ML17229A358

Application for Amends to Licenses DPR-67 & NPF-16, Incorporating Administrative Changes That Will Improve Consistency Throughout TSs & Related Bases

ML17229A358
Person / Time
Site:	Saint Lucie
Issue date:	05/29/1997
From:	Stall J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17229A359	List: ML17229A358 ML17229A360
References
L-97-134, NUDOCS 9706040201
Download: ML17229A358 (37)

Text

CATEGORY 1 REGULATO~~ INFORMATION DISTRTBUT'ON~iSTEM (RIDS)

ACCESSION NBR:9706040201 DOC.DATE: 97/0'./29 NOTARIZED: YES DOCKET FACIL:50-335 St. Lucie Plant, Un.it 1, Florida Power s Light Co. 05000335 50-3d9 St; Lucie Plant, Unit 2, Florida Power ~ Light Co. 05009389 AU'1'H.NAMF: AUTHOR AFFiLIA7ION

, STALL,J,A. Florida Power 6 Light C~. l REC I P. NAME RECiPIENT AFFILIATION Document Control Branch (Document Control Desk) 1 I

SUBJECT:

Application for amends to licenses DPR-67 a NPF-16, 1 incorporating administrative changes that .will improve C consistency throughout TSs & related Bases.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution 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 0 WIENS,L. 1 1 INTERNAL: ACRS 1 1 R 01 1 1 NRR/DE/ECGB/A 1 1 NRR/DE/EMCB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

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N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US"TO REDUCE WASTE, TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 14 ENCL '13

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Florida Power 5 Light Company, 6501 South Ocean Drive. Jensen Beach, FL 34957 May 29, 1997 L-97-134 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 RE: St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requests to amend Facility Operating License DPR-67 for 'St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2 by incorporating the attached administrative changes. The proposed amendments will improve consistency throughout the Technical Specifications and their related Bases by removing outdated material, incorporating minor changes in text, making editorial corrections, and resolving other inconsistencies identified by the plant operations staff.

It is requested that the proposed amendments, issued by December 31, 1997.

if approved, be Attachment 1 is an evaluation of the proposed changes. Attachment 2 is the "Determination of No Significant Hazards Consideration."

Attachments 3 and 4 contain copies of the affected technical specifications pages marked up to show the proposed changes.

The proposed amendments have been reviewed by the St. Lucie Facility Review Group and the FPL Company Nuclear Review Board. In accordance with'0 CFR 50.91 (b) (1), copies of the proposed amendments are being forwarded to the State Designee for the State of Florida.

Please contact us if there are any questions about this submittal.

Very truly yours, J.A. Stall Vice President @gal(

St. Lucie Plant 9706040201 97052 PDR ADQCK OS00033S PDR lliilliilllglllllllllllllllllllllllllll, an FPi. GrouP comPany

St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Page 2 Proposed License Amendments JAS/RLD Attachments cc: Regional Administrator, Region II, USNRC.

Senior Resident Inspector, USNRC, St. Lucie Plant.

Mr. W.A. Passetti, Florida Department of Health and Rehabilitative Services.

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h+~ e St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Page 3 Proposed License Amendments STATE OF FLORIDA )

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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 a

COUNTY OF + LAC I W Sworn this ~to by J. A.

and subscribed day of Stall, who fA before is personally me known to me.

Signature of A3h W~~

ary Public-State of Florida Lesl10 J. WhltWeII as::as I MY COMMISSION CC646183 EXPIRES "4jv'ij%'NEDTHRUMay 12, 2001 TR0Y FAN ssURAcE, INc, Name of Notary Public (Print, Type, or Stamp)

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St. Lucie Unit 1 and Unit 2 Docket: Nos. 50-335 and 50-389 Proposed License Amendments EVALUATION OF PROPOSED TS CHANGES

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1 i% <<I)I 4 St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos.'0-335 and 50-389 Attachment 1 Proposed License Amendments Page 1 of 16 EVALUATION OF PROPOSED TS CHANGES The proposed amendments to Facility Operating License DPR-67 for St. Lucie Unit 1 (PSL1) and NPF-16 for St. Lucie Unit 2 (PSL2) will improve consistency throughout the Technical Specifications (TS) and their related Bases by removing outdated material, incorporating minor changes in text for purposes of clarification, making editorial corrections, and resolving other inconsistencies identified by the plant operations staff.

Copies 'of the affected TS pages, marked-up to show the proposed changes, are contained in Attachment 3.

a. The following revisions will improve consistency within the PSL1 TS by deleting outdated material, deleting or correcting improper references, and correcting spelling and other typographic errors.

(1) On ~~II: In the HQ~H column of this index, the first section number listed is "3/7.7.2" which contains a typographic error. Rg~ to read, "3/4.7.2."

third line, Zgy~! the improper spelling "concentation" to read "concentration."

the bottom of the page, "63" to read, "M."

pe~

This superseded Amendment No.

typographic error was introduced when the page was re-typed for Amendment 150.

... have been deleted" to read "Pages

' 3/4 6-4

'i'hrough through ... have been deleted." This typographic error was introduced in Amendment 149, i.e., page 3/4 6-3 has

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not been deleted from the TS.

have been deleted"

'to read'" "Pages 3/4 6-22

'f'hrough through ... have been deleted." This typographic error

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(% ~1 0 St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 2 of 16 was introduced in Amendment 149, i.e., Page 3/4 6-20 has not been deleted from the TS.

(6) On In SPECIAL TEST EXCEPTIONS and in the associated statement, 401~ the outdated reference to Specification 3 1 3 2

~ ~ ~ ~ Specification 3.1.3.2, Part Length CEA Insertion Limits, was removed from the TS by Amendment 27.

(7) On EXPLOSIVE GAS MIXTURE to read, "The concentration of oxygen in the waste gas decay tank shall be determined to be within the above limits by continuously monitoring the waste gases in the on-service waste gas decay tank ~ ~

II Specification 3.3.3.10, EXPLOSIVE GAS MONITORING SYSTEM, and associated Table 3.3-13 were deleted from the TS by Amendment 147. The proposed revision to Surveillance 4.11.2.5.1 does not alter the requirement to continuously monitor oxygen in the on-service waste gas decay tank.

(8) On Under the heading in the second line of the first paragraph, gyZj ~ the improper reference to "10 CFR Appendix G" to read, "10 CFR 50, Appendix G." This typographic error was introduced in Amendment 81.

(9) On second

~~: Under the heading paragraph, gjlaZ~ the number "5.3.2" to read

, in the "5.3.1.2." The existing numerical pattern duplicates use of the identifier for original Specification 5.3.2 shown on subsequent page 5-5 under the heading, a K IU !Ltd .

~ ts ~% r St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 3 of 16

b. The following minor changes in text are proposed for the purpose of clarification, and to assure consistent implementation of the stated requirements.

Under BORATION CONTROL, SHUTDOWN MARGIN-Tzpg > 200 Fp , ~Zj ~ the second sentence to read, "If the inoperable CEA is not fully inserted, and is immovable as a result of excessive friction or mechanical interference or is known to be untrippable, the above required SHUTDOWN MARGIN shall be increased by an amount at least equal to the withdrawn worth of the immovable or untrippable CEA(s)."

This surveillance requires the SHUTDOWN MARGIN (SDM) to be determined within one hour after detection of an inoperable CEA(s) and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter while the CEA(s) is inoperable. If one or more CEAs become immovable as a. result of excessive friction or mechanical interference, or known to be untrippable, Specification 3.1.3.1.a prohibits continued reactor operation. The SDM required by TS 3.1.1.1/

4.1.1.1.1 is conservatively increased by an amount at tel since it is likely the affected CEA(s) would not insert on a reactor trip signal. This action, in addition to assuming that the CEA of highest reactivity worth is fully withdrawn per'S 1.29, ensures that adequate shutdown reactivity is available consistent with the safety analyses.

The proposed change in text adds modifiers to the conditions of immovable and untrippable consistent with these same conditions addressed in ACTION 3.1.3.1.a for Movable Control Assemblies/Full Length CEA Position, and makes clear that the specified SDM need not be increased by an additional amount corresponding to the withdrawn worth of the affected CEA(s) if the affected CEA(s) is fully inserted. This revision does not alter the intent of Surveillance 4.1.1.1.1.a and improves consistency within the TS.

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St. Lucie Unit 1 and Unit 2- L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 4 of 16 (2) On In the BORATION SYSTEMS, FLOW PATHS-SHUTDOWN and CHARGING PUMPS-SHUTDOWN read, "... (b) RCS pressure boundary integrity exists and no charging pumps are operable."

Footnote

• was established by Amendment 60 and subsequently modified by Amendments 81, 104, and 141, and provides the plant conditions for which a High Pressure Safety Injection Pump may be used to establish a boration flow path from the Refueling Water Tank to the RCS in MODES 5 and 6. The conditions are based on assumptions and conditions evaluated in the analysis for low temperature over pressure protection (LTOP) and ensure that the LTOP setpoints remain valid. If RCS pressure boundary integrity exists, the additional restrictions on charging pumps, heatup and cooldown rates, and HPSI header isolation valves specified in the footnote are required. If pressure boundary integrity does not exist, as defined in TS 1.16, these restrictions are not required. The proposed revision to part (b) of the footnote provides further clarification that part (b) only applies to the case where RCS pressure boundary integrity exists.

(3) E for FULL LENGTH CEA POSITION to read, "b) The SHUTDOWN MARGIN requirement of Specification 3.1.1.1 is determined at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

gag as a stand-alone statement to "Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> "

Repositioning the text removes an ambiguity from the existing construction in that the required unit transition to HOT STANDBY is required if 3.1.3.1.d.l and 3.1.3.1.d.2 are not met, e.g., the both ACTION statement applies to failure to complete ACTION d as a whole rather than only failure to complete part d.2.b).

This revision is consistent with the corresponding TS 3.1.3.1.f for PSL2. In addition, adding the word "next"

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St . Lucie Unit 1 and Unit 2 L-97-134 Docket Nos . 5 0-3 3 5 and 5 0-3 8 9 Attachment 1 Proposed License Amendments Page 5 of 16 makes clear that the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> action completion time begins upon failure to satisfy ACTION 3.1.3.1.d, and is consistent with NUREG-1432, Revision 1.

(4)

LENGTH CEA POSITION statement, Specification, ~ the stand-alone "Otherwise, be in at'east HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."

Adding the proposed statement ensures that, upon failure to comply with ACTION 3.1.3.1.f, actions will be taken to place the unit in a Mode for which the LCO no longer applies, and without a need to invoke Specification 3.0.3. The action and completion time are consistent with the requirements of NUREG-1432, Revision 1.

(5) /*

to read, "When the flow path from the RWT to the RCS via a single HPSI pump is established per 3.1.2.1 or 3.1.2.3 and RCS pressure boundary integrity exists, the heatup and cooldown rates shall be established in accordance with Fig. 3.1-lb Footnote

• was established by Amendment 81 to support TS 3.1.2.1 and 3.1.2.3. These specifications limit the heatup and cooldown rates per Figure 3.1-1b only for the condition of applicability in which a flow path from the RWT to the RCS via a HPSI pump is established pressure boundary integrity exists. If pressure boundary integrity does not exist as defined in TS 1.16, then Figure 3.1-1b does not apply. The proposed revision to Footnote

• of TS 3.4.9.1 conforms with the requirements provided in TS 3.1.2.1 and 3.1.2.3 for using the referenced Figure 3.1-lb, and thereby removes the existing ambiguity and improves consistency within the facility TS.

St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 6 of 16 (6) On  : Under CONTAINMENT SYSTEMS, VACUUM RELIEF VALVES, Zg~ Specification 3.6.5.1 to read, "The containment vessel to annulus vacuum relief valves The words "less than or equal to" in conjunction with "+

0.25" create an ambiguous syntax. FPL reviewed the vacuum relief valve setpoint calculations, and confirmed that the words "less than or equal to" were not appropriate when considering the nominal design values assumed in the analysis for inadvertent containment spray actuation (Updated Final Safety Analysis Report, Section 6.2). The proposed revision will remove the erroneous phrase introduced in Amendment 90, and make the Specification consistent with the associated Surveillance 4.6.5.1.

(7)

PENETRATIONS, Zey~, Specification 3.9.4.c to read, "Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall- be either:", and Zg~ka condition 3.9.4.c.i to read, "Closed by an isolation valve, blind flange, or manual valve, except for vaZves that are open on an intermittent basis under administrative control or" The referenced Table 3.6-2, CONTAINMENT ISOLATION VALVES, contained a provision (footnote *) for opening certain normally closed valves on an intermittent basis under administrative control. TS Amendment 149, which incorporated the provisions of Generic Letter (GL) 91-08, deleted Table 3.6-2 from the facility TS.

GL 91-08 did not specifically address the Refueling Operations TS 3.9.4. However, it was recognized that the list of containment isolation valves, e.g., Table 3.6-2, typically includes footnotes that modify the TS requirements for these valves and also address operational considerations for specific valves that may

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St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 7 of 16 be opened on an intermittent basis under administrative control. Moreover, GL 91-08 states, "Such notes must be incorporated into the associated LCO so that they will remain in effect when the table containing these footnotes is removed from the TS." The proposed revision to TS 3.9.4 deletes the outdated reference to Table 3.6-2, incorporates the associated provision for intermittent operation of valves under administrative control that was contained in footnote

• to that table, and is consistent with GL 91-08.

CRANE OPERABILITY, 403~ the last sentence of MPH, which states, "The provisions of Specification 3.0.3 are not. applicable.", and gg>~ the last line of to read,

"...cut off when before the crane load exceeds 3000 pounds."

The ACTION statement reference to Specification 3.0.3 is outdated and redundant, i.e., TS 3.9.6 is only applicable during refueling operations and Specification 3.0.3, by definition, is not applicable in this Mode.

TS 3.9.6 requires the manipulator crane overload cut off limit to be s 3000 pounds. The existing Surveillance requires a demonstration of the load cut off "when" the crane load ~~h 3000 pounds. The proposed revision makes Surveillance 4.9.6 consistent with the LCO.

c ~ The following revisions will update the TS Bases as indicated.

(1) On "The specified setpoint provides allowance that there will be sufficient water inventory in the steam required suffi cient time for any operator action to li ini tiate auxi ary feedwater before reactor coolant system subcooling is lost."

~P St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 8 of 16 The revision more accurately reflects the acceptance criteria associated with this reactor trip setpoint which requires that the reactor coolant remain subcooled for the limiting loss of feedwater transients. The revision is consistent with the St. Lucie Unit 1 safety analyses as reported in the Updated Final Safety Analysis Report (UFSAR) .

(2) On y, the Bases to read, "The Rate of Change of Power-High trip is provided to protect the core during startup operations and its use serves as a backup to the administratively enforced startup rate limit.~ ~

System-. The trip is not credited in any design basis accident evaluated in UFSAR Chapter 25g however, the trip is considered in the safety analysis in that the presence of this trip function precluded the need for specific analyses of other events initiated from subcri ti cal condi ti ons. "

The revision more accurately describes the relation between this reactor protection system trip function and the plant safety analyses. The revision is consistent with ABB Combustion Engineering TechNote No. 96-04, issued August 14, 1996, which was confirmed by FPL to be applicable to St. Lucie Unit 1.

(3) On Under the heading Xg~ the second paragraph to read, The restrictions associated with the establishing of the flow path from the RWT to the RCS via a single HPSI pump provide assurance that ZO CFR 50 Appendix G pressure/temperature limits will not be exceeded in the case of any inadvertent pressure transient due to a mass addition to the RCS. If RCS pressure boundary integrity does not exist as defined in Specification 1.26, these restrictions are not required. Additionally, a limit on the maximum number of operable HPSI pumps is not necessary when the pressurizer manway cover or. the reactor vessel head is removed.

St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments

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Page 9 of 16 The revisions provide additional clarification in support of the footnotes associated with TS 3.1.2.1 and 3.1.2.3.

and are consistent with the St. Lucie Unit 1 LTOP analysis. In addition, LTOP events with either the pressurizer manway. cover or the reactor vessel head removed are not credible.

(4) On

~ the following paragraph, "In accordance with Generic Letter 91-08, Removal of Component Lists from the Technical Specifications, the opening of locked or sealed closed containment isolation valves on an intermi ttent basis under admi ni strative control includes the following considerations: (2) stationing an operator, who is in constant communication with the control room, at the valve controls, (2) instructing this operator to close these valves in an accident situation, and (3) assuring that environmental.

conditions will not preclude access to close the valves and that this action wi ll prevent the release of radioactivity outside the containment."

This paragraph supports the proposed revision to TS 3.9.4 (item 1.b(7) of this evaluation), and is consistent with GL 91-08.

END OF PROPOSED TS CHANGES FOR PSL1

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St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 iillioo Proposed License Amendments Page 10 of 16 2 ~

Copies of the affected TS pages, marked-up to show the proposed changes, are contained in Attachment 4.

a. The following revisions will improve consistency within the PSL2 TS by deleting outdated material, deleting or correcting it improper references, and correcting other typographic errors.

ENGINEERING GROUP," and associated subsections, and IZIlmhaZ the subsequent Qg~g to read, "6. W 6.2o3 SHIFT TECHNICAL ADVISOR" The indicated Sections were changed by Amendment 69.

(2) On gL44

~~(: Under 6.5.2 the section, COMPANY NUCLEAR REVIEW BOARD, "TECHNICAL REVIEW RESPONSIBILITIES oo ~ oooo ~ 6 22 This section was added to the TS by Amendment 69.

(3) On ll from "1" to read "2/Train."

This typographic error was made in the original license.

The ECCS area ventilation system is designed with two independent trains and the revision will minimize the potential for an unmonitored noble gas effluent release.

The revision is consistent with the format shown for the corresponding monitors in the PSL1 TS.

through ... have obeeni " " '

deleted" to read "Pages 3/4 6-4 i

through ... have been deleted." This typographic error was introduced in Amendment 88, i.e., page 3/4 6-3 has not been deleted from the TS.

21 through ...

Eo' have been deleted" to read "Pages 3/4 6-22 I

through ... have been deleted." This typographic error was introduced in Amendment 88, i.e., Page 3/4 6-21 has not been deleted from the TS.

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St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 11 of 16 (6) In the word "that."

This grammatical error was introduced by Amendment 39.

(7) On RQKikg EXPLOSIVE GAS MIXTURE to read, "The concentration of oxygen in the waste gas decay tank shall be determined to be within the above limits by continuosly monitoring the waste gases in the on-service waste gas decay tank Specification 3.3.3.10, EXPLOSIVE GAS MONITORING SYSTEM, and associated Table 3.3-13 were deleted from the TS by Amendment 86. The proposed revision to Surveillance 4.11.2.5.1 does not alter the requirement to continuously monitor oxygen in the on-service waste gas decay tank.

b. The following minor changes in text are proposed for the purpose of clarification, and to assure consistent implementation of the stated requirements.

Tzpg GREATER THAN 2 0 0 Fg the second sentence to read, "If the inoperable CEA is not Sully inserted, and is immovable as a result of excessive friction or mechanical interference or is known to be untrippable, the above required SHUTDOWN MARGIN shall be verified acceptable with an increased allowance for the withdrawn worth of the immovable or untrippable CEA(s)."

This surveillance requires the SHUTDOWN MARGIN (SDM) to be determined within one hour after detection of an inoperable CEA(s) and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter while the CEA(s) is inoperable. If one or more CEAs become immovable as a result of excessive friction or mechanical interference, or known to be untrippable, Specification 3.1.3.1.a prohibits continued reactor operation. The SDM required by TS 3.1.1.1/

4.1.1.1.1 is conservatively increased by an amount at thd since it is likely the affected CEA(s) would not insert

St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 12 of 16 on a reactor trip signal. This action, in addition to assuming that the CEA of highest reactivity worth is fully withdrawn per TS 1.29, ensures that adequate shutdown reactivity is available consistent with the safety analyses.

The proposed change in text adds modifiers to the conditions of immovable and untrippable consistent with these same conditions addressed in ACTION 3.1.3.1.a for Movable Control Assemblies/CEA Position, and makes clear that the specified SDM need not be increased by an additional amount corresponding to the withdrawn worth of the affected CEA(s) if the affected CEA(s) is fully inserted. This revision does not alter the intent of Surveillance 4.1.1.1.1.a and improves consistency within the TS.

(2)

POSITION Specification, ~ the stand-alone statement, "Otherwise, he in at least IIOT STANDBY within the next

", and 6'ours.

ZgZig~k the final statement of ML[QH 3.1.3.1.f to read, "Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."

Adding the proposed statement to ACTION 3.1.3.1.e ensures that, upon failure to comply with the ACTION, the unit will be placed in a Mode for which the LCO no longer applies, and without a need to invoke Specification 3.0.3. This statement was inadvertently deleted by Amendment 8. Adding the word "next" to the statement in both cases makes clear that the completion time begins upon failure to satisfy the specified ACTIONS. The action statement, and specified completion time are consistent with requirements of NUREG-1432, Revision 1.

(3)

'~ with an asterisk

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~? to read, "The Reactor Coolant System total flow rate shall be determined to be within its limit by measurement* at least once per 18 months.", and ajar the following footnote:

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St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 13 of 16

• Not required to be performed until THERMAL ONER is z 904 of KLVED THERMAL PCNER.

The surveillance is applicable during operational MODE 1, and the flow rate measurement i.s performed by calorimetric heat balance. The proposed footnote is necessary to allow measurement of the flow rate at normal operating conditions in MODE 1 since the surveillance can not be performed in MODE 2 or below, and will not yield accurate results if performed below 904 of rated thermal power. This revision is consistent with corresponding SR 3.4.1.4 of NUREG-1432, Revision 1, and with corresponding Surveillance 4.2.5.2 of the PSL1 TS.

(4)

RELIEF VALVES, gag~ Specification 3.6.5 to read, "The primary containment vessel to annulus vacuum relief valves shall be OPERABLE with an actuation setpoint of 9.85 + 0.35 inches Water Gauge."

The words "less than or equal to" in conjunction with "+

0.35" create an ambiguous syntax. FPL reviewed the vacuum relief valve setpoint calculations, and confirmed that the words "less than or equal to" were not appropriate when considering the nominal design values assumed in the analysis for inadvertent containment spray actuation (UFSAR, Section 6.2). The proposed revision will remove the erroneous phrase which was introduced in Amendment 60.

(5)

CRANE, read, za~ the last line of to when before the crane load exceeds 3000 pounds."

TS 3.9.6 requires the manipulator crane overload cut off limit to be less than or equal to 3000 pounds. The existing Surveillance requires a demonstration of the load cut off "when" the crane load gzggg~ 3000 pounds.

The proposed revision makes Surveillance 4.9.6 consistent with the LCO.

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~ $ {,1 St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments

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Page 14 of 16 c ~ The following revisions will update the TS Bases as indicated.

in the third paragraph, first sentence, @lang the numerical value of the DNB-SAFDL from 1.20 to 1.28.

The revision updates this Bases section with the

.reference DNBR limit value that is currently used in the Extended Statistical Combination of Uncertainties (ESCU) cycle specific setpoint analyses for PSL2. The reference DNBR limit value of 1.28 in conjunction with ESCU corresponds to a 954 probability at a 954 confidence level that departure from nucleate boiling will not occur during steady state operation, normal operational transients, and anticipated transients. The revision is consistent with the minimum DNBR value reported in the PSL2 UFSAR (Amendment 10, 7/96).

(2) first sentence, phd~ the numerical value of the DNB-SAFDL from 1.20 to 1.28, and Xa~ the third paragraph to read, "The Thermal Margin/Low Pressure trip setpoints are derived from the core safety limits through application of appropriate allowances for equipment response time, measurement uncertainties and processing error. ~zrfety The allowances includes: an variable (power dependent) allowance to compensate for potential power for potential temperature measurement uncertainty; and e measurement error; and an allowance to compensate for the time delay associated with providing effective termination of the occurrence that exhibits the most rapid decrease in margin to the safety limit. The ~

The revision to the DNB-SAFDL numerical value is consistent with the minimum DNBR value. reported in the PSL2 UFSAR (Amendment 10, 7/96), and is discussed in item 2.c.(1) preceding.

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Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 15 of 16 The Thermal Margin/Low Pressure (TM/LP) reactor trip setpoints are verified as part of the cycle-specific setpoint analyses performed for each fuel reload, which is evaluated under 10 CFR 50.59. Individual parameter values may be adjusted, within limits, to optimize analytical and operating margins provided by the setpoints. Removing the numerical values associated with the equipment response time measurement uncertainties and processing errors will preclude the need for unnecessary Bases revisions as a result of minor adjustments that can be made to such values for reload core designs. The revision is consistent with the summary bases statements contained in the PSL1 TS Bases which only describe the types of allowances considered for the TM/LP setpoints.

(3)

Lgz, Zg~ the second sentence to read, "This specified setpoint provides allowance that there will be sufficient water inventory in the steam generator at the time of the trip to provide sufficient time for any operator action 'o initiate auxiliary feedwater before reactor coolant system subcooling is lost."

The revision more accurately reflects the acceptance criteria associated with this reactor trip setpoint which requires that the reactor coolant remain subcooled for the limiting loss of feedwater transients. The revision is consistent with the St. Lucie Unit 2 safety analyses as reported in the UFSAR. I (4) On "The Rate of Change of Power-High trip is provided to protect the core during startup operations and its use serves as a backup to the administratively enforced startup rate limit.

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System . The trip is not credi ted in any design basis accident evaluated in UFSAR Chapter 25g hovever, the trip is considered in the safety analysis in that the presence

St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 16 of 16 of this trip function precluded the need for specific analyses of other events ini ti ated from subcri ti cal condi tions. "

The revision more accurately describes the relation between this reactor protection system trip function and the plant safety analyses. The revision is consistent with ABB Combustion Engineering TechNote No. 96-04, issued August 14, 1996, which was confirmed by FPL to be applicable to St. Lucie Unit 2.

(5) On RhMEXEea numerical value of the minimum DNBR from 1.20 to 1.28.

The revision is consistent with the minimum DNBR value reported in the PSL2 UFSAR (Amendment 10, 7/96), and is discussed in item 2.c.(1) preceding.

The proposed changes will implement minor changes in text to rectify reference, typographic, omission, spelling, and/or consistency-in-format errors. Changes in wording proposed for the Bases Sections rectify errors in stated parameters and/or errors of contradiction in order to more accurately reflect the actual bases for the associated LCOs. The changes are administrative in nature and will improve consistency within the TS for each unit.

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION

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St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 2 Proposed License Amendments Page 1 of 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The proposed amendments will i mprove consistency throughout the Techni cal Specifications and their related Bases hy removing outdated material, incorporating minor changes in text, making editorial corrections, and resolving other inconsistencies identified by the plant operations staff.

Pursuant to 10CFR50.92, a determination may be made that a proposed license amendment involves no significant hazards consideration operation of the facility in accordance with the proposed amendment if 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 consecpxences of an accident previously evaluated.

The proposed amendments consist of administrative changes to the Technical Specifications (TS) for St. Lucie Units 1 and 2. The amendments will . implement minor changes in text to rectify reference, typographic, spelling, and/or consistency-in-format errors; update the TS Bases; and/or otherwise improve consistency within the TS for each unit. The proposed amendments do not involve changes to the configuration or method of operation of plant equipment that is used to mitigate the consequences of an accident, nor do the changes otherwise affect the initial conditions or conservatisms assumed in any of the plant accident analyses. Therefore, operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.

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St. Lucie Unit 1 and Unit 2 L-97-134 Docket Nos. 50-335 and 50-389 Attachment 2 Proposed License Amendments Page 2 of 2 (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 administrative revisions will not change the physical plant or the modes of plant operation defined in the Facility License for each unit. The changes do not involve the addition or modification of equipment nor do they alter the design or operation of plant systems. Therefore, operation of the facility in accordance with the proposed amendments 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 proposed amendments are administrative in nature and do not change the basis for any technical specification that is related to the establishment of, or the preservation of, a nuclear safety margin. Therefore, operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.

Based on the above discussion and the supporting Evaluation of Technical Specification changes, FPL has determined that the proposed license amendments involve no significant hazards consideration.

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments ST ~ LUCZE UNZT 1 MARKED-UP TECHNICAL SPECZFZCATZON PAGES Page VII Page B 2-6 Page B 2-8 Page 3/4 1-1 Page 3/4 1-4 Page 3/4 1-8 Page 3/4 1-12 Page 3/4 1-21 Page 3/4 1-22 Page 3/4 2-9 Page 3/4 4-21 Page 3/4 6-3 Page 3/4 6-20 Page 3/4 6-26 Page 3/4 9-4 Page 3/4 9-6 Page 3/4 10-2 Page 3/4 11-14 Page B 3/4 1-3 Page B 3/4 4-15 Page B 3/4 9-1 Page 5-4