ML15020A084
| ML15020A084 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 01/16/2015 |
| From: | Farideh Saba Plant Licensing Branch II |
| To: | Frehafer K Florida Power & Light Co |
| References | |
| TAC MF4631, TAC MF4632 | |
| Download: ML15020A084 (3) | |
Text
1 NRR-PMDAPEm Resource From:
Saba, Farideh Sent:
Friday, January 16, 2015 4:59 PM To:
ken.frehafer@fpl.com; Lewis, Atanya (Atanya.Lewis@fpl.com)
Cc:
eric.katzman@fpl.com; Snyder, Pete; Helton, Shana
Subject:
RAIs regarding St. Lucie Units 1 and 2 Requested licensing action to Adopt TSTF-426, Revision 5 Importance:
High Ken and Atanya, By letter dated August 7, 2014, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14225A630), Florida Power & Light, (the licensee) submitted a license amendment request (LAR) which proposed changes to the Technical Specifications of the St. Lucie Nuclear Plant, Unit 1 (St. Lucie 1) and St. Lucie Nuclear Plant, Unit 2 (St. Lucie 2) facilities. Specifically the licensee proposed to adopt U.S. Nuclear Regulatory Commission (NRC) approved Revision 5 to Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) Change traveler TSTF-426,Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6B & 6C, which is an approved change to the Standard Technical Specifications (STS). The proposed changes replace required actions requiring either a default shutdown or explicit LCO 3.0.3 entry with a required action based on the risk significance for the systems degraded condition which varies from 8 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The Nuclear Regulatory Commissions regulatory requirements related to the content of the Technical Specifications are contained in Title 10 of the Code of Federal Regulations (10 CFR) 50.36. During the staffs review of a change to ensure that the change is in accordance with 10 CFR 50.36 the staff uses NRC NUREG-0800, Standard Review Plan, Chapter 16, Technical Specifications as guidance. According to this guidance the language in the proposed TS changes must be the same or equivalent to that in the current TS unless there is adequate technical or administrative reasoning supporting the change.
During review of the proposed changes to Limiting Condition for Operation (LCO) 3.1.2.2 the staff has determined that additional information is required. The following requests for additional information (RAI) have been developed by the NRC staff:
RAI-1
Action a. of LCO 3.1.2.2, Boration Systems - Flow Paths - Operating differs between Units 1 and 2 in the fact that Unit 1 refers to LCO 3.1.1.2 but Unit 2 refers directly to the COLR. Since the difference in this action is not explained in the licensee LAR but the same modification is proposed for both units please explain the differences between units that result in the different actions for this LCO and any impact on the proposed changes that this difference may have.
RAI-2
Proposed Action b. of LCO 3.1.2.2, Boration Systems - Flow Paths - Operating includes a difference from the model SE dated May 30, 2013 (ML13036A381) that is not explained in the LAR. In the model SE a reduced level of defense in depth is retained by verification of the operability of the high pressure safety injection (HPSI) system and a pressurizer PORV and its associated block valve. In the proposed actions - for St. Lucie 1 on page 6 of 7 of Attachment 2 and for St. Lucie 2 on page 7 of 8 of Attachment 3 - only HPSI is verified operable. Please explain how you intend to ensure that at least one PORV and its associated block valve are also operable so that the proposed Action b. may fully meet the intent of the model SE for a reduced level of defense in depth.
RAI-3
2 The notes included with each units proposed Action b. of LCO 3.1.2.2, Boration Systems - Flow Paths - Operating may create confusion since entrance into existing Action a. is predicated on two of three boron injection flow paths being inoperable. Currently Action a. allows only one of the above required boron injection flow paths to be operable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Therefore two of three boron injection flowpaths may be inoperable for any reason while in Action a. The proposed note indicates that the action not applicable when second or third required boron injection flow path intentionally made inoperable. The proposed note conflicts with existing Action a. in that it infers that a second flow path may not be intentionally made inoperable for any reason. Each proposed bases statement insert indicates that two required boron injection flow paths may be inoperable for any reason. Please propose a new note that mentions only a third train or discuss why the proposed note mentions a second train.
Per your email dated 01/13/15, you do not need a clarification call. Also you agreed to respond to these RAIs by 02/20/15.
Thank you, Farideh Farideh E. Saba, P.E.
Senior Project Manager NRC/ADRO/NRR/DORL 301-415-1447 Mail Stop O-8G9A Farideh.Saba@NRC.GOV
Hearing Identifier:
NRR_PMDA Email Number:
1818 Mail Envelope Properties (Farideh.Saba@nrc.gov20150116165800)
Subject:
RAIs regarding St. Lucie Units 1 and 2 Requested licensing action to Adopt TSTF-426, Revision 5 Sent Date:
1/16/2015 4:58:59 PM Received Date:
1/16/2015 4:58:00 PM From:
Saba, Farideh Created By:
Farideh.Saba@nrc.gov Recipients:
"eric.katzman@fpl.com" <eric.katzman@fpl.com>
Tracking Status: None "Snyder, Pete" <Pete.Snyder@nrc.gov>
Tracking Status: None "Helton, Shana" <Shana.Helton@nrc.gov>
Tracking Status: None "ken.frehafer@fpl.com" <ken.frehafer@fpl.com>
Tracking Status: None "Lewis, Atanya (Atanya.Lewis@fpl.com)" <Atanya.Lewis@fpl.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 4558 1/16/2015 4:58:00 PM Options Priority:
High Return Notification:
No Reply Requested:
Yes Sensitivity:
Normal Expiration Date:
Recipients Received: