L-2014-082, License Amendment Request, Application for Technical Specification Change Regarding Elimination of Second Completion Times Limiting Time from Discovery of Failure to Meet a Limiting Condition for Operation

License Amendment Request, Application for Technical Specification Change Regarding Elimination of Second Completion Times Limiting Time from Discovery of Failure to Meet a Limiting Condition for Operation

ML14351A074
Person / Time
Site:	Saint Lucie
Issue date:	12/05/2014
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-082
Download: ML14351A074 (24)

Text

0 December 5, 2014 L-2014-082 FPL. 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 License Nos. DPR-67 and NPF-16 License Amendment Request, Application for Technical Specification Change Regarding Elimination of Second Completion Times Limiting Time From Discovery of Failure to Meet a Limiting Condition for Operation Pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests to amend renewed Facility Operating Licenses DPR-67 and NPF-16 to St. Lucie Nuclear Plant (St.

Lucie) Units 1 and 2, respectively. The proposed amendment would modify the St. Lucie Technical Specifications (TS) by eliminating second completion times limiting time from discovery of failure to meet a limiting condition for operation (LCO).

The changes are consistent with NRC-approved Technical Specifications Task Force (TSTF)

Traveler TSTF-439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO," (Adams Accession No. ML051860296).

Attachment 1 provides an evaluation of the proposed changes and the No Significant Hazards Consideration Determination. Attachment 2 provides the existing St. Lucie Unit 1 TS pages marked-up to show the proposed changes, and Attachment 3 provides the proposed St. Lucie Unit 1 TS Bases changes. The changes to the TS Bases are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment. Attachment 4 contains the clean St. Lucie Unit 1 TS pages.

Attachment 5 provides the existing St. Lucie Unit 2 TS pages marked-up to show the proposed changes, and Attachment 6 provides the proposed St. Lucie Unit 2 TS Bases changes. The changes to the TS Bases are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment. Attachment 7 contains the clean St. Lucie Unit 2 TS pages.

Please process these changes within in one year of receipt and once approved, the amendments will be implemented within 90 days. This letter contains no new commitments and no revisions to existing commitments.

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

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

L-2014-082 Page 2 Pursuant 10 CFR 50.91 (b)(1), a copy of this letter i3 being forwarded to the State of Florida designee.

Should you have any questions regarding this submittal, please contact Mr. Eric Katzman, Licensing Manager, at (772) 467-7734.

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

Executed on Stl day of 'eOew.I6ef, 2014.

Very truly yours, Sit V. resident St. Lucie Nuclear Plant Attachments:

1. Evaluation of Proposed Change

2. St. Lucie Unit 1 Technical Specifications Marked-Up Page

3. St. Lucie Unit 1 Technical Specifications Bases Marked-Up Page (for information only)

4. St. Lucie Unit 1 Technical Specifications Clean Page

5. St. Lucie Unit 2 Technical Specifications Marked-Up Page

6. St. Lucie Unit 2 Technical Specifications Bases Marked-Up Page (for information only)

7. St. Lucie Unit 2 Technical Specifications Clean Page cc: USNRC Administrator, Region II USNRC Project Manager, St. Lucie Nuclear Piant USNRC Resident Inspector, St. Lucie Nuclear Plant Ms. Cindy Becker, Florida Department of Health

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 1 License Amendment Request Page 1 of 8 Attachment 1 Florida Power & Light Company St Lucie Nuclear Plant Units 1 and 2 License Amendment Request Evaluation of Proposed Change

Subject:

Application for Technical Specification Change Request Regarding Eliminating Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusion

6.0 REFERENCES

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 1 License Amendment Request Page 2 of 8 1.0 SMMARY DESCRIPTION NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants"

[Reference 2], included a second Completion Time for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the LCO. These Completion Times (henceforth referred to as "second Completion Times") are joined by an "AND" logical connector to the Condition -specific Completion Time and state "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second Completion Time was to preclude entry into and out of the Actions for an indefinite period of time without meeting the LCO by providing a limit on the amount of time that the LCO could not be met for various combinations of Conditions.

Technical Specifications Task Force (TSTF) Traveler -439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO,"

(Adams Accession No. ML051860296) [Reference 1] deletes these second Completion Times from the affected Required Actions. It also revises the Standard Technical Specifications (STS) Section 1.3 Completion Times, Example 1.3-3 to remove the second Completion Times and to revise the discussion in that Example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the basis of the Completion Times and is inappropriate. Therefore, the licensee shall have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO.

These administrative controls shall ensure that the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO is not inappropriately extended.

NRC letter to the TSTF, "Status of TSTF-439, 'Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO,"' January 11, 2006 (Adams Accession No. ML060120272) [Reference 3] stated that TSTF-439 had been incorporated into the STS, Revision 3.1.

2.0 DETAILED DESCRIPTION St. Lucie Nuclear Plant (St. Lucie) Units 1 and 2 have separate Technical Specifications (TS). The changes described through this application are applicable to both units' TS unless otherwise noted.

St. Lucie Units 1 and 2 have not adopted the NUREG-1432 STS. Completion Times referenced in the STS are designated as Actions in the St. Lucie TS. Florida Power &

Light Company (FPL) is proposing the following changes to the St. Lucie Units 1 and 2 TS:

• TS 3.6.2.1, "Containment Spray and Cooling Systems," Actions l.a. and 1.b. are revised to delete "and within 10 days from initial discovery of failure to meet the LCO," such that they read:

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 1 License Amendment Request Page 3 of 8

a. With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.

b. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

St. Lucie Units 1 and 2 TS do not contain a Use and Application Section, nor do they contain second Actions for the other TS identified in TSTF-439. Accordingly, there are no other changes associated with implementation of this TSTF.

The TS Bases associated with these required Actions are also being revised to delete the discussion of the second Completion Time. This information will be replaced with a discussion that is similar to and reflects the intent of the guidance that is provided in TSTF-439 relative to proper TS Action entry when the LCO is not met:

It is possible to alternate between Technical Specification Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis for Completion Times. Therefore, the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO shall be limited. The Completion Times for those Conditions shall not be inappropriately extended.

Changes to the TS Bases are provided for information only and will be incorporated in accordance with the TS Bases Control Program In addition, as an administrative control, FPL will revise OP-AA-1 00-1000, "Conduct of Operations," accordingly. OP-AA-100-1000 provides guidance for documenting entry into TS Actions when an applicable LCO is not met.

The Unit 1 and Unit 2 TS Bases and OP-AA-100-1000 will be revised prior to implementation of the approved amendments.

Optional Changes and Variations FPL is proposing the following variations from the TS changes described in TSTF-439:

1. St. Lucie Units 1 and 2 TS have not adopted the STS. Completion Times referenced in the STS are designated as Action times in the St. Lucie TS.

2. TS 3.6.2.1, "Containment Spray and Cooling Systems," is the only St. Lucie TS that contains a second Action time. Accordingly, this is the only TS that is being revised.

3. St. Lucie Units 1 and 2 TS do not contain a Use and Application section.

Accordingly, there are no other changes associated with implementation of this TSTF.

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 1 License Amendment Request Page 4 of 8

3.0 TECHNICAL EVALUATION

As discussed in TSTF-439, Revision 2, the adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternatively meeting the requirements of separate Conditions. In 1991, the NRC could not identify any regulatory requirement or program which could prevent this misuse of the TS. However, that is no longer the case. There are now two programs which would provide a strong disincentive to continued operation with concurrent muitiple inoperabilities of the type the second Completion Times were designed to prevent.

Maintenance Rule 10 CFR 50.65(a)(1), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," (Maintenance Rule) [Reference 4] requires each licensee to monitor the performance or condition of systems, structures, and components (SSCs) against licensee established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of the SSC does not meet established goals, appropriate corrective action is required to be taken. The NRC resident inspectors monitor the licensee's Corrective Action Program and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65(a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the Actions of the TS and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective Actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65(a)(3).

Under the TS, the Completion Time for one system is not affected by other inoperable equipment. The second Completion Times were an attempt to influence the Completion Time for one system based on the condition of another system, iftwo systems were required by the same LCO. However, 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just one or two systems governed by the same LCO.

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance.

NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," [Reference 5] provides general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management Actions, and example risk management Actions. These include Actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, Actions to reduce the duration of the condition, Actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable. The comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the TS.

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 1 License Amendment Request Page 5 of 8 Reactor Oversight Process Reactor Oversight Process, NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," [Reference 6] describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP). The NEI document is endorsed by NRC Regulatory Issue Summary (RIS) 2001-11, "Voluntary Submission of Performance Indicator Data" [Reference 7]. NEI 99-02, Section 2.2 describes the Mitigating Systems Cornerstone.

In addition to these programs, there is an existing action in the action tracking system for revision of OP-AA-100-1000, "Conduct of Operations," to add a discussion of the proper use of Action times to preclude alternating between Actions to continue operation indefinitely while not meeting the LCO.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, "Technical Specifications." 10 CFR 50.36(c)(2) states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." The revised Actions continue to meet the requirements of this regulation.

10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.

4.2 Precedent TSTF-439, Revision 2 was approved for use as described in the following letters:

1. Letter from J. D. Hughley (NRC) to M. J. Pacilio (Exelon Nuclear), "Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments Re: Adoption of Technical Specification Task Force (TSTF) Traveler 439, Revision 2, 'Eliminate Second Completion Times Limiting Time From Discovery to Failure to Meet an LCO (Limiting Condition for Operation),' (TAC NOS. MD9449 AND MD9450),"

July 30, 2010 (Adams Accession No. ML101940378) [Reference 8].

2. R.E. Martin (NRC) letter to C.R. Pierce (Southern Nuclear Operating Co. Inc.),

"Vogtle Electric Generating Plant, Units 1 and 2, Issuance of Amendments Regarding Adoption of TSTF-439, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO," (TAC Nos. ME9470 and ME9471 April 24, 2013 (Adams Accession No. ML13057A309) [Reference 9].

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 1 License Amendment Request Page 6 of 8 4.3 No Significant Hazards Consideration Description of Amendment Request The proposed changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO" (Adams Accession No. ML051860296). The proposed amendment would modify the St. Lucie Units 1 and 2 Technical Specifications (TS) by eliminating second completion times limiting time from discovery of failure to meet a limiting condition for operation (LCO) for TS 3.6.2.1, "Containment Spray and Cooling Systems."

Basis for proposed no significant hazards consideration:

Florida Power & Light Company (FPL) has reviewed the proposed no significant hazards consideration (NSHC) determination contained in TSTF-439, Revision 2 and has determined the NSHC in TSTF-439 is applicable to St. Lucie Units 1 and 2. The NSHC is provided below which satisfies the requirements of 10 CFR 50.91(a).

As required by 10 CFR 50.91(a), the FPL analysis of the issue of no significant hazards consideration is presented below:

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

Response: No The proposed change that incorporated TSTF-439, Revision 2, eliminates certain Completion Times from the TS. Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised Completion Times are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed change does not alter or prevent the ability of structures, systems, or components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed change is consistent with the safety analysis assumptions and resultant consequences. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of any accident previously evaluated.

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 1 License Amendment Request Page 7 of 8

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

Response: No The proposed change does not involved 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. The proposed change does not alter any assumptions made in the safety analysis.

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 the margin of safety?

Response: No The proposed change to delete the second Completion Times does not alter the manner in which safety limits, limiting safety system settings, or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change. The proposed change will not result in plant operation in a configuration outside the design basis.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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" is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commmission's regulations, and (3) the issuance of an amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

FPL has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment 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 to be prepared in connection with the proposed amendment.

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 1 License Amendment Request Page 8 of 8

6.0 REFERENCES

1. Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Traveler TSTF-439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO" (Adams Accession No. ML051860296).

2. NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants,"

April 2012.

3. T. H. Boyce (NRC) letter to the Technical Specification Task Force, "Status of TSTF-439, 'Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO,"' dated January 11, 2006 (Adams Accession No. ML060120272).

4. 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

5. NUMARC 93-01, "Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," April 2011.

6. NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," October 2009.

7. NRC Regulatory Issue Summary (RIS) 2001-11, "Voluntary Submission of Performance Indicator Data," dated May 11, 2001.

8. Letter from J. D. Hughley (NRC) to M. J. Pacilio (Exelon Nuclear), "Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments Re: Adoption of Technical Specification Task Force (TSTF) Traveler 439, Revision 2, 'Eliminate Second Completion Times Limiting Time From Discovery to Failure to Meet an LCO (Limiting Condition for Operation)' (TAC NOS. MD9449 AND MD9450)," dated July 30, 2010 (Adams Accession No. ML101940378).

9. R.E. Martin (NRC) letter to C.R. Pierce (Southern Nuclear Operating Co. Inc.),

"Vogtle Electric Generating Plant, Units 1 and 2, Issuance of Amendments Regarding Adoption of TSTF-439, 'Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO' (TAC Nos. ME9470 and ME9471),"

dated April 24, 2013 (Adams Accession No. ML13057A309).

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 2 License Amendment Request Page 1 of 2 Attachment 2 Florida Power & Light Company St. Lucie Unit 1 License Amendment Request Technical Specifications Marked-Up Page

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 2 License Amendment Request Page 2 of 2 CONTAINMENT SYSTEMS 314.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY AND COOLING SYSTEMS A' LIMITING CONDITION FOR OPERATION 3.6.2.1 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: Containment Spray System: MODES 1, 2, and MODE 3 with Pressurizer Pressure > 1750 psia.

Containment Cooling System: MODES 1, 2, and 3.

ACTION:

1. Modes 1, 2, and 3 with Pressurizer Pressure > 1750 psia:

a. With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s-and withi,.n10 ds fFem inflal-diseevery-faikrc toc,,,,,,,t the LCO; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.

b. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days-and-within days from initial dis..v.r. of failu.. to meet the LC; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c. With one containment spray train and one containment cooling train inoperable, concurrently implement ACTIONS a. and b. The completion intervals for ACTION a. and ACTION b. shall be tracked separately for each train sterting from the time each train was discovered inoperable.

d. With two containment cooling trains inoperable, restore one cooling train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise+be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

e. With two containment spray trains inoperable or any combination of three or more trains inoperable, enter LCO 3.0.3. immediately.

2. Mode 3 with Pressurizer Pressure < 1750 psia:

a. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise+be in MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With two containment cooling trains inoperable, enter LCO 3.0.3 immediately.

A' ST. LUCIE - UNIT 1 3/4 6-15 Amendment No. 90, 4-34

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 3 License Amendment Request Page 1 of 3 Attachment 3 Florida Power & Light Company St. Lucie Unit 1 License Amendment Request Technical Specifications Bases Marked-Up Page For Information Only

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 3 License Amendment Request Page 2 of 3 INSERT 1 It is possible to alternate between Actions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO; however, doing so would be inconsistent with the basis for the Action Time. Alternating between Actions in order to continue operation indefinitely while not meeting the LCO is not allowed.

St. Lucie Units 1 and 2 L-2014-082 1O30 *'¢-lbaars'.' SIR' -'q ...

TITLE: TECHNICAL SPECIFICATIONS "'....- T~

age-3of 3 3/4.6 BASES ATTACHMENT 8 OF ADM-25.04 5 of 10 REVISION NO.: CONTAINMENT SYSTEMS 9 ST. LUCIE UNIT 1 314.6 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 maintaining the peak pressure and temperature within design limits. One containment spray train has the capability, in conjunction with the Spray Additive System, to remove iodine from the containment atmosphere and maintain concentrations below those assumed in the safety analyses. To ensure that these conditions can be met considering single-failure criteria, two spray trains and two cooling trains must be OPERABLE.

The 72-hour action interval specified in ACTION l.a and ACTION 1.d, and the 7-day action interval specified in ACTION 1.b take into account the redundant heat removal capability and the iodine removal capability of the INSERT 1 remaining operable systems, and the low probability of a DBA occurring during this periodThe .. 10 day o.t.aint for ACT.IONS l.a and 1.b is-

^A~c on --oincidnt entrcy into two ACTION conditions (spccified in AGTQnK A c^,c-41c

-.. witkth low probability of an.cict curn

,-- h-,,,,i,,,,-.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 <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />) specified in ACTION l.a to be in MODE 4 includes 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of additional time for restoration of the inoperable CS train, and takes into consideration the reduced driving force for a release of radioactive material from the 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.

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 4 License Amendment Request Page 1 of 2 Attachment 4 Florida Power & Light Company St. Lucie Unit 1 License Amendment Request Technical Specifications Clean Page

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 4 License Amendment Request Page 2 of 2 CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY AND COOLING SYSTEMS LIMITING CONDITION FOR OPERATION 3.6.2.1 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: Containment Spray System: MODES 1, 2, and MODE 3 with Pressurizer Pressure > 1750 psia.

Containment Cooling System: MODES 1, 2, and 3.

ACTION:

1. Modes 1, 2. and 3 with Pressurizer Pressure Ž> 1750 psia:

a. With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.

b. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c. With one containment spray train and one containment cooling train inoperable, concurrently implement ACTIONS a. and b. The completion intervals for ACTION a. and ACTION b. shall be tracked separately for each train starting from the time each train was discovered inoperable.

d. With two containment cooling trains inoperable, restore one cooling train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

e. With two containment spray trains inoperable or any combination of three or more trains inoperable, enter LCO 3.0.3. immediately.

2. Mode 3 with Pressurizer Pressure < 1750 psia:

a. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise, be in MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With two containment cooling trains inoperable, enter LCO 3.0.3 immediately.

ST. LUCIE - UNIT 1 3/4 6-15 Amendment No. GO. 434

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 5 License Amendment Request Page 1 of 2 Attachment 5 Florida Power & Light Company St. Lucie Unit 2 License Amendment Request Technical Specifications Marked-Up Page

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 5 License Amendment Request Page 2 of 2 CONTAINMENT SYSTEMS 314.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY AND COOLING SYSTEMS 4' LIMITING CONDITION FOR OPERATION 3.6.2.1 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: Containment Spray System: MODES 1, 2, and MODE 3 with Pressurizer Pressure > 1750 psia.

Containment Cooling System: MODES 1, 2, and 3.

ACTION:

1. Modes 1, 2, and 3 with Pressurizer Pressure _>1750 psia:

a. With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and "within ý-... eys From initial dise.very of failure t. m..ct the LC'"; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.

b. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days and within SG ' fem

-fr itiat-'-t-thr; of failure t-o met-he LG; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c. With one containment spray train and one containment cooling train inoperable, concurrently implement ACTIONS a. and b. The completion intervals for ACTION a. and ACTION b. shall be tracked separately for each train starting from the time each train was discovered inoperable.

d. With two containment cooling trains inoperable, restore one cooling train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

e. With two containment spray trains inoperable or any combination of three or more trains inoperable, enter LCO 3.0.3. immediately.

2. Mode 3 with Pressurizer Pressure < 1750 psia:

a. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise be in MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With two containment cooling trains inoperable, enter LCO 3.0.3 immediately ST. LUCIE - UNIT 2 3/4 6-15 Amendment No. 2-5, 70

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 6 License Amendment Request Page 1 of 3 Attachment 6 Florida Power & Light Company St. Lucie Unit 2 License Amendment Request Technical Specifications Bases Marked-Up Page For Information Only

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 6 License Amendment Request Page 2 of 3 INSERT I It is possible to alternate between Actions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO; however, doing so would be inconsistent with the basis for the Action Time. Alternating between Actions in order to continue operation indefinitely while not meeting the LCO is not allowed.

St. Lucie Units 1 and 2 L-2014-082 Do* PAG TITLE: TECHNICAL SPECIFICATIONS Rage 3 of 3 3/4.6 BASES ATTACHMENT 8 OF ADM-25.04 6 of 11 REVISION NO.: CONTAINMENT SYSTEMS 14 ST. LUCIE UNIT 2 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 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 from the containment atmosphere and maintain concentrations below those assumed in the safety analyses. To ensure that these conditions can be met considering single-failure criteria, two spray trains and two cooling trains must be OPERABLE.

The 72-hour action interval specified in ACTION 1.a and ACTION 1.d, and the 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 EIINSERT /The 10 day

.en.t.a.nt ,.a*ACTIONS a for 1n.b is based

.. on coincident enty into two ACTION conditions (specified in ACTION I .. ) coupled with the

,g an.

of .....a.e,, ....... ;" 'If this,,, the 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 <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />) specified in ACTION 1.a to be in MODE 4 includes 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of additional time for restoration of the inoperable CS train, and takes into consideration the reduced driving force for a release of radioactive material from the 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 from iodine removal by the Containment Spray System), and the plant safety analyses.

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 7 License Amendment Request Page 1 of 2 Attachment 7 Florida Power & Light Company St. Lucie Unit 2 License Amendment Request Technical Specifications Clean Page

St. Lucie Units 1 and 2 L-2014-082 Docket Nos. 50-335 and 50-389 Attachment 7 License Amendment Request Page 2 of 2 CONTAINMENT SYSTEMS 314.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY AND COOLING SYSTEMS LIMITING CONDITION FOR OPERATION 3.6.2.1 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: Containment Spray System: MODES 1, 2, and MODE 3 with Pressurizer Pressure > 1750 psia.

Containment Cooling System: MODES 1, 2, and 3.

ACTION:

1. Modes 1, 2, and 3 with Pressurizer Pressure _Ž1750 psia:

a. With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.

b. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days; otherwise, be in MODE 3.within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c. With one containment spray train and one containment cooling train inoperable, concurrently implement ACTIONS a. and b. The completion intervals for ACTION a. and ACTION b. shall be tracked separately for each train starting from the time each train was discovered inoperable.

d. With two containment cooling trains inoperable, restore one cooling train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

e. With two containment spray trains inoperable or any combination of three or more trains inoperable, enter LCO 3.0.3. immediately.

2. Mode 3 with Pressurizer Pressure < 1750 psia:

a. With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise, be in MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With two containment cooling trains inoperable, enter LCO 3.0.3 immediately ST. LUCIE - UNIT 2 3/4 6-15 Amendment No. 2-5, 7