOLANT SYSTEM BASES 3W4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION The plant is designed to operate with both reactor coolant loops and associated reactor coolant pumps in operation, and maintain DNBR above the DNBR limit during all normal operations and anticipated transients. In MODES 1 and 2 with one reactor coolant loop not in operation, this specification requires that the plant be inat least HOT STANDBY within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

In MODE 3, a single reactor coolant loop provides sufficient heat removal capability for removing decay heat' however, single failure considerations require that two loops be OPERABLE.

in In MODE 4, and inMODE 5 with reactor coolant loops filled, a single C reactor coolant loop or shutdown cooling loop provides sufficient heat 0 LU removal capability for removing decay heat; but single failure

.s considerations require that at least two loops (either shutdown cooling or

.L E RCS) be OPERABLE. In MODE 5 with reactor coolant loops not filled, a a single shutdown cooling loop provides sufficient heat removal capability for removing decay heat; but single failure considerations and the

- unavailability of the steam generators as a heat removing component, 0 require that at leasttwo shutdown cooling loops be OPERABLEE_..

4-0 The operation of one Reactor Coolant Pump or one shutdown cooling 5 pump provides adequate flowto ensure mbing, prevent stratification and produce gradual reactivity changes during boron concentration reductions X inthe Reactor Coolant System. The reactivity change rate associated with boron reductions will, therefore, be within the capability of operator recognition and control.

If no coolant loops are in operation during shutdown operations, suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1.1 or 3.1.1.2 is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required inthe RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction inRCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

L-2014-029 Attachment 4 Page 3 of 12 SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PAGEt-:.

3/4.4 BASES ATTACHM ENT 6 OF ADM-25.04 4 df35 RNEVSCINNO.: REA CTO R COO0LANT SY STE M ST. LUCIE UNIT 1r.

3/4.4 REACTOR COOLANT SYSTEM (continued) [7 BASES (continued) 314.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION (continued)

The restrictions on starting a Reactor Coolant Pump are provided to prevent RCS pressure transients, caused by energy additions from the secondary system, which could exceed the limits of Appendix G to 10 CFR 50. The RCS will be protected against overpressure transients and will not exceed the limits of Appendix 0 by restricting starting of the Reactor Coolant Pumps to when the secondary water temperature of each steam generator is less than 30IF above each of the Reactor Coolant System cold leg temperatures.

3/4.4.2 DELETED INSERT 1 3/4.4.3 SAFETY VALVES (net page)

The pressurizer code safety valves operate to prevent the RCS from being pressurized above its Safety Limit of 2750 psia. Each safety valve is designed to relieve 2 x 105 lbs per hour of saturated steam at the valve setpoint. The relief capacity of a single safety valve is adequate to relieve any over-pressure condition which could occur during shutdown. In the event that no safety valves are OPERABLE, an operating shutdown cooling loop, connected to the RCS, provides overpressure relief capability and will prevent RCS overpressurization.

During operation, all pressurizer code safety valves must be OPERABLE to prevent the RCS from being pressurized above its safety limit of 2750 psia. The combined relief capacity of these valves is sufficient to limit the Reactor Coolant System pressure to within its Safety Limit of 2750 psia following a complete loss of turbine generator load while operating at RATED THERMAL POWER and assuming no reactor trip until the first Reactor Protective System trip setpoint (Pressurizer Pressure-High) is reached (i.e., no credit istaken for a direct reactor trip on the loss of turbine) and also assuming no operation of the pressurizer power operated relief valve or steam dump valves.

Surveillance Requirements are specified in the Inservice Testing Program.

Pressurizer code safety valves are to be tested in accordance with the requirements of Section XI of the ASME Code, which provides the activities and the frequency necessary to satisfy the Surveillance Requirements. No additional requirements are specified.

L-2014-029 Attachment 4 Page 4 of 12 I'sET1I Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required shutdown cooling loops and may also prevent water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel.

Selection of Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety concerns. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

SR 4.4.1.3.4 is modified by a Note that states the Surveillance Requirement is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

The 31 -day frequency for ensuring locations are sufficiently filled with water takes into consideration the gradual nature of gas accumulation in the SDC System piping and the procedural controls governing system operation.

L-2014-029 Attachment 4 Page 5 of 12

E: TION NO.: TITLE: TECHNICAL SPECIFICATIONS FAE: I I'

3/4.5 BASES ATTACHMENT 7 OF ADM-25.04 -4 6 RIEVSON NO.: EMERGENCY CORE COOLING SYSTEMS (ECCS)

-- ST. LUCIE UNIT 1 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued)

BASES (continued) 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS The OPERABILITY of two separate and independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available in the event of a LOCA assuming the loss of one subsystem through any single failure consideration. Either subsystem operating in conjunction with the safety injection tanks is capable of supplying sufficient core cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double ended break of the largest RCS cold leg pipe downward. In addition, each ECCS subsystem provides long term core cooling capability in the recirculation mode during the o2 accident recoverypqý TS 3.5.2.c and 3.5.3.a require that ECCS subsystem(s) have an o independent OPERABLE flow path capable of automatically transferring E suction to the containment sump on a Recirculation Actuation Signal.

L The containment sump is defined as the area of containment below the

.>: minimumflood level inthe vicinity of the containment sump strainers.

h- Therefore, the LCOs are satisfied when an independent OPERABLE flow c, path to the containment sump strainer is available.

o n TS 3.5.2.d requires that an ECCS subsystem(s) have OPERABLE charging caDC pump and associated flow path fromthe BAMT(s). Reference toTS 3.1.2.2

_o requires thatthe Train A charging pump flowpath isfrom the BAMT(s) o through the boric acid makeup pump(s). The Train B charging pump MW flowpath isfrom the BAMT(s) through the gravity feed valve(s).

TS 3.5.2, ACTION a.l. provides an allowed outage/action completion time (AOT) of upto 7 daysfrom initial discovery of failure to meet the LCO provided the affected ECCS subsystem is inoperable only because its associated LPSI train is inoperable. This 7 day AOT is based on the findings of a deterministic and probabilistic safety analysis and is referred to as a "risk-informed" AOT extension. Entry into this ACTION requires that a risk assessment be performed in accordance with the Configuration Risk Management Program (CRMP) which is described in the Administrative Procedure (ADM-17.08) that implements the Maintenance Rule pursuant to 10 CFR 50.65.

The Surveillance Requirements provided to ensure OPERABILITY of each component ensure that at a minimum, the assumptions used in the accident analyses are met and that subsystem OPERABILITY is maintained.

L-2014-029 Attachment 4 Page 6 of 12 C:TION NO.: TrrLE: TECHNICAL SPECIFICATIONS PAO l 3f4.5 BASES ATTACHMENT 7 OF ADM-25.04 56f RFV INN.: EMERGENCY CORE COOLING SYSTEMS (ECCS) 5o

- ST. LUCIE UNIT 1 31/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued) A- 'K-.-

BASES (continued) 3/4.5.2 and 3X4.5.3 ECCS SUBSYSTEMS (continued)

Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one point on the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and thatthe performance atthe test flow is greater than or equal to the performance assumed in the unit safety analysis. Surveillance Requirements are specified in the Inservice Testing Program, wthich encompasses Section Xl of the ASME Code.Section XI ofthe ASME Code provides the activities and frequencies necessary to satisfy the requirements.

. TS Surveillance Requirement 4.5.2.c requires that each ECCS shall be

"* demonstrated OPERABLE by visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the sump I- suctions during LOCA conditions.

co TS Surveillance Requirement 4.5. 2.d.2 requires that each ECCS subsystem Z- be demonstrated OPERABLE at least overy 18 months by visual inspection of the containment sump and verifying that the suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

There are no trash racks or screens associated with the sump components, but the current Technical Specification of"sump components (trash racks, screens, etc.)" sufficiently encompasses the strainer modules. Therefore, the surveillance requirements are satisfied when visual inspection verifies that loose debris is not present which could be transported to the strainers, and by visual inspection of the strainer modules and associated equipment for structural distress or corrosion.

The Iimftations on HPSI pump operability when the RCS temperature is e 270OF and _ 236PF, and the associated Surveillance Requirements provide additional administrative assurance that the pressure/temperature limits (Figures 3.4-2a and 3.4-2b) will not be exceeded during a mass addition transient mitigated by a single PORV. A limit on the maimum number of operable HPSI pumps is not necessary when the pressurizer manway cover or the reactor vessel head is removed.

L-2014-029 Attachment 4 Page 7 of 12 INSERT 2 TS Surveillance Requirement 4.5.2.b.1 is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. The individual will have a method to rapidly close the system vent path ifdirected.

TS Surveillance Requirement 4.5.2.b.2 ensures that ECCS locations susceptible to gas accumulation are sufficiently filled with water.

ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety concerns. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 -day frequency for SR 4.5.2.b.1 takes into consideration the gradual nature of gas accumulation in the ECCS piping and the procedural controls governing system operation.

L-2014-029 Attachment 4 Page 8 of 12 S*TICN 10.: TITLE: TECHNICAL SPECIFICATIONS 3T4.6 BASES ATTACHMENT 8 OF ADM-25.04 5 0f-10 REVS NNO.: 'CONTAINMENT SYSTEMS 9 ST. LUCIE UNIT 1 3/4.6 CONTAINMENT SYSTEMS (continued)

BASES (continued) 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS The OPERABILITY of the containment spray and cooling systems ensures that depressurization and cooling capability will be available to limit post-accident pressure and temperature in the containment to

>: acceptable values. During a Design Basis Accident (DBA), at least one

- containment cooling train and one containment spray train are capable of S-J maintaining the peak pressure and temperature within design limits. One

- < containment spray train has the capability, in conjunction with the Spray ac Additive System, to remove iodine fromthe containment atmosphere and w

0a- maintain concentrations belowthose assumed in the safety analyses. To E ensure that these conditions can be met considering single-failure criteria, Co C) two spray trains and two cooling trains must be OPERABLE.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months action interval specified inACTION 1.a and ACTION 1.d, and

- . the 7 day action interval specified inACTION 1.b take into account the

~. redundant heat removal capability and the iodine removal capability of the

~' remaining operable systems, and the low probability of a DBA occurring

during this period. The 10 day constraint for ACTIONS 1.a and 1.b is

sc based on coincident entry into two ACTION conditions (specified in 2,- ACTION 1.c) coupled with the low probability of an accident occurring o during thistime. Ifthe system(s) cannot be restored to OPERABLE status within the specified completion time, alternate actions are designed to bring the unit to a mode for which the LCO does not apply. The extended interval (54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months ) specified inACTION 1.a to be in MODE 4 includes 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of additional time for restoration of the inoperable CS train, and takes into consideration the reduced driving force for a release of radioactive material fromthe RCS when in MODE 3. With two containment spray trains or any combination of three or more containment spray and containment cooling trains inoperable in MODES 1, 2, or Mode 3 with Pressurizer Pressure >_1750 psia, the unit is in a condition outside the accident analyses and LCO 3.0.3 must be entered immediately. In MODE 3 with Pressurizer Pressure < 1750 psia, containment spray is not required.

The specifications and bases for LCO 3.6.2.1 are consistent with NUREG-1432, Revision 0 (9/28/92), Specification 3.6.6A (Containment Spray and Cooling Systems; Credit taken for iodine removal by the Containment Spray System), and the plant safety analyses.

L-2014-029 Attachment 4 Page 9 of 12 SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PACE:_ ,

3X4.6 BASES ATTACHMENT 8 OF ADM-25.04 6 oi1 EVISON MO.: CONTAINMENT SYSTEMS

- ST. LUCIE UNIT 1 14.6 CONTAINMENT SYSTEMS (continued)

UhSLS (continued)

P1/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS (continued) 3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS (continued)

Ensuring that the containment spray pump discharge pressure is met satisfies the periodic surveillance requirementto detect gross degradation caused by ,

impeller structural damage or other hydraulic component problems. Along with this requirement,Section XI of the ASME Code verifies the pump developed head at one point on the pump characteristic curve to verify both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greaterthan or equal to the performance assumed in the unit safety analysis. Surveillance Requirements are specified in the Inservice Testing Program, which encompasses Section Xl of the ASME Code.Section XI ofthe ASM E Code provjdes the activities and frequencies necessary to satisfy the requirements.

314.6.2.2 SPRAY ADDITIVE SYSTEM INSERT 3 (next page) I The OPERABILITY of the spray additive system ensures that sufficient NaOH is added to the containment spray in the event of a LOCA. The limits on NaOH volume and concentration ensure a containment sump pH value of between 7.0 and 9.66 for the solution recirculated within containment after a LOCA. This pH band minimizesthe evolution of iodine and minimizes the effect of chloride and caustic stress corrosion on mechanical systems and components. The contained water volume limit includes an allowance for water not usable because of tank discharge line location or other physical characteristics. These assumptions are consistent with the iodine removal efficiency assumed in the accident analyses.

3/4.6.2.3 DELETED 314.6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated fromthe outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment. Containment isolation within the time limits specified ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a LOCA.

L-2014-029 Attachment 4 Page 10 of 12 INSERT 3 Containment Spray System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the containment spray trains and may also prevent a water hammer and pump cavitation.

Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The Containment Spray System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria forthe location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety concerns. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31-day frequency for SR 4.6.2.1 .c takes into consideration the gradual nature of gas accumulation in the Containment Spray System piping and the procedural controls governing system operation.

TS Surveillance Requirement 4.6.2.1 .a is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be roceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. The individual will have a method to rapidly close the system vent path if directed.

L-2014-029 Attachment 4 Page 11 of 12 GSECTIO N NO.: TrTLE: TECHNI CAL SPECIF ICATIO NS AGEý..*:

3/4.9 BASES ATTACHMENT 11 OF ADM-25. 04 6 6, 6 REVLSION NO.: REFUELING OPERATIONS

--6-- ST. LUCIE UNIT 1 314.9 REFUELING OPERATIONS (continued)

BASES (continued) 3/4.9.5 COMMUNICATIONS The requirement for communications capability ensures that refueling station personnel can be promptly informed of significant changes inthe facility status or core reactivity condition during CORE ALTERATIONS.

3/4.9.6 MANIPULATOR CRANE OPERABILITY The OPERABIUTIY requirements of the cranes used for movement of fuel assemblies ensures that: 1) each crane has sufficient load capacity to lift a fuel element, and 2) the core internals and pressure vessel are protected from excessive lifting force inthe event they are inadvertently engaged during lifting operations.

314.9.7 DELETED 314.9.8 SHUTDO1VA COOLING AND COOLANT CIRCULATION The requirement that at least one shutdown cooling loop be in operation ensures that 1) sufficient cooling capacity is available to remove decay heat and maintain the water inthe reactor pressure vessel below 140PF as required during the REFUELING MODE, and 2) sufficient coolant circulation is maintained through the reactor core to minimize the effects of a boron dilution incident and prevent boron stratification.

'5 m C If SDC loop requirements are not met, there will be no forced circulation to o w provide mixing to establish uniform boron concentrations. Suspending oEa- positive reactivity additions that could result in failure to meet the minimum

._E c boron concentration limit is required to assure continued safe operation.

a) Introduction of coolant inventory must be from sources that have a boron 5 *. concentration greater than what would be required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in

=

~RCS boron concentration, but provides acceptable margin to maintaining 0o subcritical operations._,

0

-C

The requirement to have two shutdown cooling loops OPERABLE when

& 0

I = there is less than 23 feet of water above the irradiated fuel inthe core cr, - ensuresthat a single failure of the operating shutdown cooling loop will not M~ result in a complete loss of decay heat removal capability. With the reactor vessel head removed and 23 feet of water above the irradiated fuel in the core, a large heat sink is available for core cooling, thus in the event of a failure of the operating shutdown cooling loop, adequate time is provided to initiate emergency proceduresto cool the core.

JINSERT 4 (next page)

L-2014-029 Attachment 4 Page 12 of 12 INSERT 4 Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the Shutdown Cooling loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria lirTfts.

Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety concerns. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31-day frequency for ensuring locations are sufficiently filled with water takes into consideration the gradual nature of gas accumulation in the Shutdown Cooling System piping and the procedural controls governing system operation.

L-2014-029 Attachment 5 Page 1 of 8 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 5 St. Lucie Unit 2 Technical Specifications Changes Marked Up Pages 3/4 4-4 3/4 4-5 3/4 4-6 3/4 5-4 314 6-15a 3/4 9-8 3/4 9-9

L-2014-029 Attachment 5 Page 2 of 8 REACTOR COOLANT SYSTEM HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required Reactor Coolant pump(s), if not in operation, shall be determined to be OPERABLE once per 7 days by verifying correct breaker alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying the secondary side water level to be > 10% indicated narrow range level at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.3.3 At least one Reactor Coolant or shutdown cooling loop shall be verified to be in operation and circulating Reactor Coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.3.4 Verify required shutdown cooling trains locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.*

1*Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. I ST. LUCIE - UNIT 2 314 4-4 TAmendment No.

L-2014-029 Attachment 5 Page 3 of 8 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and in operation*, and either:

a. One additional shutdown cooling loop shall be OPERABLE, or

b. The secondary side water level of at least two steam generators shall be greater than 10% indicated narrow range level.

APPLICABILITY: MODE 5 with Reactor Coolant loops filled ACTION:

a. With one of the shutdown cooling loops inoperable and with less than the required steam generator level, immediately initiate corrective Z -action to return the inoperable shutdown cooling loop to OPERABLE

- status or to restore the required steam generator level as soon as possible.

UO)

M) CL*

u) b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than 0_ orequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 t6 Iand immediately initiate corrective action to return the required shutdown o a)* cooling loop to operation.

U)I SSURVEILLANCE REOUIREMENTS

' 4; 4.4.1.4.1.1 The secondary side water level of at least two steam generators when 0 "5 required shall be determined to be within limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

3 A 4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be in 0>'1 operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

.*' I

-0 0 The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided

1) no operations are permitted that would cause introduction into the RCS, coolant with C boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and 2) core outlet temperature is maintained at least 10°F below 0-c saturation temperature.

Ej One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for (I E surveillance testing provided the other shutdown cooling loop is OPERABLE 0 and in operation.

S## A Reactor Coolant pump shall not be started with two idle loops unless the secondary water temperature of each steam generator Is less than 4OWF above each of the Reactor Coolant System cold leg temperatures.

ST. LUCIE - UNIT 2 3/4 4-5 Amendment No. 46, 34,14, 422-

L-2014-029 Attachment 5 Page 4 of 8 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two shutdown cooling loops shall be OPERABLE# and at least one shutdown cooling loop shall be in operation.*

APPLICABILITY: MODE 5 with reactor coolant loops not filled.

ACTION:

a. With less than the above required loops OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required loops to OPERABLE status as soon as possible.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required shutdown cooling loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.2.1 Verify shutdown cooling trains locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other shutdown cooling loop is OPERABLE and in operation.

The shutdown cooling pump may be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided (1) no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and (2) core outlet temperature is maintained at least 101F below saturation temperature.

ST. LUCIE - UNIT 2 3/4 4-6 Amendment No. *'=,,----,,*

L-2014-029 Attachment 5 Page 5 of 8 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position

a. V3733 a. SIT VentValves a. Locked Closed V3734

b. V3735 b. SITVentValves b. Locked Closed V3736

c. V3737 c. SIT Vent Valves c. Locked Closed V3738 V3739 V3740

)tow b. At least once per 31 days by verifying that each valve (manual, power-operated or automatic) in the flow path that is not locked, Wi .2 sealed, or otherwise secured In position, Is in its correct positIon.*,

c. B.ha EGGS piping at L..__1 Zaccsible p -- s follow " ligc-e, shutdown cl orany " ich could cause

d. By a visual inspection which verifies that no loose debris (rags,

.Q W trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall

0. be performed:

.t U)-

1. For all accessible areas of the containment prior to

_ 0 establishing CONTAINMENT INTEGRITY, and

_ 1=

2. At least once daily of the areas affected within containment by the containment entry and during the final entry when CONTAINMENT INTEGRITY is established.

-14

e. At least once per 18 months by:

1. Verifying automatic isolation and interlock action of the shutdown cooling system from Reactor Coolant System when RCS pressure (actual or simulated) is greater than or equal to 515 psia, and that the interlocks prevent opening the shutdown cooling system isolation valves when RCS pressure (actual or simulated) is greater than or equal to 276 psia.

1*Not required to be met for system vent flow paths opened under administrative control.

ST. LUCIE - UNIT 2 3/4 5-4 Amendment No. -?-

L-2014-029 Attachment 5 Page 6 of 8 SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is positioned to take suction from the RWT on a Containment Pressure - -

High-High test signal.

b. By verifying that each spray pump develops the specified discharge pressure when tested pursuant to the Inservice Testing Program.

c. At least once per 18 months, during shutdown, by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal.

2. Verifying that upon a Recirculation Actuation Test Signal (RAS), the containment sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established.

d. At least once per 31 days, by verifying containment spray system locations susceptible to gas accumulation are sufficiently filled with water.

i Not required to be met for system vent flow paths opened under administrative control. I ST. LUCIE - UNIT 2 314 6-15a Amendment No.- 2, ", 48&-

L-2014-029 Attachment 5 Page 7 of 8 REFUELING OPERATIONS 314.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation.*

APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vessel flange is greater than or equal to 23 feet.

ACTION:

With no shutdown cooling loop OPERABLE and in operation, suspend all operations involving an increase in reactor decay heat load or operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3.9.1 and within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required shutdown cooling loop to OPERABLE and operating status as soon as possible. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SURVEILLANCE REQUIREMENTS 4.9.8.1 At least once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s:

a. At least one shutdown cooling loop shall be verified to be in operation

b. The total flow rate of reactor coolant to the reactor pressure vessel shall be verified to be greater than or equal to 3000 gpm.**

4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days The shutdown cooling loop may be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8-hour period during the performance of CORE ALTERATIONS in the vicinity of reactor pressure vessel hot legs, provided no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.9.1.

The reactor coolant flow rate requirement may be reduced to 1850 gpm if the following conditions are satisfied before the reduced requirement is implemented: the reactor has been determined to have been subcritical for at least 125 hours0.00145 days 0.0347 hours 2.066799e-4 weeks 4.75625e-5 months , the maximum RCS temperature is _<117 0 F, and the temperature of CCW to the shutdown cooling heat exchanger is < 870 F.

ST. LUCIE

UNIT 2 3/4 9-8 Amendment No. 76, 122

L-2014-029 Attachment 5 Page 8 of 8 REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and at least one shutdown cooling loop shall be in operation.-

APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vessel flange is less than 23 feet.

ACTION:

a. With less than the required shutdown cooling loops OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required loops to OPERABLE status, or to establish greater than or equal to 23 feet of water above the reactor pressure vessel flange, as soon as possible.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3.9.1 and within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required shutdown cooling loop to operation. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SURVEILLANCE REQUIREMENTS 4.9.8.2 At least once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s:

a. At least one shutdown cooling loop shall be verified to be in operation.

b. The total flow rate of reactor coolant to the reactor pressure vessel shall be verified to be greater than or equal to 3000 gpm.'

4.9.8.2.1 Verify shutdown cooling trains locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days The reactor coolant flow rate requirement may be reduced to 1850 gpm if the following conditions are satisfied before the reduced requirement is implemented: the reactor has been determined to have been subcritical for at least 125 hours0.00145 days 0.0347 hours 2.066799e-4 weeks 4.75625e-5 months , the maximum RCS temperature is < 11 7F, and the temperature of CCW to the shutdown cooling heat exchanger is < 87*F.

One required shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing, provided that the other shutdown cooling loop is OPERABLE and in operation.

ST. LUCIE - UNIT 2 3/4 9.9 Amendment No. 48, 0, 7-6, 422, 430,

-4118

Attachment 6 L-2014-029 Page 1 of 8 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 6 St. Lucie Unit 2 Technical Specifications Changes Retyped/Clean Pages 3/4 4-4 3/4 4-5 3/4 4-6 3/4 5-4 3/4 6-15a 3/4 9-8 3/4 9-9

Attachment 6 L-2014-029 Page 2 of 8 REACTOR COOLANT SYSTEM HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required Reactor Coolant pump(s), if not in operation, shall be determined to be OPERABLE once per 7 days by verifying correct breaker alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying the secondary side water level to be > 10% indicated narrow range level at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.3.3 At least one Reactor Coolant or shutdown cooling loop shall be verified to be in operation and circulating Reactor Coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.3.4 Verify required shutdown cooling trains locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.*

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

ST. LUCIE - UNIT 2 3/4 4-4 Amendment No.

Attachment 6 L-2014-029 Page 3 of 8 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and in operation*, and either:

a. One additional shutdown cooling loop shall be OPERABLE#, or

b. The secondary side water level of at least two steam generators shall be greater than 10% indicated narrow range level.

APPLICABILITY: MODE 5 with Reactor Coolant loops filled ACTION:

a. With one of the shutdown cooling loops inoperable and with less than the required steam generator level, immediately initiate corrective action to return the inoperable shutdown cooling loop to OPERABLE status or to restore the required steam generator level as soon as possible.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and immediately initiate corrective action to return the required shutdown cooling loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be determined to be within limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.1.3 Verify required shutdown cooling trains locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided

1) no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and 2) core outlet temperature is maintained at least 10F below saturation temperature.

One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other shutdown cooling loop is OPERABLE and in operation.

A Reactor Coolant pump shall not be started with two idle loops unless the secondary water temperature of each steam generator is less than 40PF above each of the Reactor Coolant System cold leg temperatures.

ST. LUCIE - UNIT 2 3/4 4-5 Amendment No. 46, 34,46,422

Attachment 6 L-2014-029 Page 4 of 8 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two shutdown cooling loops shall be OPERABLE# and at least one shutdown cooling loop shall be in operation.*

APPLICABILITY: MODE 5 with reactor coolant loops not filled.

ACTION:

a. With less than the above required loops OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required loops to OPERABLE status as soon as possible.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required shutdown cooling loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.1.4.2.1 Verify shutdown cooling trains locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other shutdown cooling loop is OPERABLE and in operation.

The shutdown cooling pump may be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided (1) no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and (2) core outlet temperature is maintained at least 10*F below saturation temperature.

ST. LUCIE - UNIT 2 3/4 4-6 Amendment No. 42-2

Attachment 6 L-2014-029 Page 5 of 8 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position

a. V3733 a. SITVent Valves a. Locked Closed V3734

b. V3735 b. SITVent Valves b. Locked Closed V3736

c. V3737 c. SITVentValves c. Locked Closed V3738 V3739 V3740

b. At least once per 31 days by verifying that each valve (manual, power-operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.*

c. At least once per 31 days, by verifying ECCS locations susceptible to gas accumulation are sufficiently filled with water.

d. By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

1. For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and

2. At least once daily of the areas affected within containment by the containment entry and during the final entry when CONTAINMENT INTEGRITY is established.

e. At least once per 18 months by:

1. Verifying automatic isolation and interlock action of the shutdown cooling system from Reactor Coolant System when RCS pressure (actual or simulated) is greater than or equal to 515 psia, and that the interlocks prevent opening the shutdown cooling system isolation valves when RCS pressure (actual or simulated) is greater than or equal to 276 psia.

Not required to be met for system vent flow paths opened under administrative control.

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

Attachment 6 L-2014-029 Page 6 of 8 SURVEILLANCE REQUIREMFNTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is positioned to take suction from the RWT on a Containment Pressure - -

High-High test signal.*

b. By verifying that each spray pump develops the specified discharge pressure when tested pursuant to the Inservice Testing Program.

c. At least once per 18 months, during shutdown, by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal.

2. Verifying that upon a Recirculation Actuation Test Signal (RAS), the containment sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established.

d. At least once per 31 days, by verifying containment spray system locations susceptible to gas accumulation are sufficiently filled with water.

Not required to be met for system vent flow paths opened under administrative control.

.ST. LUCIE - UNIT 2 3/4 6-15a Amendment No. 7-0,04,4

Attachment 6 L-2014-029 Page 7 of 8 REFUELING OPERATIONS 314.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation.*

APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vessel flange is greater than or equal to 23 feet.

ACTION:

With no shutdown cooling loop OPERABLE and in operation, suspend all operations involving an increase in reactor decay heat load or operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3.9.1 and within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required shutdown cooling loop to OPERABLE and operating status as soon as possible. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SURVEILLANCE REQUIREMENTS 4.9.8.1 At least once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s:

a. At least one shutdown cooling loop shall be verified to be in operation

b. The total flow rate of reactor coolant to the reactor pressure vessel shall be verified to be greater than or equal to 3000 gpm.**

4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

The shutdown cooling loop may be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8-hour period during the performance of CORE ALTERATIONS in the vicinity of reactor pressure vessel hot legs, provided no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.9.1.

The reactor coolant flow rate requirement may be reduced to 1850 gpm if the following conditions are satisfied before the reduced requirement is implemented: the reactor has been determined to have been subcritical for at least 125 hours0.00145 days 0.0347 hours 2.066799e-4 weeks 4.75625e-5 months , the maximum RCS temperature is < 11 7F, and the temperature of CCW to the shutdown cooling heat exchanger is < 87*F.

ST. LUCIE - UNIT 2 3/4 9-8 Amendment No. :76, 422

Attachment 6 L-2014-029 Page 8 of 8 REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and at least one shutdown cooling loop shall be in operation.-

APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vessel flange is less than 23 feet.

ACTION:

a. With less than the required shutdown cooling loops OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required loops to OPERABLE status, or to establish greater than or equal to 23 feet of water above the reactor pressure vessel flange, as soon as possible.

b. With no shutdown cooling loop in operation, suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3.9.1 and within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate corrective action to return the required shutdown cooling loop to operation. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SURVEILLANCE REQUIREMENTS 4.9.8.2 At least once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s:

a. At least one shutdown cooling loop shall be verified to be in operation.

b. The total flow rate of reactor coolant to the reactor pressure vessel shall be verified to be greater than or equal to 3000 gpm.*

4.9.8.2.1 Verify shutdown cooling trains locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

The reactor coolant flow rate requirement may be reduced to 1850 gpm ifthe following conditions are satisfied before the reduced requirement is implemented: the reactor has been determined to have been subcritical for at least 125 hours0.00145 days 0.0347 hours 2.066799e-4 weeks 4.75625e-5 months , the maximum RCS temperature is < 11 7F, and the temperature of CCW to the shutdown cooling heat exchanger is < 870F.

One required shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing, provided that the other shutdown cooling loop is OPERABLE and in operation.

ST. LUCIE - UNIT 2 3/4 9-9 Amendment No. 48, 40, 76, 4-22, 4-*,

4465

L-2014-029 Attachment 7 Page 1 of 13 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 7 St. Lucie Unit 2 Technical Specifications Bases Changes Marked Up Pages For Information Only

L-2014-029 Attachment 7 Page 2 of 13 NO.: P Pa&TPJN iE,1,: :

TECHNICAL SPECIFICATIONS RAFVGIN 314.4 NO.:

TrrLE:

BASES ATTACHM ENT 6 OF ADM-25.04 REACTOR COOLANT SYSTEM

(*3 of. 37,rf.

A

-- ST. LUCIE UNIT22 BASES FOR SECTION 3/4.4 K_.

3/4.4 REACTOR COOLANT SYSTEM 314.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION The plant is designed to operate with both reactor coolant loops and associated reactor coolant pumps inoperation, and maintain DNBR above the DNBR limit during all normal operations and anticipated transients. In MODES 1 and 2 with one reactor coolant loop not in operation, this specification requires that the plant be in at least HOT STANDBY within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

In MODE 3, a single reactor coolant loop provides sufficient heat removal capability for removing decay heat; however, single failure considerations require that two loops be OPERABLE.

In MODE 4, and in MODE 5 with reactor coolant loops filled, a single reactor H coolant loop or shutdown cooling loop provides sufficient heat removal Li

capability for removing decay heat; but single failure considerations require

'E M that at least two loops (either shutdown cooling or RCS) be OPERABLE

-. a In MODE 5 with reactor coolant loops not filled, a single shutdown cooling

.E o loop provides sufficient heat removal capability for removing decay heat; but

.s2 CDE single failure considerations and the unavailability or the steam generators as Z5 a heat removing component, require that at least two shutdown cooling loops

> I be OPERABLE 7

-E The operation of one reactor coolant pump or one shutdown cooling pump

, provides adequate flow to ensure mixing, prevent stratification and produce 2 ~gradual reactivity changes during boron concentration reductions in the

0 Reactor Coolant System. The reactivity change rate associated with boron M - reductions will, therefore, be within the capability of operator recognition and

- control.

If no coolant loops are in operation during shutdown operations, suspending the introduction of coolant into the RCS with boron concentration less than required to meet the minimum SDM of LCO 3.1.1.1 or 3.1.1.2 is required to assure continued safe operation. Introduction of coolant inventory must be from sourcesthat have a boron concentration greaterthan what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

L-2014-029 Attachment 7 Page 3 of 13 SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PXOE,;,

3f4.4 BASES ATTACHMENT 6 OF ADM-25.04 7 '. .

LEVSIONO.: REACTOR COOLA NT SYSTEM 9 ST. LUCIE UNIT 2 314.4 REACTOR COOLANT SYSTEM (continued)

BASES (continued) 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION (continued)

The restriction on starting a reactor coolant pump inMODES 4 and 5, with two idle loops and one or more RCS cold leg temperatures lessthan or equal to that specified in Table 3.4-3 is provided to prevent RCS pressure transients, caused by energy additions from the secondary system from exceeding the limits of Appendix 0 to 10 CFR 50. The RCS will be protected against overpressure transients by (1) sizing each PORV to mitigate the pressure transient of an inadvertent safety injection actuation in a water-solid RCS with pressurizer heaters energized, (2) restricting starting of the RCPs to when the secondary water temperature of each steam generator is less than 40?F above each of the RCS cold leg temperatures, (3) using SDCRVs to mitigate RCP start transients and the transients caused by inadvertent SIAS actuation and charging water, and (4) rendering one HPSI pump inoperable when the RCS is at low temperatures.

314.4.2 SAFETY1VALVES Insert 1 (next page)

The pressurizer code safety valves operate to prevent the RCS from being pressurized above its Safety Limit of 2750 psia. Each safety valve is designed to relieve 212,182 lbs per hour of saturated steam atthe valve setpoint. The relief capacity of a single safety valve is adequate to relieve any overpressure condition which could occur during shutdown. In the event that no safety valves are OPERABLE, an operating shutdown cooling loop, connected to the RCS, provides overpressure relief capability and will prevent RCS overpressurization. In addition, the Overpressure Protection System provides a diverse means of protection against RCS overpressurization at low temperatures.

During operation, all pressurizer code safety valves must be OPERABLE to prevent the RCS from being pressurized above its safety limit of 2750 psia.

The combined relief capacity of these valves is sufficient to limit the system pressure to within its Safety Limit of 2750 psia following a complete loss of turbine generator load while operating at RATED THERMAL POWER and assuming no reactortrip until the first Reactor Protective System trip setpoint (Pressurizer Pressure-High) is reached (i.e., no credit is taken for a direct reactortrip on the loss of turbine) and also assuming no operation of the pressurizer power-operated relief valve or steam dump valves.

L-2014-029 Attachment 7 Page 4 of 13 iisERT1 Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required shutdown cooling loops and may also prevent water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel.

Selection of Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety concerns. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

SR 4.4.1.3.4 is modified by a Note that states the Surveillance Requirement is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

The 31 -day frequency for ensuring locations are sufficiently filled with water takes into consideration the gradual nature of gas accumulation in the SDC System piping and the procedural controls governing system operation.

L-2014-029 Attachment 7 Page 5 of 13 SBC:TIN NO.: TrTLE: TECHNICAL SPECIFICATIONS .....

314.5 BASES ATTACHMENT 7 OF ADM-25.04 A REV ISIONNO.: EMERGENCY CORE COOLING SYSTEMS (ECCS) -- of7)-.

ST. LUCIE UNIT 2 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued) '7777, BASES (continued) 314.5.2 and 34.&5.3 EC CS SUBSYSTEMS The OPERABIUTY of two separate and independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available in the event of a LOCA assuming the loss of one subsystem through any single failure consideration. Either subsystem operating in conjunction with the safety injection tanks is capable of supplying sufficient core cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double-ended break of the largest RCS hot leg pipe downward. In addition, each ECCS subsystem provides long-term core cooling capability in the recirculation mode during the accident recovery .perinri-TS 3.5.2. c and 3.5.3 require that ECCS subsysterr(s) have an independent o OPERABLE flow path capable of automatically transferring suction to the containment on a Recirculation Actuation Signal. The containment sump is defined as the area of containment below the minimum flood level inthe o >_ vicinity of the containment sump strainers. Therefore, the LCOs are satisfied

.----q when an independent OPERABLE flow path to the containment sump strainer

-- mn is available.

>I TS 3.5.2.d requiresthat an ECCS subsystem(s) have an OPERABLE c0 charging pump and associated flow path from the BAMT(s). Reference toTS 3.1.2.2 requires that the one charging pump flow path is from the BAMT(s) týD- through the boric acid makeup pump(s). The second charging pump flowpath 2 iP isfromthe BAMT(s)through the gravity feed valves.

C._o C'; TS 3.5.2, ACTION a.l. provides an allowed outage/action completion time (AOT) of up to 7 days from initial discovery of failure to meet the LCO provided the affected ECCS subsystem is inoperable only because its associated LPSI train is inoperable. This 7 day AOT is based on the findings of a deterministic and probabilistic safety analysis and is referred to as a "risk-informed"AOT extension. Entry into this ACTION requires that a risk assessment be performed inaccordance with the Configuration Risk Management Program (CRMP) which is described inthe Administrative Procedure (ADM-1 7.08) that implements the Maintenance Rule pursuantto 10 CFR 50.65.

In Mode 3 with RCS pressure < 1750 psia and inMode 4, one OPERABLE ECCS subsystem is acceptable without single failure consideration on the basis ofthe stable reactivity condition of the reactor and the limited core cooling requirements.

L-2014-029 Attachment 7 Page 6 of 13 TrrLE: TECHNICAL SPECIFICATIONS .A - ,

T 4.5 BASES ATTACHMENT 7 OF ADM-25.04 .

REV IONND.: EMERGENCY CORE COOLING SYSTEMS (ECCS) Li of 7

--2--- ST. LUCIE UNIT 2 314.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued)

BASES (continued) 314.5.2 and 3f4.5.3 ECCS SUBSYSTEMS (continued)

S eriodic surveillance testing ofECCS pumpsto detect gross degradation caused by impeller structural damage or other hydraulic component problems 2is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at only one point on C the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline H performance and thatthe performance at the test flow is greaterthan or equal uJ to the performance assumed in the unit safety analysis. Surveillance Z Requirements are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements.

Refer to UFSAR for flow balancing requirements The practice of calibrating and testing the SDC isolation valve interlock function below 515 psia (the current plant practice is to set and test the interlock function at 500 psia) meets the requirements of Technical Specification Surveillance 4.5.2.e.1. The staff accepted that testing the SDC isolation interlock at a more conservative setpoint demonstrates operability at and above the setpoint (NRC letter from William C. G leaves to J.A. Stall dated November 2, 1999, subject"St. Lucie Unit 2-Amendment Request Regarding Safety Injection Tank and Shutdown Cooling System Isolation Interlock Surveillances (TAC No. MA561 9).

<- INSERT 3 (next page) 314.5.4 REFUELING WATER TANK The OPERABILITY of the Refueling Water Tank (RW-T) as part ofthe ECCS ensuresthat a sufficient supply of borated water is available for injection by the ECCS inthe event of a LOCA. The limits on RVVT minimum volume and boron concentration ensure that (1) sufficient water is available within containment to permit recirculation cooling flow to the core, and (2) the reactor will remain subcritical in the cold condition following mixing of the RWT and the RCS water volumes with all control rods inserted except for the most reactive control assembly. These assumptions are consistent with the LOCA analyses.

The contained water volume limit includes an allowance forwater not usable because of tank discharge line location or other physical characteristics.

L-2014-029 Attachment 7 Page 7 of 13 INSERT 2 TS Surveillance Requirement 4.5.2.b is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. The individual will have a method to rapidly close the system vent path if directed.

INSERT 3 ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety concerns. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls governing system operation.

L-2014-029 Attachment 7 Page 8 of 13 38mTIDN NO.: PA :l TrrLE: TECHNICAL SPECIFICATIONS ,',<

3/4.6 BASES ATTACHMENT 8 OF ADM-25.04 6 of 11V REVWSN N.: CONTAINMENT SYSTEMS of t11 ST. LUCIE UNIT 2 314.6 CONTAINMENT SYSTEMS (continued) -

BALLE (continued) 314.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 314.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS The OPERABILITY of the containment spray and cooling systems ensures that depressurization and cooling capability will be available to limit post-accident pressure and temperature inthe containment to acceptable values:

During a Design Basis Accident (DBA), at least one containment cooling train and one containment spray train are capable of maintaining the peak pressure and temperature within design limits. One containment spray train has the capability, in conjunction with the Iodine Removal System, to remove iodine 2

oJ from the containment atmosphere and maintain concentrations below those M assumed in the safety analyses. To ensure thatthese conditions can be met considering single-failure criteria, two spray trains and two cooling trains must a- be OPERABLE.--

E The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months action interval specified in ACTION l.a and ACTION 1.d, and the ID 7 day action interval specified in ACTION 1.b take into account the redundant heat removal capability and the iodine removal capability of the remaining operable systems, and the low probability of a DBA occurring during this period. The 10 day constraint forACTIONS 1.a and 1.b is based on coincident entry into two ACTION conditions (specified in ACTION 1.c) coupled with the low probability of an accident occurring during this time. If the system(s) cannot be restored to OPERABLE status within the specified completion time, alternate actions are designed to bring the unitto a mode for which the LCO does not apply. The extended interval (54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months ) specified inACTION 1.a to be in MODE 4 includes 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of additional time for restoration of the inoperable CS train, and takes into consideration the reduced driving force for a release of radioactive material fromthe RCS when in MODE 3. With two containment spray trains or any combination of three or more containment spray and containment cooling trains inoperable in MODES 1, 2, or Mode 3 with Pressurizer Pressure > 1750 psia, the unit is in a condition outside the accident analyses and LCO 3.0.3 must be entered immediately. In MODE 3 with Pressurizer Pressure < 1750 psia, containment spray is not required.

The specifications and bases for LCO 3.6.2.1 are consistent with NUREG-1432, Revision 0 (9128/92), Specification 3.6.6A (Containment Spray and Cooling Systems; Credit taken from iodine removal by the Containment Spray System), and the plant safety analyses.

L-2014-029 Attachment 7 Page 9 of 13 mBTIJN NO.: PG~;

TrrLE: TECHNICAL SPECIFICATIONS PAGE _ 'r 3T4.6 BASES ATTACHMENT 8 OF ADM-25.04 NEISDN IO.: CONTAINMENT SYSTEMS - l*:

11 ST. LUCIE UNIT 2 314.6 CONTAINMENT SYSTEMS (continued) ;47.

BASES (continued) 14.6.2 DEPRESSURIZATION AND COOLING SYSTEMS (continued)

W4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS (continued)

Ensuring thatthe containment spray pump discharge pressure is met satisfies the periodic surveillance requirement to detect gross degradation caused by impeller structural damage or other hydraulic component problems. Along with this requirement,Section XI of the ASME Code verifies the pump developed head at one point on the pump characteristic curve to verify both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis. Surveillance Requirements are specified inthe Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements.

34.6.2.2 IODINE REMOVAL SYSTEM INSERT 4 (next page)

The OPERABILITY of the Iodine Removal System ensuresthat sufficient N2Ht is added to the containment spray inthe event of a LOCA. The limits on N2H4 volume and concentration ensure a minimum of 50 ppm of N2H4 concentration available in the spray for a minimum of 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months per pump for a total of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months to provide assumed iodine decontamination factors on the containment atmosphere during spray function and ensure a pH value of between 7.0 and 8.1 for the solution recirculated within containment after a LOCA. This pH band minimizes the evolution of iodine and minirrizes the effect of chloride and caustic stress corrosion on mechanical systems and components. The contained watervolume limit includes an allowance forwater not usable because of tank discharge line location or other physical characteristics.

These assumptions are consistent with the iodine removal efficiency assumed in the safety analyses.

334.6.2.3 DELETED 34.6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensuresthat the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment and is consistent with the requirements of GDC 54 through GDC 57 ofAppendixA to 10 CFR Part 50. Containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used inthe analysesfor a LOCA.

L-2014-029 Attachment 7 Page 10 of 13 INSERT 4 Containment Spray System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the containment spray trains and may also prevent a water hammer and pump cavitation.

Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The Containment Spray System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety concerns. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31-day frequency for SR 4.6.2.1 .d takes into consideration the gradual nature of gas accumulation in the Containment Spray System piping and the procedural controls governing system operation.

TS Surveillance Requirement 4.6.2.1 .a is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. The individual will have a method to rapidly close the system vent path if directed.

L-2014-029 Attachment 7 Page 11 of 13 SECTION NO.: TITLE TECHNICAL SPECIFICATIONS PAGE:

314.9 BASES ATTACHMENT 11 OF ADM-25.04 6 of 8 REVISION NO.: REFUELING OPERATIONS

- ST. LUCIE UNIT 2 3/4.9 REFUELING OPERATIONS (continued)

BASES (continued) 314.9.6 MANIPULATOR CRANE The OPERABILITY requirements for the refueling machine ensures that:

(1) manipulator cranes will be used for movement of fuel assemblies, with or without CEAs, (2) each crane has sufficient load capacity to lift a fuel assembly, with or without CEAs, and (3) the core internals and pressure vessel are protected from excessive lifting force in the event they are inadvertently engaged during lifting operations.

3/4.9.7 DELETED 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION The requirement that at least one shutdown cooling loop be in operation ensures that (1) sufficient cooling capacity is available to remove decay heat and maintain the water in the reactor pressure vessel below 140OF as required during the REFUELING MODE, and (2) sufficient coolant circulation is maintained through the reactor core to minimize the effects of a boron dilution incident and prevent boron stratification.

If SDC loop requirements are not met, there will be no forced circulation to provide mixing to establish uniform boron concentrations. Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration. but provides acceptable margin to maintaining subcritical operations.

sManaging of gas voidsIs important to shutdown cooling Isystem OPERABILITY.

L-2014-029 Attachment 7 Page 12 of 13 SECTION NO.: TITLEE TECHNICAL SPECIFICATIONS PAGE:

3/4.9 BASES ATTACHMENT 11 OF ADM-25.04 7 of 8 REVISION NO.: REFUELING OPERATIONS

-,4--- ST. LUCIE UNIT 2 3/4.9 REFUELING OPERATIONS (continued)

BASES (continued) 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION (continued)

The requirement to have two shutdown cooling loops OPERABLE when there is less than 23 feet of water above the reactor pressure vessel flange with irradiated fuel in the core ensures that a single failure of the operating shutdown cooling loop will not result in a complete loss of decay heat removal capability. With the reactor vessel head removed and 23 feet of water above the reactor pressure vessel flange with irradiated fuel in the core, a large heat sink is available for core cooling, thus in the event of a failure of the operating shutdown cooling loop, adequate time is provided to initiate emergency procedures to cool the core.

The footnote providing for a minimum reactor coolant flow rate of

>_1850 gpm considers one of the two RCS injection points for a SDCS train to be isolated. The specified parameters include 50 gpm for flow measurement uncertainty, and 30F uncertainty for RCS and CCW temperature measurements. The conditions of minimum shutdown time, maximum RCS temperature, and maximum temperature of CCWto the shutdown cooling heat exchanger are initial conditions specified to assure that a reduction in flow rate from 3000 gpm to 1800 gpm will not result in a temperature transient exceeding 140OF during conditions when the RCS water level is at an elevation > 29.5 feet.

E f*INSERT 5 (next page) 1 3/4.9.9 CONTAINMENT ISOLATION SYSTEM The OPERABILITY of this system ensures that the containment isolation valves will be automatically isolated upon detection of high radiation levels within the containment. The OPERABILITY of this system is required to restrict the release of radioactive material resulting from a fuel handling accident of a recently irradiated fuel assembly from the containment atmosphere to the environment. Recently irradiated fuel is defined as fuel that has occupied parts of a critical reactor core within the previous 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

L-2014-029 Attachment 7 Page 13 of 13 INSERT 5 Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the Shutdown Cooling loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety concerns. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 -day frequency for ensuring locations are sufficiently filled with water takes into consideration the gradual nature of gas accumulation in the Shutdown Cooling System piping and the procedural controls governing system operation.