L-2015-030, Application for Technical Specifications Changes to Remove Communications and Manipulator Crane Requirements and Relocate to Licensee-Controlled Documents
| ML15084A141 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/10/2015 |
| From: | Costanzo C Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2015-030 | |
| Download: ML15084A141 (30) | |
Text
0 March 10, 2015 FPL.
L-2015-030 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re:
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Application for Technical Specifications Changes to Remove Communications and Manipulator Crane Requirements and Relocate to Licensee-Controlled Documents Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requests to amend Facility Operating Licenses DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2. The proposed amendment would remove Technical Specifications (TS) Limiting Condition for Operation (LCO) 3/4.9.5, "Communications," from the St. Lucie Unit I TS and the St. Lucie Unit 2 TS; LCO 3/4.9.6, "Manipulator Crane Operability," from the St. Lucie Unit 1 TS; and LCO 3/4.9.6, "Manipulator Crane," from the St. Lucie Unit 2 TS and relocate the TS requirements to the Updated Final Safety Analysis Report (UFSAR) for St. Lucie Unit 1 and the UFSAR for St.
Lucie Unit 2. This proposed amendment is consistent with NUREG-1432, "Standard Technical Specifications for Combustion Engineering Plants."
The Enclosure to this letter contains a description of the proposed changes and includes a no significant hazards determination and environmental considerations.
Although this request is neither outage related nor required by any specific date, a prompt review is requested. Once approved, the amendment shall be implemented within 60 days of its receipt by FPL. There are no new commitments or changes to existing commitments made in this submittal.
This license amendment proposed by FPL has been reviewed by the St. Lucie Plant Onsite Review Group. In accordance with 10 CFR 50.91 (b)(1), a copy of the proposed license amendment is being forwarded to the State Designee for the State of Florida.
Please contact Mr. Eric Katzman, Licensing Manager, at 772-467-7734 if there are any questions about this submittal.
Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
L-2015-030 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on Sincerely, Christopher Costanzo Site Vice President St. Lucie Plant 6547
Enclosure:
License Amendment Request to Remove Communications and Manipulator Crane Requirements from the Technical Specifications and Relocate to Licensee-Controlled Documents cc:
USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Units 1 and 2 Ms. Cynthia Becker, Florida Department of Health
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 1 of 12 Enclosure Evaluation of the Proposed Changes License Amendment Request to Remove Communications and Manipulator Crane Requirements from the Technical Specifications and Relocate to Licensee-Controlled Documents 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
3.1 Unit 1 and Unit 2 TS LCO 3/4.9.5, "Communications" 3.2 Unit 1 LCO 3/4.9.6, "Manipulator Crane Operability" 3.3 Unit 2 LCO 3/4.9.6, "Manipulator Crane"
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions
5.0 ENVIRONMENTAL CONSIDERATION
6.0 PRECEDENT
7.0 REFERENCES
ATTACHMENTS:
- 1.
St. Lucie Unit 1 Technical Specification Markups
- 2.
St. Lucie Unit 2 Technical Specification Markups
- 3.
St. Lucie Unit 1 Retyped Technical Specification Pages
- 4.
St. Lucie Unit 2 Retyped Technical Specification Pages
St. Lucie Units i and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 2 of 12 1.0
SUMMARY
DESCRIPTION Florida Power & Light Company (FPL) proposes to revise the St. Lucie Unit 1 and St. Lucie Unit 2 licensing basis by amending Appendix A of Renewed Facility Operating Licenses DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2. The proposed changes will remove Technical Specifications (TS) Limiting Condition for Operation (LCO) 3/4.9.5, "Communications," from the St. Lucie Unit 1 TS and the St. Lucie Unit 2 TS, LCO 3/4.9.6, "Manipulator Crane Operability," from the St. Lucie Unit 1 TS, and LCO 3/4.9.6, "Manipulator Crane," from the St. Lucie Unit 2 TS and relocate the requirements to the Updated Final Safety Analysis Report (UFSAR) for St. Lucie Unit 1 and the UFSAR for St. Lucie Unit 2. Changes to the UFSAR are controlled in accordance with 10 CFR 50.59. The change is consistent with NUREG-1432, "Standard Technical Specifications for Combustion Engineering Plants."
Note that plant-specific TS relating to LCO 3.9.5, "Communication," and LCO 3.9.6, "Manipulator Crane (Refueling Machine)," were not included in the original version of NUREG-1432 because this TS did not meet the TS inclusion requirements as identified in the NRC letter from T. E. Murley to W. S. Wilgus, dated May 9, 1988.
2.0 DETAILED DESCRIPTION Unit 1 and Unit 2 TS LCO 3/4.9.5, "Communications," provides requirements for communications capability to ensure that refueling station personnel can be promptly informed of significant changes in the facility status or core reactivity condition during core alterations.
Unit 1 TS LCO 3/4.9.6, "Manipulator Crane Operability," provides requirements for the cranes used for movement of control element assemblies or fuel assemblies to ensure each crane has sufficient load capacity to lift a fuel assembly and protection of the core internals and pressure vessel from excessive lifting force in the event that they are inadvertently engaged during lifting operations. Unit 2 TS LCO 3/4.9.6, "Manipulator Crane," provides requirements for the refueling machine to ensure manipulator cranes will be used for movement of fuel assemblies; each crane has sufficient load capacity to lift a fuel assembly, with or without a control element assembly; and protection of the core internals and pressure vessel from excessive lifting force in the event that they are inadvertently engaged during lifting operations. The proposed St. Lucie Unit 1 and St. Lucie Unit 2 License Amendment Request (LAR) will remove Unit 1 and Unit 2 TS LCO 3/4.9.5, "Communications," Unit I TS LCO 3/4.9.6, "Manipulator Crane Operability,"
and Unit 2 TS 3/4.9.6, "Manipulator Crane," and relocate the requirements to the Updated Final Safety Analysis Report (UFSAR) for St. Lucie Unit 1 and the UFSAR for St. Lucie Unit 2.
During relocation, current TS Actions may be modified. Such modification, if performed, will be controlled by the provisions of 10 CFR 50.59 to determine if prior NRC approval is required.
Note that the proposed removal results in several TS pages being deleted.
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 3 of 12
3.0 TECHNICAL EVALUATION
10 CFR 50.36(c)(2)(ii) specifiesthe four criteria for including LCOs in the TS for commercial nuclear power reactors:
(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
(B) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
(D) Criterion 4. A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
The NRC position on application of screening criteria to apply to Unit 1 and Unit 2 TS LCO 3/4.9.5, "Communications;" Unit 1 TS LCO 3/4.9.6, "Manipulator Crane Operability;" and Unit 2 TS 3/4.9.6, "Manipulator Crane," based on the Commission's Interim Policy Statement Criteria to Technical Specification Improvements is documented in a letter dated May 9, 1988 from T. E.
Murley (NRC) to W. S. Wilgus (B&W Owners Group). The screening criteria were later incorporated into 10 CFR 50.36(c)(2)(ii), which contains the requirements for items that must be in the TS. An assessment of Unit 1 and Unit 2 TS LCO 3/4.9.5, "Communications;" Unit 1 TS LCO 3/4.9.6, "Manipulator Crane Operability;" and Unit 2 TS LCO 3/4.9.6, "Manipulator Crane," against the four criteria of 10 CFR 50.36(c)(2)(ii) is provided below.
3.1 Unit 1 and Unit 2 TS LCO 3/4.9.5, "Communications" TS LCO 3/4.9.5, "Communications," is applicable only during core alterations, which can only be conducted with the reactor head removed and the reactor coolant system depressurized. The components covered by this LCO include radios and associated power and transmission equipment necessary to establish and maintain communications between the control room and the refueling station.
10 CFR 50.36(c)(2)(ii)(A) Criterion 1 applies to installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Equipment used by personnel to establish and maintain communications between the control room and the refueling station is not part of any installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Therefore, Criterion 1 is not met for this LCO.
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 4 of 12 10 CFR 50.36(c)(2)(ii)(B) Criterion 2 applies to a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Equipment used by personnel to establish and maintain communications between the control room and the refueling station is not a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, Criterion 2 is not met for this LCO.
10 CFR 50.36(c)(2)(ii)(C) Criterion 3 applies to a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Equipment used by personnel to establish and maintain communications between the control room and the refueling station does not include any structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, Criterion 3 is not met for this LCO.
10 CFR 50.36(c)(2)(ii)(D) Criterion 4 applies to a structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Equipment used by personnel to establish and maintain communications between the control room and the refueling station has not been shown in any operating experience or probabilistic risk assessment to be significant to public health and safety. Therefore, Criterion 4 is not met for this LCO.
Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met for inclusion in the TS as an LCO, Unit 1 and Unit 2 TS LCO 3/4.9.5, "Communications," may be removed from the TS and relocated to the UFSAR. Following NRC approval of this proposed license amendment, changes to the relocated requirements will be controlled by the provisions of 10 CFR 50.59 to determine if prior NRC approval is required.
3.2 Unit 1 TS LCO 3/4.9.6, "Manipulator Crane Operability" Unit 1 TS LCO 3/4.9.6, "Manipulator Crane Operability," is applicable only during movement of control element assemblies or fuel assemblies within the reactor pressure vessel, which can only take place with the reactor head removed and the reactor coolant system depressurized. This LCO governs the manipulator crane (refueling machine) located inside the Reactor Building.
The refueling machine is a traveling bridge and trolley which is located above the refueling cavity and runs on rails set in the concrete on each side of the pool. Motors on the bridge and trolley accurately position the machine over each fuel assembly location within the reactor core or fuel transfer carrier. The hoist assembly contains an air operated grappling device which, when rotated by the actuator mechanism, engages the fuel assembly to be removed. The hoist assembly and grappling device are raised and lowered by a cable attached to the hoist winch.
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 5 of 12 After the fuel assembly has been raised into the refueling machine, the refueling machine transports the fuel assembly to its designated location.
During withdrawal or insertion of either a fuel assembly, or a fuel assembly with a control..
element inserted, the load on the hoist cable is monitored at the console to ensure that movement is not being restricted. Limits are such that damage to the assembly is prevented.
10 CFR 50.36(c)(2)(ii)(A) Criterion 1 applies to installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The manipulator crane (refueling machine) does not meet this criterion because it is not related to any installed instrumentation that performs these functions.
Therefore, Criterion 1 is not met for this LCO.
10 CFR 50.36(c)(2)(ii)(B) Criterion 2 applies to a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The initial conditions of Criterion 2 are not limited to only process variables assumed in safety analyses, but also include certain active design features and operating restrictions needed to preclude unanalyzed accidents. Active design features are intended to be those design features under the control of operations personnel (i.e., licensed operators and personnel who perform control functions at the direction of licensed operators). Should an LCO involve a physical, designed-in plant feature that prevents operations staff from immediately placing the plant in an unanalyzed condition in the course of operations (one that would require a design change before operators could exceed the limits of the LCO) that LCO would not satisfy Criterion 2. Two design basis accidents have been identified that could involve the manipulator crane:
- 1. UFSAR Section 15.3.3, "Inadvertent Loading of a Fuel Assembly into the Improper Position"
- 2. UFSAR Section 15.4.3, "Fuel Handling Accident" Each of the above accidents is discussed individually below as it relates to Criterion 2 for the manipulator crane LCO.
Inadvertent Loading of a Fuel Assembly into the Improper Position The manipulator crane would have been used to load a fuel assembly into an improper position if that event were to occur. However, TS LCO 3/4.9.6 only provides limits on minimum load capacity and load limit controls required for the manipulator crane. This LCO has no bearing on the process used to ensure fuel assemblies are moved into the proper position in the core; thus, LCO 3/4.9.6 does not prevent the misloading of a fuel assembly or otherwise involve the initiating conditions for this accident. Therefore, Criterion 2 is not met by TS LCO 3/4.9.6 for the Inadvertent Loading of a Fuel Assembly into the Improper Position accident.
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 6 of 12 Fuel Handling Accident This event consists of the drop of a single fuel assembly either in the Fuel Handling Building (FHB) or inside of Containment. For a Fuel Handling Accident (FHA) to occur in containment, the fuel assembly would be dropped from the manipulator crane. The manipulator crane cannot physically access the FHB, so it plays no role in the FHA postulated to occur there. TS LCO 3/4.9.6 only provides limits on minimum load capacity and load limit controls for the manipulator crane. The fuel assembly and the manipulator crane have physical, designed-in features that would prevent the operators from inadvertently placing the plant in an unanalyzed condition. In order to use a different fuel assembly in the reactor or a different manipulator crane that could change an initial condition for the FHA, a design change and review under the provisions of 10 CFR 50.59 would be required. Therefore, Criterion 2 is not met by this LCO for the Fuel Handling Accident.
10 CFR 50.36(c)(2)(ii)(C) Criterion 3 applies to a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The manipulator crane is used solely during refueling operations with the reactor head removed. It does not meet this criterion because it neither actuates to mitigate a design basis accident or transient nor is related to equipment that does meet this criterion.
Therefore, Criterion 3 is not met for this LCO.
10 CFR 50.36(c)(2)(ii)(D) Criterion 4 applies to a structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. The manipulator crane has not been shown in any operating experience or probabilistic risk assessment to be significant to public health and safety. Therefore, Criterion 4 is not met for this LCO.
Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met for inclusion in the TS as an LCO; Unit 1 TS LCO 3/4.9.6, "Manipulator Crane Operability," may be removed from the TS and relocated to the UFSAR. Following NRC approval of this proposed license amendment, changes to the relocated requirements will be controlled by the provisions of 10 CFR 50.59 to determine if prior NRC approval is required.
3.3 Unit 2 TS LCO 3/4.9.6, "Manipulator Crane" Unit 2 TS LCO 3/4.9.6, "Manipulator Crane," is applicable only during movement of fuel assemblies, with or without a control element assembly, within the reactor pressure vessel, which can only take place with the reactor head removed and the reactor coolant system depressurized.
This LCO governs the manipulator crane (refueling machine) located inside the Reactor Building. The refueling machine is a traveling bridge and trolley located above the refueling pool and rides on rails set in the concrete on each side of the refueling pool. Motors on the bridge and trolley position the machine over each fuel assembly location within the reactor core or fuel transfer carrier. The hoist assembly and grappling device are raised and lowered by a
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 7 of 12 cable attached to the hoist winch. After the fuel assembly has been raised into the refueling machine, the refueling machine transports the fuel assembly to its designated location.
During withdrawal or insertion of a fuel assembly, the load cell shall be continuously monitored to ensure that movement is not being restricted. Limits are such that specified loads are not exceeded.
10 CFR 50.36(c)(2)(ii)(A) Criterion 1 applies to installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The manipulator crane (refueling machine) does not meet this criterion because it is not related to any installed instrumentation that performs these functions.
Therefore, Criterion 1 is not met for this LCO.
10 CFR 50.36(c)(2)(ii)(B) Criterion 2 applies to a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The initial conditions of Criterion 2 are not limited to only process variables assumed in safety analyses, but also include certain active design features and operating restrictions needed to preclude unanalyzed accidents. Active design features are intended to be those design features under the control of operations personnel (i.e., licensed operators and personnel who perform control functions at the direction of licensed operators). Should an LCO involve a physical, designed-in plant feature that prevents operations staff from immediately placing the plant in an unanalyzed condition in the course of operations (one that would require a design change before operators could exceed the limits of the LCO) that LCO would not satisfy Criterion 2. Two design basis accidents have been identified that could involve the manipulator crane:
- 1. UFSAR Section 15.4.7, "Inadvertent Loading of a Fuel Assembly"
- 2. UFSAR Section 15.7.4.1.2, "Fuel Handling Accident" Each of the above accidents is discussed individually below as it relates to Criterion 2 for the manipulator crane LCO.
Inadvertent Loading of a Fuel Assembly The manipulator crane would have been used to load a fuel assembly into an improper position if that event were to occur. However, TS LCO 3/4.9.6 only provides limits on minimum load capacity and load limit controls required for the manipulator crane. This LCO has no bearing on the process used to ensure fuel assemblies are moved into the proper position in the core; thus, LCO 3/4.9.6 does not prevent the misloading of a fuel assembly or otherwise involve the initiating conditions for this accident. Therefore, Criterion 2 is not met by TS LCO 3/4.9.6 for the Inadvertent Loading of a Fuel Assembly accident.
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 8 of 12 Fuel Handling Accident This event consists of the drop of a single fuel assembly either in the Fuel Handling Building (FHB) or inside of Containment. For a Fuel Handling Accident (FHA) to occur in containment, the fuel assembly would be dropped from the manipulator crane. The manipulator crane cannot physically access the FHB, so it plays no role in the FHA postulated to occur there. LCO 3/4.9.6 only provides limits on minimum load capacity and load limit controls for the manipulator crane.
The fuel assembly and the manipulator crane have physical, designed-in features that would prevent the operators from inadvertently placing the plant in an unanalyzed condition. In order to use a different fuel assembly in the reactor or a different manipulator crane that could change an initial condition for the FHA, a design change and review under the provisions of 10 CFR 50.59 would be required. Therefore, Criterion 2 is not met by this LCO for the Fuel Handling Accident.
10 CFR 50.36(c)(2)(ii)(C) Criterion 3 applies to a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The manipulator crane is used solely during refueling operations with the reactor head removed. It does not meet this criterion because it neither actuates to mitigate a design basis accident or transient nor is related to equipment that does meet this criterion.
Therefore, Criterion 3 is not met for this LCO.
10 CFR 50.36(c)(2)(ii)(D) Criterion 4 applies to a structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. The manipulator crane has not been shown in any operating experience or probabilistic risk assessment to be significant to public health and safety. Therefore, Criterion 4 is not met for this LCO.
Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met for inclusion in the TS as an LCO, Unit 2 TS LCO 3/4.9.6, "Manipulator Crane," may be removed from the TS and relocated to the UFSAR. Following NRC approval of this proposed license amendment, changes to the relocated requirements will be controlled by the provisions of 10 CFR 50.59 to determine if prior NRC approval is required.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 establishes four criteria for having a Limiting Condition for Operation (LCO) in the plant Technical Specifications. Meeting at least one of those criteria requires an LCO to be established. The proposed changes do not eliminate the necessity of establishing and maintaining communications between the control room and the refueling station or the minimum load capacities and load limit controls required for the manipulator crane; rather, they only act to remove the requirements from the TS and relocate the requirements to the UFSAR.
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 9 of 12 In conclusion, FPL has determined that the proposed change does not require any exemptions or relief from regulatory requirements, other than the TS, and does not affect conformance with any regulatory requirement.
4.2 No Significant Hazards Consideration Determination The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazard if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
FPL is proposing that the Facility Operating Licenses DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2 be amended to remove Technical Specification (TS) Limiting Condition for Operation (LCO) 3/4.9.5, "Communications," from the St. Lucie Unit 1 TS and the St. Lucie Unit 2 TS, LCO 3/4.9.6, "Manipulator Crane Operability," from the St. Lucie Unit 1 TS, and LCO 3/4.9.6, "Manipulator Crane," from the St. Lucie Unit 2 TS and relocate the requirements to the Updated Final Safety Analysis Report (UFSAR) for St. Lucie Unit 1 and the UFSAR for St. Lucie Unit 2. The proposed changes are consistent with NUREG-1432, "Standard Technical Specifications for Combustion Engineering Plants."
FPL has reviewed this proposed license amendment and determined that its adoption would not involve a significant hazards consideration.
The basis for this determination is as follows:
- 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes act to remove the current necessity of establishing and maintaining communications between the control room and the refueling station and the minimum load capacities and load limit controls required for the manipulator crane limits and relocate the requirements to the UFSAR, which will have no impact on any safety related structures, systems or components. Once relocated to the UFSAR, changes to establishing and maintaining communications between the control room and the refueling station and the minimum load capacities and load limit controls required for the manipulator crane limits will be controlled in accordance with 10 CFR 50.59.
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 10 of 12 The probability of occurrence of a previously evaluated accident is not increased because these changes do not introduce any new potential accident initiating conditions. The consequences of accidents previously evaluated in the UFSAR are not affected because the ability of the components to perform their required functions is not affected.
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 changes act to remove the current necessity of establishing and maintaining communications between the control room and the refueling station and the minimum load capacities and load limit controls required for the manipulator crane limits and relocate the requirements to the UFSAR, which will have no impact on any safety related structures, systems or components. Once relocated to the UFSAR, changes to establishing and maintaining communications between the control room and the refueling station and the minimum load capacities and load limit controls required for the manipulator crane limits will be controlled in accordance with 10 CFR 50.59.
The proposed changes do not introduce new modes of plant operation and do not involve physical modifications to the plant (no new or different type of equipment will be installed). There are no changes in the method by which any safety related plant structure, system, or component (SSC) performs its specified safety function. As such, the plant conditions for which the design basis accident analyses were performed remain valid.
No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of the proposed changes. There will be no adverse effect or challenges imposed on any SSC as a result of the proposed changes.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
- 3.
Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
Margin of safety is related to confidence in the ability of the fission product barriers to perform their accident mitigation functions. The proposed changes act to remove the current necessity of establishing and maintaining communications between the control room and the refueling station and the minimum load capacities and load limit controls
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 11 of 12 required for the manipulator crane limits and relocate the requirements to the UFSAR, which will have no impact on any safety related structures, systems or components. Once relocated to the UFSAR, changes to establishing and maintaining communications between the control room and the refueling station and the minimum load capacities and load limit controls required for the manipulator crane limits will be controlled in accordance with 10 CFR 50.59. The proposed changes do not physically alter any SSC.
There will be no effect on those SSCs necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR) limits, loss of cooling accident peak cladding temperature (LOCA PCT), or any other margin of safety. The applicable radiological dose consequence acceptance criteria will continue to be met. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
4.3 Conclusions Based on the above, FPL concludes that the proposed amendment 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.
5.0 ENVIRONMENTAL CONSIDERATION
10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment of an operating license for a facility requires no environmental assessment, if the operation of the facility in accordance with the proposed amendment does not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in a significant increase in individual or cumulative occupational radiation exposure. FPL has reviewed this license amendment request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination is as follows.
Basis This change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:
- 1.
As demonstrated in the 10 CFR 50.92 evaluation, the proposed amendment does not involve a significant hazards consideration.
- 2.
The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The
St. Lucie Units 1 and 2 L-2015-030 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 12 of 12 proposed amendment does not change 'or modify the design or operation of any plant systems, structures, or components. The proposed amendment does not affect the amount or types of gaseous, liquid, or solid waste generated onsite. The proposed amendment does not directly or indirectly affect effluent discharges.
- 3.
The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure. The proposed amendment does not change or modify the design or operation of any plant systems, structures, or components. The proposed amendment does not directly or indirectly affect the radiological source terms.
6.0 PRECEDENT This License Amendment Request is similar to a License Amendment Request approved by letter dated February 17, 2010, "Salem Nuclear Generating Station, Unit Nos. 1 and 2, Issuance of Amendments Re: Relocation of Certain Technical Specification Requirements Associated with Refueling Operations (TAC Nos. ME1279 and ME1280)."
7.0 REFERENCES
- 1.
Letter from T. E. Murley (USNRC) to W. S. Wilgus (B&W Owners Group),
dated May 9, 1988
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2015-030 Page 1 of 4 ATTACHMENT 1 St. Lucie Unit 1 Technical Specifications Markups This coversheet plus 3 pages INDEX page VIII TS page 3/4 9-5 TS page 3/4 9-6 LICENSE AMENDMENT REQUEST PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO REMOVE COMMUNICATIONS AND MANIPULATOR CRANE REQUIREMENTS AND RELOCATE TO LICENSEE-CONTROLLED DOCUMENTS
INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REOUIREMENTS SECTION 3/4.9 PAGE REFUELING OPERATIONS 3/4.9.1 3/4.9.2 3/4.9.3 3/4.9.4 3/4.9.7 3/4.9.8 3/4.9.9 3/4.9.10 3/4.9.11 3/4.9.12 3/4.9.13 3/4.9.14 BORON CONCENTRATION..............................................................................
3/4 9-1 IN ST R U M E N TA T IO N.........................................................................................
3/4 9-2 D E C A Y T IM E......................................................................................................
3/4 9-3 CONTAINMENT PENETRATIONS.....................................................................
3/4 9-4 C O M M U C A T O S..........................................................................................
3/4 9-5 A.4 IU A.T R T
RANE R.
.TV............................
3/4 9-6 D E LE T E D...........................................................................................................
3/4 9-7 SHUTDOWN COOLING AND COOLANT CIRCULATION.................................
3/4 9-8 CONTAINMENT ISOLATION SYSTEM..............................................................
3/4 9-9 WATER LEVEL - REACTOR VESSEL............................................................
3/49-10 SPENT FUEL STORAGE POOL......................................................................
3/49-11 FUEL POOL VENTILATION SYSTEM - FUEL STORAGE..............................
3/4 9-12 D E L E T E D.........................................................................................................
3/4 9-15 D E L E T E D.........................................................................................................
3/4 9-16 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 3/4.10.2 3/4.10.3 3/4.10.4 3/4.10.5 SHUTDOW N MARGIN....................................................................................
3/4 10-1 GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIM ITS.........................................................................................................
3/4 10-2 DELETED.........................................................................................................
3/4 10-3 DELETED.........................................................................................................
3/4 10-4 CENTER CEA M ISALIGNM ENT......................................................................
3/4 10-5 UNIT 1 ViII Amendment No. 4. -24 2-2-7 5
ST. LUCIE -
24~
REFUELING OPERATIONS COMMUNICATIONS 1 MTWGCONDMITIN FOR OPERATION 3.9.6 D)Irol e8IIMmuIIn tioot chlll be mnaintaned bctwccn the eI to APPLICAB ILA'T OWrif GORE ALTERATIONS A GTIQGN --
Whcn d-rcet eommunjoationo bctwccn the 8ontrol roFAm and perzonnc! at the rcfueling station eannet be maintained, suspcnd all CORE AL-TERATIONS.
The proY~.tian of Spcoifieetien 3.0.3 Wer not app~ioaible.
SLJRVEILLAIJCE44EQU2REMENT-9 A Q ra LAW-
^^-
-Al-rm^
r^^ý
^ýý
-r--RRA' R
I the refue*ing ctation shell be damonctratld within one hour* prior to thVe sta~t of 8nd at least onoc per 12 houre during CORE ALTERAT4IONS.
INTENTIONALLY DELETEDI ST. LUCIE - UNIT 1 3/4 9-5 Amendment No. 4O9
REFUELING OPERATIONS ma A LII P~I II A P~.
~
A LIU~
- HED A Dli ITU I l1m3l 8Ik1l~~
Vii
.Il*Wk kIrDfD*WAIfkIl L.'T' C WAN O.'-'*T*."O FOR. 0-PEP.ATI"
- .9.6 The mani &pulator orano shall be used for moyemwnt of CE!Aq or. fuo aPIcaRmblico and c be OPE.,RABLE yoith
- a.
A minimum
.apacity ef 2000 pound.,
and b-An oyorlead out c9# limit of-3000 pnd*u, APPICAB6ILIn*lYI DuFringmlnt of GEMlI fuel uscla mbli
.ithi the IeaVter prlVsUle Yes-AG~QT-I
'Agith tho rgio ntc for 6rac OPPERABRILI TY not satisfied, sbucpend uoe of any iooal mIanIipuI-lato o-Frano441 frm peationcinr, n the moeyement cf CE!!Ar and fuel assemblies withiR h roaeter proccuro Yessel.
SURI-4I4II I
ALf h'r RPI IPE#AE+T4&
nohP manipulato crano-ucoTo moVomonRt 0fG
!!!~ACr, 9Fuci ar,,eombII6 WAc w
tinmcRcaoto prcccuro Yoccol shall be demonc6tratod OPERABLE within 72 houc prior to tho cta~ of cUch 8porationc by pe~frming a lead test of at leact 2600 poui-ndc -and-domoncRtratin an autemat*9 lead out oe# boforo tho omno load e)(oodc 30900 Poundcr.
INTENTIONALLY DELETEDl ST. LUCIE - UNIT 1 3/4 9-6 Amendment No. 46i
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-3 89 License Amendment Request L-2015-030 Page 1 of 4 ATTACHMENT 2 St. Lucie Unit 2 Technical Specifications Markups This coversheet plus 3 pages INDEX page IX TS page 3/4 9-5 TS page 3/4 9-6 LICENSE AMENDMENT REQUEST PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO REMOVE COMMUNICATIONS AND MANIPULATOR CRANE REQUIREMENTS AND RELOCATE TO LICENSEE-CONTROLLED DOCUMENTS
INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.8.2 D.C. SOURCES O P E R A T IN G.......................................................................................
3/4 8-10 S H U T D O W N.......................................................................................
3/4 8-13 3/4.8.3 ONSITE POWER DISTRIBUTION SYSTEMS O P E R A T IN G.......................................................................................
3/4 8-14 S H U T D O W N.......................................................................................
3/4 8-16 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES MOTOR-OPERATED VALVES THERMAL OVERLOAD PROTECTION BYPASS DEVICES......................................................
3/4 8-17 3/4.9 REFUELING OPERATIONS 3/4.9.1 3.4.9.2 3/4.9.3 3/4.9.4 3/4.95-3/4.9.7 3/4.9.8 3/4.9.9 3/4.9.10 3/4.9.11 3/4.9.12 3/4 10 BO RO N CO NCENTRATIO N.............................................................................
3/4 9-1 IN ST R U M E N TA T IO N........................................................................................
3/4 9-2 D E C A Y T IM E....................................................................................................
3/4 9-3 CONTAINMENT BUILDING PENETRATIONS..................................................
3/4 9-4 COMMUNICATIONS.......
3/4 9-5 M ANIPU ",6 TO R C RA NE...................................................................................
3/4 9-6 D E L E T E D..........................................................................................................
3/4 9-7 SHUTDOWN COOLING AND COOLANT CIRCULATION H IG H W ATER LEV EL............................................................................
3/4 9-8 LO W W ATER LEV EL.............................................................................
3/4 9-9 CONTAINMENT ISOLATION SYSTEM...........................................................
3/4 9-10 WATER LEVEL - REACTOR VESSEL...........................................................
3/49-11 SPENT FUEL STO RAG E POOL.....................................................................
3/4 9-12 D E LE T E D........................................................................................................
3/4 9-13 SPECIAL TEST EXCEPTIONS 3/4.10.1 3/4.10.2 3/4.10.3 3/4.10.4 3/4.10.5 SHUTDOWN MARGIN...................................................................................
3/4 10-1 MODERATOR TEMPERATURE COEFFICIENT, GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS........................................
3/4 10-2 REACTOR COOLANT LOOPS.......................................................................
3/4 10-3 CENTER CEA MISALIGNMENT.....................................................................
3/4 10-4 CEA INSERTION DURING ITC, MTC, AND POWER COEFFICIENT MEASUREMENTS..........................................................................................
3/4 10-5 ST. LUCIE - UNIT 2 IX Amendment No. 4104-, 4.34
REFUELING OPERAMONS 3/4.-"l COMMUNICATIMNS LIMITINMG rCONDITIONl FOR OIPEiRT"O Dircot oimunioatiens shell be maintainad betwen the ontrel rmv and perconncl at the rcfueling atation.
APPI ICARII lTY~ fliirinri CORF Al TFPATIfl~
AG~OT'G Whon dirF8Et oemm'-FieatiRn, bot;eeR the eCetrel room and persennel Et the rcfu,,lIng Stati ea+nnt be maintainod, cucpond ail CORE ALTERATIONS.
SURVEILLANCE REQUIREMENTS 4..6 Diroot commu~nieationo betWeen the control roomR and perconnol at tho r~2TuaIIna ttfltICn tflflhl t3 iomonctrataa witnin 1 nour crior t3 mc ctnrr OT 1-1ý and at least onoc per 12 hobIm dubIring GORE AL!Fi l.1 IINTENTIONALLY DELETEDI ST. LUCIE - UNIT 2 3/4 9-5 Amendment No. 26
ArR.FULIN
'O'r4PF4ATIOI'R 314.9.6 MANIPULATOR CRANE
' RIMIT GIN~NftTGIQN FJR-OPERAT"O 21.9.6 The manipulator oFER8Ano ohll b used fGr movomonet of fuiel assemblies, With or without GEMc, and shell be ORPER1BLE with a-.
A miniimum eapaeity of 2000 pounds, and b-An ovorload ouit off limfit of l866 thBn or ogual to 3000 pounds.
APPLICABILIW: DuriR ng emevmnt of fbiel assemblies, With or Without CEAC, within the repater p~e,sWFB e-~eeee AGT-G0#1 Wiffth the~ roguiroemonts for erano OPERABIIT-Y Retsaisfied, cusepod us f a~, ineperable m'anipu~lator ecran fromR epeffl~enc involving the meycment of CE!!Ac and fuol asromblioc within to roactor peraccre Yoeo-sl.
SURVEILLANCE REQUIREMENTS 114 ho manPulatGr erane ucoed tor movcmcniet e; ;uci assemblqws. with or without GF!!ArC.
within the reactor Sroccuro vecoci shell be domoeffetratd OPERABLE withi 72 hOUrc I
prior fo tno MtR 9 OT cun epcrationa by; pertorminRo a lead test eT at least 20uu pounac ana domcncR8at8iREI Bn aUtomato lo8d out off before the orano load exocods 3000 Beoundo.
IINTENTIONALLY DELETEDI ST. LUCIE - UNIT 2 3/4 9-6 Amendment No. 99
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2015-030 Page 1 of 4 ATTACHMENT 3 St. Lucie Unit 1 Retyped Technical Specifications Pages This coversheet plus 3 pages INDEX page VIII TS page 3/4 9-5 TS page 3/4 9-6 LICENSE AMENDMENT REQUEST PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO REMOVE COMMUNICATIONS AND MANIPULATOR CRANE REQUIREMENTS AND RELOCATE TO LICENSEE-CONTROLLED DOCUMENTS
INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION..............................................................................
3/4 9-1 3/4.9.2 INSTRUMENTATION........................................................................................
3/4 9-2 3/4.9.3 D E C A Y T IM E......................................................................................................
3/4 9-3 3/4.9.4 CONTAINMENT PENETRATIONS.....................................................................
3/4 9-4 3/4.9.5 D E LE T E D...........................................................................................................
3/4 9-5 3/4.9.6 D E LE T E D...........................................................................................................
3/4 9-6 3/4.9.7 D E LE T E D...........................................................................................................
3/4 9-7 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION.................................
3/4 9-8 3/4.9.9 CONTAINMENT ISOLATION SYSTEM..............................................................
3/4 9-9 3/4.9.10 WATER LEVEL - REACTOR VESSEL............................................................
3/4 9-10 3/4.9.11 SPENT FUEL STORAGE POOL......................................................................
3/4 9-11 3/4.9.12 FUEL POOL VENTILATION SYSTEM - FUEL STORAGE..............................
3/4 9-12 3/4.9.13 D E LE T E D.........................................................................................................
3/4 9-15 3/4.9.14 D E LE T E D.........................................................................................................
3/4 9-16 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN....................................................................................
3/4 10-1 3/4.10.2 GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION L IM IT S.........................................................................................................
3 /4 10 -2 3/4.10.3 D E LE T E D.........................................................................................................
3/4 10-3 3/4.10.4 D E LE T E D.........................................................................................................
3/4 10-4 3/4.10.5 CENTER CEA MISALIGNMENT......................................................................
3/4 10-5 ST. LUCIE - UNIT 1 VIII Amendment No. 4. 24. 2-27 4-93,243
INTENTIONALLY DELETED ST. LUCIE - UNIT 1 3/4 9-5 Amendment No. 4--2
rF INTENTIONALLY DELETED ST. LUCIE - UNIT 1 3/4 9-6 Amendment No. 462
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2015-030 Page 1 of 4 ATTACHMENT 4 St. Lucie Unit 2 Retyped Technical Specifications Pages This coversheet plus 3 pages INDEX page IX TS page 3/4 9-5 TS page 3/4 9-6 LICENSE AMENDMENT REQUEST PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO REMOVE COMMUNICATIONS AND MANIPULATOR CRANE REQUIREMENTS AND RELOCATE TO LICENSEE-CONTROLLED DOCUMENTS
INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.8.2 D.C. SOURCES O P E R A T IN G.........................................................................................
3/4 8-10 S H U T D O W N.........................................................................................
3/4 8-13 3/4.8.3 ONSITE POWER DISTRIBUTION SYSTEMS O P E R A T IN G.........................................................................................
3/4 8-14 S H U T D O W N.........................................................................................
3/4 8-16 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES MOTOR-OPERATED VALVES THERMAL OVERLOAD PROTECTION BYPASS DEVICES......................................................
3/4 8-17 3/4.9 REFUELING OPERATIONS 3/4.9.1 BO RO N CO NCENTRATIO N..............................................................................
3/4 9-1 3.4.9.2 IN STR U M ENTAT IO N.........................................................................................
3/4 9-2 3/4.9.3 D E C A Y T IM E......................................................................................................
3/4 9-3 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS...................................................
3/4 9-4 3/4.9.5 D E LE T E D...........................................................................................................
3/4 9-5 3/4.9.6 D E LE T E D...........................................................................................................
3/4 9-6 3/4.9.7 D E LE T E D...........................................................................................................
3/4 9-7 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION H IG H W A TER LEV EL.............................................................................
3/4 9-8 LO W W ATER LEV EL..............................................................................
3/4 9-9 3/4.9.9 CONTAINMENT ISOLATION SYSTEM............................................................
3/4 9-10 3/4.9.10 WATER LEVEL - REACTOR VESSEL............................................................
3/4 9-11 3/4.9.11 SPENT FUEL STORAGE POOL......................................................................
3/4 9-12 3/4.9.12 D E L E T E D.........................................................................................................
3/4 9-13 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 S H UTD O W N M A RG IN....................................................................................
3/4 10-1 3/4.10.2 MODERATOR TEMPERATURE COEFFICIENT, GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS........................................
3/4 10-2 3/4.10.3 REACTOR COOLANT LOOPS.........................................................................
3/4 10-3 3/4.10.4 CENTER CEA MISALIGNMENT......................................................................
3/4 10-4 3/4.10.5 CEA INSERTION DURING ITC,.MTC, AND POWER COEFFICIENT M EA S U R E M E N T S............................................................................................
3/4 10-5 ST. LUCIE - UNIT 2 IX Amendment No. 4-04, 4,4
INTENTIONALLY DELETED ST. LUCIE - UNIT 2 3/4 9-5 Amendment No. 2-5
INTENTIONALLY DELETED ST. LUCIE - UNIT 2 3/4 9-6 Amendment No. 99