ML15182A160

Issuance of Amendments Regarding Adoption of Technical Specification Task Force Traveler 523 (TSTF-523), Revision 2

ML15182A160
Person / Time
Site:	Saint Lucie
Issue date:	07/20/2015
From:	Farideh Saba Plant Licensing Branch II
To:	Nazar M Florida Power & Light Co
Saba F DORL/LPL2-2 301-415-1447
References
TAC MF4424, TAC MF4425
Download: ML15182A160 (34)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 July 20, 2015

SUBJECT:

ST. LUCIE PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS REGARDING ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER 523 (TSTF;523), REVISION 2 (TAC NOS. MF4424 AND MF4425)

Dear Mr. Nazar:

The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed

.Amendment No. 224 to Renewed.. Facility Operating License No. DPR-67 and Amendment No. 17 4 to Renewed Facility Operating License No. NPF-16 for the St. Lucie Plant, Unit Nos. 1 and 2, respectively. The amendments change the Technical Specifications (TSs) in response to Florida Power & Light Company's application dated July 14, 2014, as supplemented by letter dated June 30, 2015.

The amendments modify the TSs to address NRC Generic Letter 2008-01, "Managing Gas Accumulation in emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." The amendments revise and add surveillance requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to p_rovide allowances that permit performance of the verification.

11 ~

The NRC staff's safety evaluation of the amendments is enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Docket Nos. 50-335 and 50-389

Enclosures:

1. Amendment No. 224 to DPR-67

2. Amendment No. 174 to NPF-16

3. Safety Evaluation cc w/enclosures: Distribution via Listserv Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-335 ST. LUCIE PLANT UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 224 Renewed License No. DPR-67

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power & Light Company (the licensee) dated July 14, 2014, as supplemented by letter dated June 30, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities wjll be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, Renewed Facility Operating License No. DPR-67 is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and by amending paragraph 3.8 to read as follows:

B.

Technical Specifications. *

• The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 224, are hereby incorporated in the renewed license.

FPL shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.

Attachment:

Changes to Operating License No. DPR-67 and the Technical Specifications Date of Issuance: July 20, 2015 FOR THE NUCLEAR REGULA TORY COMMISSION Shana R. Helton, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT

.~**. " -

AMENDMENT NO. 224 TO RENEWED FP..CILITY OPERATING LICENSE NO. DPR-67 DOCKET NO. 50-335 Replace Page 3 of Renewed Facility Operating License DPR-67 with the attached Page 3. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove 314 4-1c 3/4 4-1d 314 4-1 e 3/4 5-4 314 6-15a 314 6-16 314 9-8 314 9-8a Insert 314 4-1c 3/4 4-1d 3/4 4-1e 314 5-4 314 6-15a 3/4 6-16 314 9-8 314 9-8a applicable provision$ of the Act and to the rules, regulations, and orders of the Commission now or hereafter'in effect; and is subject to the additional conditions specified or incorporated below:

A.

Maximum Power Level FPL is authorized to operate the facility at steady state reactor core power levels not in excess of 3020 megawatts (thermal).

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised

. through Amendment No. 224 are hereby incorporated in the renewed license.

FPL shall operate the facility in accordance with the Technical Specifications.

Appendix B, the Environmental Protection Plan (Non-Radiological), contains environmental conditions of the renewed license. If significant detrimental effects

• or evidence of irreversible damage are detected by the monitoring programs required by Appendix B of this license, FPL will provide the Commission with an

• analysis of the problem and plan of action to be taken subject to Commission approval to eliminate or significantly reduce the detrimental effects or damage.

C.

Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d), as revised on March 28, 2003, describes certain future activities to be completed before the period of extended operation. FPL shall complete these activities no later than March 1, 2016, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on March 28, 2003, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4), following issuance of this renewed license. Until that update is complete, FPL may make changes to the programs described in such supplement without prior Commission approval, provided that FPL evaluates each such change pursuant to the criteria set forth in 10 CFR 50,59 and otherwise complies with the requirements in that section.

D.

Sustained Core Uncoverv Actions Procedural guidance shall be in place to instruct operators to implement actions that are designed to mitigate a small-break loss-of-coolant accident prior to a calculated time of sustained core uncovery.

Renewed License No. DPR-67 Amendment No. 224

REACTOR COOLANT SYSTEM HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required reactor coolant pump(s), if not in operation, shall be determined to be OPERABLE in accordanc.e with the Surveillance Frequency Control Program by verifying correct breaker alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying the secondary side water level to be~ 10% of narrow range indication in accordance with the Surveillance Frequency Control Program.

4.4.1.3.3 At least one reactor coolant or shutdown cooling loop shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.3.4 Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.*

• Not required to be performed until 12 ho'urs after entering MODE 4.

ST. LUCIE - UNIT 1 3/4 4-1c Amendment No.-Be, ~. 224

)

REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and in operation* and either:

a.

One additional shutdown cooling loop shall be OPERABLE#, or

b.

The secondary side water level of at least two steam generators shall be greater than 10% of narrow range indication, APPLICABILITY: MODE 5 with reactor coolant loops filled##.

ACTION:

a.

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

b.

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

. SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be determined to be within limits in accordance with the Surveillance Frequency Control Program.

4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.4.1.3. Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

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

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

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

ti#-

A reactor coolant pump shall not be started with two idle loops unless the secondary water temperature of each steam generator is less than 30°F above each of the Reactor Coolant System cold leg temperatures.

ST. LUCIE - UNIT 1 3/4 4-1d Ameridment No. ae, &i, 400, 4+9,

.w+,~,224

REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two shutdown cooling loops shall be OPERABLE# and at least one shutdown cooling loop shall be in operation*.

APPLICABILITY: MODE 5 with reactor coolant loops not filled.

ACTION:

a.

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

b.

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

SURVEILLANCE REQUIREMENTS 4.4.1.4.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.4.2.1 Verify shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

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

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

ST. LUCIE - UNIT 1 3/4 4-1e Amendment No. ea, 400, 4+9,

~. 224

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position

1.

V-3659

1.

Mini-flow

1.

Open isolation

2.

V-3660

2.

Mini-flow

2.

Open isolation

b.

In accordance with the Surveillance Frequency Control Program by:

1.

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

2.

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

c.

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

1.

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

2.

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

d.

In accordance with the Surveillance Frequency Control Program by:

1.

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

2.

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

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

ST. LUCIE - UNIT 1 3/4 5-4 Amendment No. 9Q, +2G,

~.~.224

SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is positioned to take suction from the Rwr on a Containment Pressure -- High High test signal.*

b.

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

c.

In accordance with the Surveillance Frequency Control Program by verifying containment spray system locations susceptible to gas accumulation are sufficiently filled with water.

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

ST. LUCIE - UNIT 1 3/4 6-15a Amendment No. ~. ~. 4-94,

~.224

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

d.

In accordance with the Surveillance Frequency Control Program, during shutdown, by:

1.

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

2.

Verifying that each spray pump starts automatically on a CSAS test signal.

3.

Verifying that upon a recirculation actuation signal, the containment sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established.

e.

By verifying each spray nozzle is unobstructed following maintenance wh.ich could result in nozzle blockage.

4.6.2.1.1. Each containment cooling train shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by:

1.

Starting each cooling train fan unit from the control room and verifying that each unit operates for at least 15 minutes, and *

2.

Verifying a cooling water flow rate of greater than or equal to 1200 gpm to each cooling unit.

b.

In accordance with the Surveillance Frequency Control Program, during shutdown, by verifying that each containment cooling train starts automatically on an SIAS test signal.

ST LUCIE - UNIT 1 3/4 6-16 Amendment No. 00, +:M, ~. ;w.i,

~.224

REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation*.

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

ACTION:

a.

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

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

b.

The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.8.1 At least one shutdown cooling loop shall be verified to be in operation and circulating reactor coolant at a flow rate of greater than or equal to 3000 gpm in accordance with the Surveillance Frequency Control Program.

4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

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

ST. LUCIE - UNIT 1 314 9-8 Amendment No. W, 4-79, ~. 224

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and at least one shutdown cooling loop shall be in operation.*

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

ACTION:

a.

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

b.

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

c.

The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.8.2 At least one shutdown cooling loop shall be verified to be in operation and circulating reactor coolant at a flow rate of greater than or equal to 3000 gpm in accordance with the Surveillance Frequency Control Program.

4.9.8.2.1 Verify shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

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

ST. LUCIE - UNIT 1 314 9-8a Amendment No. W, -WJ, 4+9, +99,

~. 224

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY ORLANDO UTILITIES COMMISSION OF THE CITY OF ORLANDO, FLORIDA AND FLORIDA MUNICIPAL POWER AGENCY DOCKET NO. 50-389 ST. LUCIE PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 17 4 Renewed License No. NPF-16

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power & Light Company (the licensee) dated July 14, 2014, as supplemented by letter dated June 30, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the healtt) and safety of the public; and E.

The issuance of this amendment is in accordance with 1 O CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, Renewed Facility Operating License No. NPF-16 is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, /"'-

and by amending paragraph 3.8 to read as follows:

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. t-74 are hereby incorporated into the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.

Attachment:

Changes to Operating License No. NPF-16 and the Technical Specifications Date of Issuance: July 20, 2015 FOR THE NUCLEAR REGULATORY COMMISSION Shana R. Helton, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT AMENDMENT NO. 174 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-16 DOCKET NO. 50-389 Replace Page 3 of Renewed Facility Operating License NPF-16 with the attached Page 3. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove 3/4 4-4 3/44-5 3/44-6 3/4 5-4 3/4 6-15a 3/4 6-16 3/4 9-8 3/4 9-9 Insert 3/4 4-4 3/4 4-5 3/44-6 3/4 5-4 3/4 6-15a 3/4 6-16 3/4 9-8 3/4 9-9

3. '.

neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required.

D.

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, FPL to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and E.

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, FPL to possess, but not separate, such byproduct and special.nuclear materials as may be produced by the operation of the facility.

3.

This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission's regulations: 10 CFR Part 20, Section 30.34 of 1 O FR Part 30, Section 40.41 *of 1 O CFR Part 40, Section 50.54 and 50.59 of 1 O CFR Part 50, and Section 70.32 of 1 O CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A.

Maximum Power Level FPL is authorized to operate the facility at steady state reactor core power levels not in excess of 3020 megawatts (thermal).

8.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 17 4 are hereby incorporated in the renewed license.

FPL shall operate the facility in accordance with the Technical Specifications.

Renewed License No. NPF-16 Amendment No. 17 4

REACTOR COOLANT SYSTEM HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required Reactor Coolant pump(s), if not in operation, shall be determined to be OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying the secondary side water level to be~ 10% indicated narrow range level in accordance with the Surveillance Frequency Control Program.

4.4.1.3.3 At least one Reactor Coolant or shutdown cooling loop shall be verified to be. in operation and circulating Reactor Coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.3.4 Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.*

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

ST LUCIE - UNIT 2 3/4 4-4 Amendment No. 4+3, 174

REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and in operation*, and either:

a..

One additional shutdown cooling loop shall be OPERABLE#, or

b.

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

APPLICABILITY: MODE 5 with Reactor Coolant loops filled##.

ACTION:

a.

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

b.

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

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be determined to be within limits in accordance with the Surveillance Frequency Control Program.

4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.4.1.3 Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance.with the Surveillance Frequency Control Program.

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

1) no operations are permitted that would cause introduction into the RCS, coolant with.

boron concentration less than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and 2) core outlet temperature is maintained at least 10°F below saturation temperature.

One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other shutdown cooling loop is OPERABLE and in operatiOJ1.

1. 1. A Reactor Coolant pump shall not be started with t:Wo idle loops unless the secondary water temperature of each steam generator is less than 40°F above each of the Reactor Coolant System cold leg temperatures.

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

M, 4&, ~.

.:!+a, 174

REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two shutdown cooling loops shall be OPERABLE# and at least one shutdown cooling loop shall be. in operation.*

APPLICABILITY: MODE 5 with reactor coolant loops not filled.

ACTION:

a.

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

b.

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

SURVEILLANCE REQUIREMENTS 4.4.1.4.2 At least one shutdown cooling loop shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.4.2.1 Verify shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

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

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

ST. LUCIE - UNIT 2 3/4 4-6 Amendment No. ~. ~. 17 4

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position

a.

V3733

a. SIT Vent Valves

a. Locked Closed V3734

b.

V3735

b. SIT Vent Valves

b. Locked Closed V3736

c.

V3737

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

b.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.*

c.

In accordance with the Surveillance Frequency Control Program by verifying ECCS locations susceptible to gas accumulation are sufficiently filled with water.

d.

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

1.

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

2.

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

e.

In accordance with the Surveillance Frequency Control Program by:

1.

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

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

ST. LUCIE - UNIT 2 3/4 5-4 Amendment No. +'J, ~. 174

SURVEILLANCE REQUIREMENTS 4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is positioned to take suction from the RWT on a Containment Pressure - - High.-High test signal.*

b.

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

c.

In accordance with the Surveillance Frequency Control Program, during shutdown, by:

1.

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

2.

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

• Not required to be met for system vent flow paths opened under administrative control ST. LUCIE - UNIT 2 3/4 6-15a Amendment No. :m, 9+, ~, ~,

174

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3.

Verifying that each spray pump starts automatically on a CSAS test signal.

d.

In accordance with the Surveillance Frequency Control Program by verifying containment spray system locations susceptible to gas accumulation are sufficiently filled with water.

e.

By verifying each spray nozzle is unobstructed following maintenance which could result in nozzle blockage.

. 4.6.2.1.1. Each containment cooling train shall be demonstrated OPERABLE:

\\/

a.

In accordance with ttie Surveillance Frequency Control Program by:

1.

Starting each cooling train fan unit from the control room and verifying that each unit operates for at least 15 minutes, and

2.

Verifying a cooling water flow rate of greater than or equal to 1200 gpm to each cooling unit.

b:

In accordance with the Surveillance Frequency Control Program, during shutdown, by verifying that each containment cooling train starts automatically on an SIAS test signal.

ST LUCIE - UNIT 2 3/4 6-16 Amendment No. ~. +-0, 448, ~.

174

REFUELING OPERATIONS 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation.*

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

ACTION:

With no shutdown cooling loop OPERABLE and.in operation, suspend all operations involving an increase in reactor decay heat load or operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of Technical Specification 3. 9.1 and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate corrective action to return the required shutdown cooling loop to OPERABLE and operating status as soon as possible. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.9.8.1 In accordance with the Surveillance Frequency Control Program:

a.

At le~st one shutdown cooling loop shall be verified to be in operation

b.

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

c.

Verify required shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water.

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

• • The reactor coolant flow rate requirement may be reduced to 1850 gpm if the following conditions are satisfied before the reduced requirement is implemented: thereactor has been determined to have been subcritical for at least 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />, the maximum RCS temperature is s 117°F, and the temperature of CCW to the shutdown cooling heat exchanger is s 87°F.

ST LUCIE UNIT 2 3/4 9-8 Amendment No.

422,.::t-'7d, 174

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOROPERATION 3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and at least one shutdown cooling loop shall be in operation.**

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

ACTION:

a.

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

b.

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

SURVEILLANCE REQUIREMENTS 4.9.8.2 In accordance with the Surveillance Frequency Control Program:

a.

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

b.

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

c.

Verify shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water.

The reactor coolant flow rate requirement may be reduced to 1850 gpm if the following conditions are satisfied before the reduced requirement is implemented: the reactor has been determined to have been subcritical for at least 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />, the maximum RCS temperature is~ 117°F, and the temperature of CCW to the shutdown cooling heat exchanger is~ 87°F.

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

ST. LUCIE - UNIT 2 3/4 9-9 Amendment No. ~. W, +e, +2J; +J9,

.Me.~. 174

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR AMENDMENT NO. 224 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-67 AND AMENDMENT NO. 174 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-16 FLORIDA POWER & LIGHT COMPANY, ET AL.

1.0 INTRODUCTION

ST. LUCIE PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-355 and 50-389 By letter dated July 8, 2014, as supplemented by letter dated June 30, 2015,1 Florida Power & Light Company (the licensee) requested changes to the Technical Specifications (TSs) for St. Lucie Nuclear Plant, Units 1 and 2 (St. Lucie 1 and 2), which are contained in Appendix A of Renewed Facility Operating License Nos. DPR-67 and NPF-16. The licensee requested to revise or add surveillance requirements (SRs) to the TSs to verify that system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances that permit performance of the verification. The licensee requested to adopt the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Standard Technical s*pecifications (STSs) Change Traveler TSTF-523, Revision 2, "Generic Letter [GL] 2008-01, Managing Gas Accumulation," dated February 21, 2013.2* The Federal Register (FR) notice published on January 15, 2014 (79 FR 2700), announced the availability of this TSTF.

By letter dated June 30, 2015, the licensee supplemented its amendment request. NRC staff determined that the licensee's supplement did not expand the scope of the submittal and did not change the NRG staff's proposed no significant hazards consideration determination, as published in the FR on October 28, 2014 (79 FR 64225).

1 Agencywide Documents and Management System (ADAMS) Accession Nos. ML14205A278 and ML15198A149, respectively.

2 ADAMS Accession No. ML13053A075.

Enclosure

2.0 REGULATORY EVALUATION

2.1 Background

On January 11, 2008, the NRC issued GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"3 to address the issue of gas accumulation in emergency core cooling systems (ECCSs), decay heat removal (OHR) systems, and containment spray (CS) systems. Gas accumulation in such systems can result in water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

• These effects may result in the subject system being unable to perform its specified safety function. The industry and NRC staff agreed that a change to the STSs and plant-specific TSs would be necessary to address some issues discussed in GL 2008-01. TSTF-523, Revision 2 contains proposed changes to the STSs SRs and Bases to address some of the concerns in GL 2008-01.

2.2 Description of Proposed Changes The licensee proposed revising the St. Lucie 1 and 2 TSs to ado.pt the changes described in TSTF-523, Revision 2, with variations to address plant-specific numbering, format, and titles in the St. Lucie TSs. The proposed changes would revise ECCS SRs related to gas accumulation and add new SRs related to gas accumulation for the residual heat removal (RHR) and CS systems. The licensee also included associated draft changes to its TS Bases in its application.

The licensee proposed the following changes to the TSs (Section 3 of this Safety Evaluation describes the changes in more detail):

TS 3/4.4.1.3, "Reactor Coolant System - Hot Shutdown": add new SR 4.4.1.3.4; TS 3/4.4.1.4.1, "Reactor Coolant System - Cold Shutdown - Loops Filled": add new SR 4.4.1.4.1.3; e

TS 3/4.4.1.4.2, "Reactor Coolant System - Cold Shutdown - Loops Not Filled": add new SR 4.4.1.4.2.1; TS 3/4.5.2, "ECCS Subsystems - Operating": revise SR 4.5.2b.1 and add SR 4.5.2b.2 for St. Lucie 1 TSs, and revise SRs 4.5.2b and 4.5.2c for St. Lucie 2 TSs; TS 3/4.6.2, "Containment Systems - Depressurization and Cooling Systems -

Containment Spray and Cooling Systems": revise SR 4.6.2.1 a and add new SR 4.6.2.1 c for St. Lucie 1 TSs; and revise SR 4.6.2.1 a and add new SR 4.6.2.1d for St. Lucie 2 TSs; TS 3/4.9.8.1, "Refueling Operations - Shutdown Cooling and Coolant Circulation - High Water Level": add new SR 4.9.8.1.1 for St. Lucie 1 TSs, and add new SR 4.9.8.1 c for St. Lucie 2 TSs; e

TS 3/4.9.8.2, "Refueling Operations - Low Water Level": add new SR 4.9.8.2.1 to St. Lucie 1 TSs, and add new SR 4.9.8.2c to St. Lucie 2 TSs.

3 ADAMS Accession No. ML072910759.

2.3 Regulatory Review The NRC staff considered the following regulatory requirements, guidance, and plant-specific licensing and design basis information during its review of the licensee's application.

TSTF 523, Revision 2 and its associated model safety evaluation4 discuss applicable regulatory requirements and guidance, including 10 CFR Part 50, Appendix A. Because the St. Lucie 1 construction permit was issued prior to 10 CFR Part 50, Appendix A, the St. Lucie 1 design approval for the construction phase was based on the proposed general design criteria (GDC) published by the Atomic Energy Commission (AEC) in the FR (32 FR 10213) on July 11, 1967.

Section 1.3.2, "Comparison of Preliminary and Final Design," and Chapter 3, "Design Criteria -

Structures, Components, Equipment and Systems," of the St. Lucie 1 Updated Final Safety Analysis Report (UFSAR) describes the St. Lucie 1 GDC. The UFSAR evaluation of the following GDC reflect design requirements similar to those specified in the GOG discussed in TSTF-523, Revision 2: Criterion 1, "Quality Standards and Records," Criterion 34, "Residual Heat Removal," Criterion 35, "Emergency Core Cooling," Criterion 36, "Inspection of Emergency Core Cooling System," Criterion 37, "Testing of Emergency Core Cooling System," Criterion 38, "Containment Heat Removal," Criterion 39, "Inspection of Containment Heat Removal System,"

and Criterion 40, "Testing of Containment Heat Removal System." Additionally, the regulations in 10 CFR 50.46 provide specified ECCS performance criteria.

The regulations in Appendix A to 10 CFR Part 50 provide the design requirements for St. Lucie 2. The GDC in 1 O CFR Part 50, Appendix A, that are applicable to gas management in the subject systems include: GOG 1, 34, 35, 36, 37, 38, 39, and 40. GDC 1 requires that the subject systems be designed, fabricated, erected, and tested to quality standards. GDC 34

. requires an RHR system designed to maintain specified acceptable fuel design limits and to meet design conditions that are not exceeded if a single failure occurs and specified electrical power systems fail. GDC 35, 36, and 37 require an ECCS design that meets performance, inspection, and testing requirements. Additionally, the regulations in 10 CFR 50.46 provide specified ECCS performance criteria. GDC 38, 39, and 40 require a containment heat removal system design that meets performance, inspection, and testing requirements. Additionally, the regulations in 10 CFR 50.46 provide specified ECCS performance criteria.

Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 requires that applicants for construction permits include in their preliminary safety analysis reports a description of th.e quality assurance program to be applied to the design, fabrication, construction, and testing of the structures, systems, and components of the facility. Part 50, Appendix B also requires that applicants for operating licenses include, in their final safety analysis reports, information pertaining to the managerial and administrative controls to be used to assure safe operation. The quality assurance criteria provided in Part 50, Appendix B that apply to gas management in the subject systems include: Criteria Ill, V, XI,

. XVI, and XVII. Criteria Ill and V require measures to ensure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, "Definitions," and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion XI requires a test program to ensure that the subject

• 4 ADAMS Accession No. ML13255A169.

systems will perform satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have been satisfied. Criterion XVI requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management. Criterion XVII requires maintenance of records of activities affecting quality.

The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36(c). The regulations in 10 CFR 50.36 require that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility.

operation will be within safety limits, and that the LCOs will be met. Section 6 of the St. Lucie 1 and 2 TSs requires the licensee to establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)." Furthermore, Appendix A to RG 1.33 identifies instructions for filling and venting the ECCS and OHR system, as well as for draining and refilling heat exchangers.

3.0 TECHNICAL EVALUATION

The SRs the licensee proposed to add are consistent with TSTF-523, Revision 2, and are appropriate to address the issues discussed in GL 2008-01. The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 1 O CFR 50.36(c). The proposed SRs must be sufficient to provide reasonable assurance that the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The licensee proposed the following TS changes, which are applicable to both units' TSs unless stated otherwise:

(1)

Add SR 4.4.1.3.4, which states, "Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.*" The added Footnote (*)

states, "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4."

(2)

Add SR 4.4.1.4.1.3, which states, "Verify required shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(3)

Add SR 4.4.1.4.2.1, which states, "Verify shutdown cooling train locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(4)

For Unit 1, add Footnote(*) to SR 4.5.2.b.1, which states, "Not required to be met for system vent flow paths opened under administrative control."

(5)

For Unit 1, add SR 4.5.2b.2, which states, Verifying ECCS train locations susceptible to gas accumulation are sufficiently filled with water."

(6)

For Unit 2, add Footnote(*) to SR 4.5.2.b, which states, "Not required to be met for system vent flow paths opened under administrative control."

(7)

For Unit 2, revise SR 4.5.2c, which currently states, "By verifying that the ECCS piping is full of water by venting the accessible piping high points following maintenance, shutdown cooling system operation and/or any other activity which could cause the introduction of air into the system," to state, "In accordance with the Surveillance Frequency Control Program by verifying ECCS locations susceptible to gas accumulation are sufficiently filled with water."

(8)

Add Footnote (*) to SR 4.6.2.1 a, which states, "Not required to be met for system vent flow paths opened under administrative control."

(9)

For Unit 1, add a new SR 4.6.2.1 c, which states, "In accordance with the Surveillance Frequency Control Program by verifying containment spray system locations susceptible to gas accumulation are sufficiently filled with water." This change results in having to renumber current SRs 4.6.2.1 c and 4.6.2.1 d to SRs 4.6.2.1 d and 4.6.2.1 e, respectively.

(10)

For Unit 2, add a new SR 4.6.2.1 d, which states, "In accordance with the Surveillance Frequency Control Program by verifying containment spray system locations susceptible to gas accumulation are sufficiently filled with water." This change results in having to renumber current SR 4.6.2.1 d to SR 4.6.2.1 e.

(11)

For Unit 1, add SR 4.9.8.1.1, which states, "Verify required shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(12)

For Unit 2, add SR 4.9.8.1 c, which states, "Verify required shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water."

(13)

For Unit 1, add SR 4.9.8.2.1, which states, "Verify shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(14)

• For Unit 2, add SR 4.9.8.2c, which states, "Verify shutdown cooling loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

. (15)

Add and revise the affected TS SR Bases language to state the purpose of the SRs, discuss methods of identifying locations susceptible to gas accumulation, discuss gas volume acceptance criteria, discuss methods for performing the SR consistent with licensee actions and ongoing programs related to GL 2008-01, and describe the SR frequency.

(16)

Add and revise TS LCO Bases language to describe what is required for operability of the sy~tems and to reiterate the importance of gas management.

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRC discussion contained in Task Interface Agreement (TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative to Compliance with Surveillance Requirements (SR) 3.5.1.1, 3.5.2.3, and 3.5.3.1."5 Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRC stated that the intent of the TS SRs, which state "full of water," may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function. Therefore, the phrase, "sufficiently filled with water," was recommended for the proposed TS changes. In the TSs, "sufficiently filled with water" is understood to mean, "sufficiently filled with water to support Operability."

The regulations in 1 O CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the NRC staff finds that the new SR language that states, "Verify the [system name] locations susceptibl~ to gas accumulation are sufficiently filled with water," is acceptable because this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that state that the SR does not have to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Mode 4 is acceptable because the note provides a limited time to perform the Surveillance after entering the Applicability of the LCO. The licensee must have confidence that the SR can be met, or else the licensee must declare the LCO not met.

The language for the notes that allow the SRs to not be met for system vent flow paths opened under administrative control is necessary to allow the licensee to credit administratively controlled manual action to close the system vent flow path in order to maintain system Operability during system venting and performance of the proposed gas accumulation SR.

Therefore, the NRC finds that these notes are acceptable.

The NRC staff found that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCOs will be met. Therefore, the NRC staff finds the proposed change acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the NRC staff notified the State of Florida official (Ms. Cynthia Becker, M.P.H., Chief of the Bureau of Radiation Control, Florida Department of Health) on June 30, 2015, 6 of the proposed issuance of the amendments. The State official had no comments.

5 ADAMS Accession No. ML082560209.

6 The NRC staff notified the State official by telephone and by e-mail. The e-mail is in ADAMS under Accession No. ML15189A457.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in i11dividual or cumulative occupational radiation exposure. The Commission previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on the proposed finding published in the FR on October 28, 2014 (79 FR 64225). Accordingly, the amendments meet 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 need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance ttiat such activities will be conducted in compliance with the Commis~ion's regulations; and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Caroline E. Tilton Date: July 20, 2015

ML15182A160 OFFICE NRR/DORULPL2-2/PM NRR/DORULPL2-2/LA NAME A Klett BClayton DATE 07/08/15 07/08/15 OFFICE OGG (NLO)

NRR/DORULPL2-2/BC NAME BHarris SHelton DATE 07111/15 07116/15