ML17229A159

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Application for Amend to License DPR-67,requesting Mod for Selected cycle-specific Reactor Physics Parameters to Refer to COLR for Limiting Values
ML17229A159
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 12/09/1996
From: Stall J
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17229A160 List:
References
RTR-NUREG-1432 GL-88-16, L-96-298, NUDOCS 9612120449
Download: ML17229A159 (20)


Text

CATEGORY 1

':REUiJLAT  : INFORMATION'DISTRIBUTIONISTEM (RIDE)

P('.CESSION'4~4RA612120449 DOC. DATE: 96/12/09 NOTARIZED: YES DOCKET I FACii:50-"3~35 St. Lucie Plant, Unit 1, Florida Power 6 Light Co. '5000335 AUTH. NAME Ao"1'ECiR AFFILIATION STALL,J';A. Florida Power & 'ght Co.

RECI P. NAME RECIPIENT AFFILIATION CP~~ ~

Document Control Branch (Document Control De sk) its

SUBJECT:

Application for amend to license DPR-67,!;equesting mod for selected cycle-specific reactor physics parameters to refer to COLR for limiting values.

DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution L ENCL l SIZE: 1Q NOTES:

E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 LA 1 1 PD2-3 PD 1 1 WIENS,L. 1 1 0

INTERNAL: ACRS 1 FILE CENTER 1 1 NRR/DE/EMCB 1 ARR DRCH/HICB 1 1 NRR/DSSA/SPLB 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

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TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL .12

Florida Power 5 Light Company, P.O. Box 128, Fort Pierce, FL 34954-0128 L-96-298 December 9, 1996 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment CoreO eratin LimitsRe ort COLR Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requests to amend Facility Operating License DPR-67 for St. Lucie Unit 1 by incorporating the attached Technical Specifications (TS) revisions. The amendment will modify specifications for selected cycle-specific reactor physics parameters to refer to the St. Lucie Unit 1 Core Operating Limits Report (COLR) for limiting values. Minor administrative changes are also included. The proposed TS changes conform to the guidance provided in Generic Letter 88-16 and are consistent with the Standard Technical Specifications for Combustion Engineering Plants (NUREG-1432, Revision 1).

It is requested that the proposed amendment, ifapproved, be issued prior to completion of the current operating Cycle 14, which is scheduled to be completed in October, 1997. is an evaluation of the proposed TS changes. Attachment 2 is the "Determination of No Significant Hazar'ds Consideration." Attachment 3 contains a copy of the affected TS pages marked-up to show the proposed changes. Enclosed is a copy of "St. Lucie Unit 1, Cycle 14 Core Operating Limits Report."

The proposed amendment has been reviewed by the St. Lucie Facility Review Group and the Florida Power & Light Company Nuclear Review Board. In accordance with 10 CFR 50.91 (b)(1), a copy of the proposed amendment is being forwarded to the State Designee for the State ofFlorida.

Please contact us ifthere are any questions about this submittal.

Very truly yours, J. A. Stall Vice President St. Lucie Plant

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St. Lucie Unit 1 L-96-298 Docket No. 50-335 Page 2 of 3 Proposed License Amendment Core 0 eratin LimitsRe ort COLR JAS/RLD Attachments

Enclosure:

St. Lucie Unit 1, Cycle 14 Core Operating Limits Report, Revision 0.

cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC.

Resident Inspector, USNRC, St. Lucie Plant. 'enior Mr. W.A. Passetti, Florida Department of Health and Rehabilitative Services.

s St. Lucie Unit I L-96-298 Docket No. 50-335 Page 3 of3 Proposed License Amendment CoreO eratin LimitsRe ort COLR STATE OF FLORIDA )

) ss.

COUNTY OF ST. LUCIE )

J. A. Stall being first duly sworn, deposes and says:

That he is Vice President, St. Lucie Plant, for the Nuclear Division of Florida Power &, Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.

J. A. Stall STATE OF FLORIDA COUNTYOF >~ LUC L ~

Sworn to and subscribed before me this g day of 19~4 by J. A. Stall, who is personally known to me.

KAREN WEST Signature of Notary Public-State of Florida N C M9%~0N f CC35%$

Apdl 18, 1998

" >>p ~, COh%D THRU TROY FAIN INSURANCE, MtC.

Name of Notary Public (Print, Type, or Stamp)

L f' g I",C'er i 9l ') ~ i "i.'

St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment Core 0 eratin Limits Re ort COLR ATTACHMENT1 EVALUATIONOF PROPOSED TS CHANGES

St. Lucie Unit 1 L-96-298 Docket No. 50-335 Attachment 1 Proposed License Amendment Page 1 of 8 CoreO eratin LimitsRe ort COLR EVALUATIONOF PROPOSED TS CHANGES Introduction The proposed amendment to Facility Operating License DPR-67 for St. Lucie Unit 1 (PSLl) will modify specifications for selected cycle-specific reactor physics parameters to refer to the St. Lucie Unit 1 Core Operating Limits Report (COLR) for limiting values. Minor administrative changes are also included.

The proposed Technical Specification (TS) changes conform to the guidance provided in Generic Letter 88-16 and are consistent with the Standard Technical Specifications for Combustion Engineering Plants (NUREG-1432, Revision 1).

Back round A number of TS address limits associated with reactor physics parameters that are subject to change as a function of reload core design. The methodology for determining such limits for cycle-specific parameters is typically documented in an NRC approved Topical Report or in a plant-specific submittal.

As a consequence, the NRC review of proposed changes to these limits is primarily restricted to confirmation that the updated limits are calculated using an NRC approved methodology and are consistent with all applicable limits of the safety analyses. In order to eliminate the burden that is associated with the process for requesting, reviewing, and approving a license amendment to implement changes to cycle-specific parameter limits, Generic Letter (GL) 88-16 encouraged licensees to propose changes to their technical specifications (TS) that are consistent with the guidance provided in that letter.

Three separate actions to modify the plant's TS are discussed in GL 88-16: (1) adding a definition of a named formal report, e.g., COLR, that includes the values of cycle-specific parameter limits that have been established using an NRC approved methodology and are consistent with all applicable limits of the safety analyses, (2) the addition of an administrative reporting requirement to submit the formal report to the Commission for information, and (3) the modification of individual TS to note that cycle-specific parameters shall be maintained within the limits provided in the defined formal report. The NRC staff noted that it is essential to safety that the plant is operated within the bounds of cycle-specific parameter limits and that a requirement to maintain the plant within the appropriate bounds must be retained in the TS. However, the specific values of these limits may be modified by licensees, without affecting nuclear safety, provided that these changes are determined using an NRC approved methodology and are consistent with all applicable limits of the plant safety analyses that are addressed in the Final Safety Analysis Report (FSAR). The concept of a COLR and the provisions of GL 88-16 were incorporated into the improved Standard Technical Specifications for Combustion Engineering Plants (NUREG-1432).

St. Lucie Unit 1 L-96-298 Docket No. 50-335 Attachment 1 Proposed License Amendment Page 2 of 8 Core 0 eratin LimitsRe ort COLR Descri tion of Pro osed TS Chan es Modifications to individual specifications involve replacing the operating limit with a reference to the COLR, deleting applicable figures which are relocated to the COLR, and making editorial changes for the purpose of clarification. In the following descriptions, text being added is shown in bold italics and text being omitted is shown with strikeout.

Section 1.0 DEFINITIONS 1-2: Add the following definition:

I CORE OPERA TINCr IMITSREPORT COI R L9a The COLR is the unit-specific document t1iat provides cycle specific parameter limits for the current operating reload cycle. Tliese cycle-specific parameter limits sliall be deterniined for each reload cycle in accordance with Specification 6.9.1.11.

Plant operation >uithin t1iese liniits is addressed in individual Specifications.

TS 3.1.1.4 . 3/4 1-5 MODERATOR TEMPERATUI&COEFFICIENT:

Revise the LCO to read, "3.1.1.4 The moderator temperature coefticient (MTC) shall be maintained >vithin the limits specified in the COLR The maximuni positive limitsliall be:"

Delete item c, "

TS 3/4 1.3 1 s 3/4 1-21 1-22 1-23 FULL LENGTH CEA POSITION:

ACTION e: Change final line of this action to read, "... shown in COLR Figure 3.1-1a ."

ACTION f: Change this action to read, "With one full-length CEA misaligned from any other CEA in its group by 15 or more inches beyond the time constraints shown in COLR Figure 3.1-1a, ..."

ACTION f2.a): Change this action to read, "Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the remainder of the CEAs in the group with the inoperable CEA shall be aligned to within 7.5 inches of the inoperable CEA while maintaining the allowable CEA sequence and insertion limits shown on COLR Figure 3.1-2; ..."

SURVEILLANCEREQUIREMENT 4.1.3.1.4: Change the last line of this surveillance to read, "... Dependent Insertion Limit of COLR Figure 3.1-2:"

Delete Figure 3. l-la, "Allowable Time to Realign CEA vs. Initial F,~ "

St. Lucie Unit 1 L-96-298 .

Docket No. 50-335 Attachment 1 Proposed License Amendment Page 3 of S CoreO eratin LimitsRe ort COLR TS 3.1,3.6 s. 3/4 1-28 1-30 REGULATINGCEA INSERTION LIMITS:

'hd I 2 I I II I gldl (regulating CEAs are considered to be fully withdrawn I CCIR~

Change the LCO to read, " 3.1.3.6 The regulating CEA groups shall be limited to the d<<h withdrawn to at least 129.'0 inches) ..." 'hen ACI'ICN .I:R I h I I fll" I,".,I and insertion limits specified in the COLRR ACTION b.1: Revise as follows, "The Short Term Steady State Insertion Limits oFPigare are not exceeded, or "

Delete Figure 3.1-2, "CEA Insertion Limits vs. THERMlALPOWER with 4 Reactor Coolant Pumps Operating" TS3 4,2,1 s 3/42-1throu h2-8 LINEARHEATRATE:

Change the LCO to read, "3.2.1 The linear heat rate shall not exceed the limits shovmmn Figu~~ specified in tlie COLR "

ACTION: Change the third line of the condition statement to read, "...the power dependent control limits of COLR Figure 3.2-2, ..."

'gyp df 'gh~gh SURVEILLANCE REQUIREMENT 4.2.1.3: Change to read, " The excore detector rate by: "

I 4.2.1.3.b: Change the last line to read, "...COLR Figure 3.2-2."

4.2.1.3.c: Change the second line to read, "...limits of COLR Figure 3.2-2, ..."

4.2.1.3.c.2: Change the last line to read, " ...COLR Figure 3.2-3."

'gyyh*df SURVEILLANCE REQUIREMENT 4.2.1.4: Change to read, rale by verifying ..."

I 'gh~h'l " The incore detector 2

4.2.1.4.b: Change the last line to read, " COLR Figure 3.2-1."

Delete FIGURE 3.2-1, "ALLOWABLEPEAK LINEARHEAT RATE VS. BURNUP,"

St. Lucie Unit 1 L-96-298 Docket No. 50-335 Attachment 1 Proposed License Amendment Page 4 of 8 CoreO eratin LimitsRe ort COLR and replace with the statement, "Pages 3/4 2-4 (Ainendinent 106), 3/4 2-5 (Arnendrnent 63), and 3/4 2-6 through 3/42-8 (Aniendinent 109) have been deleterl froni the Technical Specifications. The next page is 3/42-9.

D I PIGUEE .

- . "AXIAL SHAPE INDEX VS. MAXMUMAILUWAELE POWER LEVEL PER SPECIFICATION 4.2.1.3." Delete this page (3/4 2-4) from the TS.

Delete blank pages 3/4 2-5 through 3/4 2-7 from the TS.

Delete FIGURE 3.2-3, "Allowable Combinations of Thermal Power And F,T. Delete this page (3/4 2-8) from the TS.

23 2- T D I Revise the LCO to read, "3.2.3 The calculated value of F,T shall be within the liniilsspecifiedin tlie COLR. "

ACTION: Revise the condition statement to read, "With F, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> either: ... "

~e not ivithin liniits, ACTION b: Revise to read, " Reduce THERMALPOWER to bring the combination of THERMALPOWER and F,Y to within the limits of COLR Figure 3.2-3 and withdraw the full length CEAs to or beyond the Long Term Steady State Insertion Limits of Specification 3.1.3.6. The THERMALPOWER limit determined from COLR Figure 3.2-3 shall then be used to establish a revised upper THERMALPOWER level limit on COLR Figure 3.2-4 (truncate Figure 3.2-4 at the allowable fraction of RATED THERMAL POWER determined by COLR Figure 3.2-3) and subsequent operation shall be maintained within the reduced acceptable operation region of COLR Figure 3.2-4."

TS 3/4 2 5 . 3/4 2-13 2-14 2-15 DNB PAIMMETERS:

SURVEILLANCEREQUIREMENT 4.2.5.2: Modify this surveillance with an asterisk after the word "measurement" and add the following footnote,

  • Notrequired to be perfornied until THE1BL4L POWER is z 90% ofRATED THERiVALPOWER TABLE 3.2-1: For the parameter AXIALSHAPE INDEX, change the associated limit specified in the column labeled "Four Reactor Coolant Pumps Operating" to read, "COLR Figure 3.2-4"

St. Lucie Unit 1 I 96-29S Docket No. 50-335 Attachment 1 Proposed License Amendment Page 5 of 8 Core 0 eratin LimitsRe ort COLR Delete FIGURE 3.2-4, "AXIALSHAPE INDEX Operating Limits With 4 Reactor Coolant Pumps Operating." Delete this page (3/4 2-15) from the TS.

TS 3/4.9.1 . 3/4 9-1 REFUELING OPERATIONS BORON CONCENTRATION:

Revise the LCO as follows: "3.9.1 With the reactor vessel head unbolted or removed, the boron concentration of all fllled portions of the Reactor Coolant System and the refueling cavity shall be maintained ivithin the limit specified in the COLR" a .Either~

ACTION: Revise to read, "With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes and initiate and continue boration at a 40 gpm of 1720 ppm boron or its equivalent to restore boron concentration to >vithin limits." until-K SURVEILLANCEREQUIREMENT 4.9.1.1: Revise the stem of this requirement to read, "%m The boron concentration limit shall be determined prior to: ..."

Bases pages B 3/4 l-l, B 3/4 1-4, B 3/4 2-1, and B 3/4 9-1 are revised to reflect the changes proposed above, as shown in Attachment 3 to this submittal.

Section 6.0 ADMINISTRATIVECONTROLS . 6 -19: Add new administrative control, "6.9.1.11 CORE OPERATING LIMITSREPORT (COLR)" as shown in Insert - B of Attachment 3 to this submittal.

St. Lucie Unit 1 L-96-298 Docket No. 50-335 Attachment 1 Proposed License Amendment Page 6 of 8 CoreO eratin LimitsRe ort COLR Bases for the Pro osed TS Chan es The present limits in the COLR (enclosed with this submittal) are unchanged from those existing in the current TS. However, the proposed amendment will allow Florida Power and Light Company (FPL) to make changes to these parameter limits, as appropriate for a specific reload core design, without the need for a license amendment to update the TS prior to implementation. As discussed in Generic Letter (GL) 88-16, such changes can be made, without affecting nuclear safety, provided such changes are developed using an NRC-approved methodology and the calculated parameter limits are consistent with all applicable plant safety analyses limits.

DEFINITION 1.9a is added to the St. Lucie Unit 1 Technical Specifications to formally define the Core Operating Limits Report (COLR). The COLR willprovide cycle specific reactor physics parameter limits for each current operating reload cycle that are not otherwise retained in individual technical specifications. Accordingly, Limiting Conditions for Operation (LCO) 3.1.1.4, Moderator Temperature Coefficient; 3/4.1.3.1, Full Length CEA Position; 3.1.3.6, Regulating CEA Insertion Limits; 3/4.2.1, Linear Heat Rate; 3.2.3, Total Integrated Radial Peaking Factor; 3/4.2.5, DNB Parameters; and 3/4.9.1, Refueling Operations-Boron Concentration are modified to replace the specific values of cycle-specific parameter limits with the appropriate reference to the formally defined COLR. The affected specifications are also modified, as appropriate, to require that the plant be operated within the bounds of these calculated limits. These changes conform to the guidance in GL 88-16 and are consistent with NUREG-1432.

TS 6.9.1.11 is added to the administrative controls section:

Part "a" requires the cycle specific parameter limits for the above listed LCOs to be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and to be documented in the COLR.

Part "b" requires the analytical methods employed to determine the core operating limits to be those previously reviewed and approved by the NRC, and lists the documents that describe those methods used for St. Lucie Unit 1. The safety analysis methods of Siemens Power Corporation (SPC) and the nuclear design methods of Westinghouse Electric Corporation (W) are used, where appropriate, in defining the specified COLR parameter limits. The safety analyses for reload core designs are performed by SPC. However, the generation of physics input to the safety analyses is accomplished by either SPC using their codes, or by FPL using the W computer codes. FPL's training and competence in the application of the W nuclear design methods to perform core reload design analyses, and performance data demonstrating core physics model verification for St. Lucie Unit 1 are documented in NF-TR-95-01, "Nuclear Physics Methodology for Reload Design of Turkey Point & St. Lucie Nuclear Plants," Florida Power 2 Light Company, January

I III i W

St. Lucie Unit 1 L-96-298 Docket No. 50-335 Attachment I Proposed License Amendment Page 7 of 8 ore eratin Limits Re ort COLR 1995, previously submitted to the NRC under Docket Nos. 50-250 and 50-251 (FPL letter L-95-006, January 17, 1995). The topical report was approved as an acceptable reference in the COLR and associated TS for FPL's Turkey Point Plants (Letter from R.P. Croteau (NRC) to J.H. Goldberg (FPL), TURKEY POINT UNITS 3 AND 4 - ISSUANCE OF AMENDMENTS RE: IMPLEMENTATION OF FPL NUCLEAR PHYSICS METHODOLOGY(TAC NOS. M91393 AND M91394); June 9, 1995). Similarly, FPL desires that NF-TR-95-01 be docketed with the reference methodologies for the St. Lucie Unit 1 COLR, and includes this reference in proposed TS 6.9.1.11.b.2.

Part "c" requires that the core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SHUTDOWN MARGIN, transient analysis limits, and accident analysis limits) of the safety analyses are met.

Finally, Part "d" requires the COLR to be submitted, upon issuance, to the NRC for each reload cycle and for any mid-cycle revisions or supplements thereto.

The proposed administrative control TS 6.9.1.11 conforms to the guidance provided in GL 88-16 and is consistent with the corresponding specification of NUREG-1432.

In addition to the revisions needed to implement the COLR, the following administrative changes are included:

TS 4.2 1 3 xcore Detector Monitorin S stem and 4 2 1 4 Incore Detector Monitorin

~Sstem: The phrase "core power distribution" is replaced with "linear heat rate" to more accurately reflect the parameter addressed by these sur veillance requirements TS 4,2,5.2 NB Parameters-Surveillance Re uirements: This surveillance requires the Reactor Coolant System total flow rate to be determined by measurement at least once per 18 months and is applicable during operational Mode 1. The measurement is performed by calorimetric heat balance. A footnote is added to indicate that the surveillance is not required to be performed until thermal power is s 90% of rated thermal power. The footnote is necessary to allow measurement of the flow rate at normal operating conditions in Mode 1 since the surveillance cannot be performed in Mode 2 or below, and will not yield accurate results ifperformed below 90% of rated thermal power. This provision is consistent with corresponding SR 3.4.1.4 of the Standard Technical Specifications for Combustion Engineering Plants (NUREG-1432, Revision 1).

TS 3.9.1 efuelin 0 erations-Boron Concentration: The existing ACTION requirements include a'statement that, "The provisions of Specification 3.0.3 are not applicable." Since TS 3.0.3 is not applicable in Mode 6 (the applicable mode for TS 3.9.1) by definition, the statement is redundant and is deleted.

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St. Lucie Unit 1 L-96-298 Docket No. 50-335 Attachment 1 Proposed License Amendment Page 8 of 8 CoreO eratin LimitsRe ort COLR Pa es 3/42-5 throu h 3/42-8 willbe deleted &om the TS since these pages will be blank. A note is added to the preceding page, 3/4 2-4, which documents deletion of the affected pages and of pagination.

~i-maintains continuity i h I pg fTS i l4. d b*dl* d, p p d, ih interrupting the page sequence.

Conclusion The proposed changes to the Technical Specifications conform to the guidelines of GL 88-16 to modify TS that have cycle-specific parameter limits. The values of these parameter limits are defined in the COLR. In addition to 10 CFR 50.59, changes to the COLR will be controlled in accordance with the proposed administrative controls in this submittal which require the use of NRC-approved methodologies and require that all applicable limits of the safety analyses are met. The COLR, including any mid-cycle revisions or supplements thereto, shall be provided to the NRC upon issuance, for each reload cycle.

Accounting for plant specific differences in format, the proposed TS changes are consistent with the Standard Technical Specifications for Combustion Engineering Plants. As discussed in Attachment 2 to this submittal, the proposed license amendment does not involve a significant hazards consideration.

St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment CoreO eratin LimitsRe ort COLR ATTACHMENT2 DETERMINATIONOF NO SIGNIFICANTHAZARDS CONSIDERATION

St. Lucie Unit 1 L-96-298 Docket No. 50-335 Attachment 2 Proposed License Amendment Page 1 of2 Core 0 eratin Limits Re ort COLR DETERMINATIONOF NO SIGNIFICANTHAZARDS CONSIDERATION Description ofamendment request: The proposed amendment to Facility Operating License DPR-67 for St. Lucie Unit 1 (PSL1) will modify specifications for selected cycle-specific reactor physics parameters to refer to the St. Lucie Unit 1 Core Operating Limits Report (COLR) for limiting values. Editorial changes are also included for purposes of clarification. The proposed Technical Specification (TS) changes conform to the guidance provided in Generic Letter 88-16 and are consistent with the Standard Technical Specifications for Combustion Engineering Plants (NUREG-1432, Revision 1).

Pursuant to 10 CFR 50.92, a determination may be made that a proposed license amendment involves no significant hazards consideration ifoperation 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. Each standard is discussed as follows:

(1) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment relocates the calculated values of selected cycle-specific reactor physics parameter limits from the TS to the COLR, and includes minor editorial changes which do not alter the intent of stated requirements. The amendment is administrative in nature and has no impact on any plant configuration or system performance relied upon to mitigate the consequences of an accident. Parameter limits specified in the COLR for this amendment are not changed from the values presently required by Technical Specifications. Future changes to the calculated values of such limits may only be made using NRC approved methodologies, must be consistent with all applicable safety analysis limits, and are controlled by the 10 CFR 50.59 process. Assumptions used for accident initiators and/or safety analysis acceptance criteria are not changed by this amendment. Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment relocates the calculated values of cycle specific reactor physics limiting parameters to the COLR and will not change the physical plant or the modes of operation defined in the facility license. The changes do not involve the addition of new equipment or the modification of existing

St. Lucie Unit 1 L-96-298 Docket No. 50-335 Attachment 2 Proposed License Amendment Page 2 of 2 Core 0 eratin LimitsRe ort COLR equipment, nor do they alter the design configuration of St. Lucie plant systems. Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The cycle specific parameter limits being relocated to the COLR by this amendment have not been changed &om the values presently required by the TS, and a requirement to operate the plant within the bounds of the limits specified in the COLR is retained in the individual specifications. Future changes to the calculated values of these limits by the licensee may only be developed using NRC-approved methodologies, must remain consistent with all plant safety analysis limits addressed in the Final Safety Analysis Report (FSAR), and are further controlled by the 10 CFR 50.59 process. As discussed in Generic Letter 88-16, the administrative controls established for the values of cycle specific parameters using the guidance of that letter assure conformance with 10 CFR 50.36. Safety analysis acceptance criteria are not being altered by this amendment. Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

Based on the discussion presented above and on the supporting Evaluation of Proposed TS Changes, FPL has concluded that this proposed license amendment involves no significant hazards consideration.