ML17229A914

Withdraws Proposed TS 5.6.1 Previously Represented as Insert a in Attachment 3 to 981231 Request for Amend to License. Proposed TS in Attachment Suppl Original Submittal,Replacing Insert-A,Attachment 3 & Revises LCO 3.4.9.11 & Bases

ML17229A914
Person / Time
Site:	Saint Lucie
Issue date:	11/25/1998
From:	Stall J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17229A915	List: ML17229A914 ML17229A916
References
L-98-294, TAC-MA0666, TAC-MA666, NUDOCS 9811270119
Download: ML17229A914 (11)

Text

CATEGORY REGULATO Y INFORMATION DISTRIBUTION YSTEM (RIDS)

ACCESSION NBR:9811270119 DOC.DATE: 98/11/25 NOTARIZED: YES DOCKET FACIL:50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH.NAZE '. AUTHOR AFFILIATION STALL,J.A. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Withdraws proposed TS 5.6.1 previously represented as Insert A in attachment 3 to 981231 request for amend to license.

Proposed TS in attachment suppl original submittal, replacing Insert-A,Attachment 3 &, revises LCO 3.4.9.11 & Bases. A DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: T TITLE: OR Submittal: General Distribution E

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 LA 1 PD2-3 PD 1 1 GLEAVES,W 1 1 INTERNAL: ACRS 1 1 FILE CENTER 0 1 1 NRR/DE/ECGB/A" 1 1 NRR 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 NRC PDR 1 1 D

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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Fiorida Powers Light Company,6351 S. Ocean Drive, Jensen Beach, FL 34957 November 25, 1998 L'-',98-294 .

10 CFR 50.90

, PP.IL U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Re: St. Lucie Unit 2 Docket No. 50-389 Proposed License Amendment: SFP Storage Capacity; Soube o o C edi C No MA0666 Su e e Ref: (1) FPL Letter L-97-325, J. A. Stall to,NRC (DCD): Proposed License Amendment, SFP Storage Capacity; Soluble Boron Credit; December 31, 1997.

(2) FPL Letter L-98-132, Rajiv S. Kundalkar to NRC (DCD): Proposed License Amendment:

SFP Storage Capacity; Soluble Boron Credit (TAC No. MA0666), Response to Request for Additional Information; May 15, 1998.

(3) FPL Letter L-98-221, J.A. Stall to NRC (DCD): Proposed License Amendment: SFP'Storage Capacity; Soluble Boron Credit (TAC No. MA0666); Summary of June 18 and July 24, 1998 Teleconferences; September 15, 1998.

Florida Power and Light Company (FPL) requested an amendment to the St. Lucie Unit 2 operating license that would allow an increase in the capacity of the spent fuel pool, in part, by taking credit for a certain soluble boron concentration in the pool coolant (Reference 1). In References 2 and 3, FPL provided additional information to the NRC staff in connection with that amendment request. In telephone conferences held between the NRC staff (Hebdon, et al.) and FPL (Weinkam, et al.) on November 12 and 13, 1998, the staff informed FPL that the Technical Specifications (TS) proposed in Reference 1 should be revised to: (a) relocate the fuel storage pool minimum boron concentration requirements from Section 5.6.1, Design Features-Fuel Storage-Criticality, to a Limiting Conditions for Operation (LCO) section, (b) include required actions in the event that the boron concentration requirement is not met, and (c) include a surveillance requirement to verify the spent fuel storage pool boron concentration is within its limit once per 7 days consistent with the Standard TS for Combustion Engineering Plants (NUREG-1432).

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Accordingly, the proposed TS 5.6.1 previously represented as Insert-A in Attachment 3 to L-97-325 (Reference 1) is withdrawn. As a supplement to the original submittal, the proposed Specifications in the Attachment to this letter replace "Insert-A to L-97-325, Attachment 3," and revise LCO 3/4.9.11 and its associated Bases. These changes do not alter the existing TS requirement for minimum boron concentration in the spent fuel storage pool nor do they change the minimum boron concentration previously proposed in Reference 1. The new proposed Surveillance Requirement 4.9.11.1 provides @)p~

the additional assurance requested by the staff that the required boron concentration will be maintained 'f when irradiated fuel is in the pool. Minor editorial changes to proposed TS 5.6.1 are discussed in Reference 3 and are also included in this supplement.

The changes to the original submittal and contained herein do not alter the statements or conclusions of the No Significant Hazards Consideration evaluation contained in Attachment 2 to Reference 1, and subsequently published in the Federal Register (63 FR 9602, February 25, 1998). The proposed TS changes in the Attachment to this letter have been reviewed by the St. Lucie Facility Review Group and r.~)>r' 9 98ii270ii9 98ii25 I[

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St. Lucie Unit 2 L-98-294 Docket No. 5U-389 Page 2 Proposed License Amendment: SFP Storage Capacity; So ub e o o C ed' o A0666 Su leme the Florida Power 8 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 of Florida.

Finally, in a teleconference on November 16, 1998, the NRC staff requested that FPL document by this letter FPL's intentions relative to the amended 10 CFR 70.24 and 10 CFR 50 which will become effective on December 14, 1998 (63 FR 63127, November 12, 1998). Issuance of an amendment approving the Reference 1 request, as revised herein, will impact the existing exemption from the current 10 CFR 70.24 "CriticalityAccident Requirements" for St. Lucie Unit 2 in that the exemption does not address the criteria for a case where credit is taken for soluble boron in the spent fuel storage pool criticality analysis. The new 10 CFR 50.68 will provide for this case. Please be advised that it is FPL's intention to comply with the provisions of 10 CFR 50.68(b).

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

Very truly yours, J. A. Stall Vice President St. Lucie Plant JAS/RLD Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant Mr. W.A. Passetti, Florida Department of Health and Rehabilitative Services

St. Lucie Unit 2 L-98-294

, Docket No. 50-389 Page 3 Proposed License Amendment: SFP Storage Capacity; Soube o C ed' No MA0666 Su e e 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 Sworn to and subscribed before me this k5 day of &ttdtyi~, 19 by J. A. Stall, who is personally known to me.

of,, Public-State of Florida LeSlie J. VMtWIIII e4'ignature

.sss I MY COMMSSION CC646183 EXPIRES May 12, 2001 BONDED THRU 18Ã FAN NSVRAHCEe l!C.

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

St. Lucie Unit 2

, Docket 50-389 Proposed License Amendment: SFP Storage Capacity; Soube o o C edi C o A0666'Su leme ATTACHMENTto FPL Letter L-98-29

~CIKbllR Description and Bases for Proposed TS Changes (2 pages)

INSERT-A to L-97-325, Attachment 3 (REVISED)

Page IX Page 3/4 9-12 Page B 3/4 9-3

St. Lucie Unit 2 L-98-294 Docket 50-389 Attachment Proposed License Amendment: SFP Storage Capacity; Soube o o C edi AC No MA0666 Su le en This Attachment provides the description of and bases for a supplement to FPL's request for license amendment (Reference 1), and includes the following pages marked-up to show the proposed changes:

(1) o 3  : The changes to this page include the addition of the phrase "as described in Section 9.1 of the Updated Final Safety Analysis Report" to proposed Specifications 5.6.1.a.1 and 5.6.1.a.2; deletion of proposed Specification 5.6.1.a.3 and renumbering proposed Specification 5.6.1.a.4; and correction of a typographic error in the last line of proposed Specification 5.6.1.d by'replacing the word "restrictive" with "reactive."

gaas's: The changes to proposed Specifications 5.6.1.a.1, 5.6.1.a.2, and 5.6.1.d are editorial changes mutually agreed upon by FPL and the NRC staff, and are discussed in FPL Letter L-98-221, September 15, 1998 (Reference 3). The allowance for biases and uncertainties applied to the calculated values of k,are presently documented in the criticality safety analysis for the St. Lucie Unit 2 spent fuel storage rack using soluble boron credit (Reference 1). The Updated Final Safety Analysis Report (UFSAR) section that is referenced by proposed, TS 5.6.1.a.1 and 5.6.1.a.2 will be revised to describe the applicable biases and uncertainties during the next regular UFSAR update pursuant to 10 CFR 50.71(e) following approval of the proposed license amendment.

Deleting the original proposed Specification 5.6.1.a.3 from INSERT-A (Reference 1) prevents duplication of the same requirement for minimum boron concentration in the spent fuel storage pool water which will now appear in the revised TS 3/4.9.11 that is proposed herein.

h I to this LCO that is described below.

(3) a e 3 9-12 TS 3/49 E L V L-S EN FUEL S 0 G OO: This LCO is rewritten to include the required fuel storage pool minimum boron concentration of greater than or equal to 1720 ppm, as well as the existing LCO requirement for minimum water level; provide an ACTION statement for the condition where the boron concentration requirement is not satisfied; and add SURVEILLANCE REQUIREMENT 4.9.11.1 to require verification that the fuel storage pool boron concentration is within its limit at least once per 7 days. In addition, editorial changes are made to the existing ACTION addressing fuel storage pool water level, and in the title of the LCO for the purpose of clariTication. An exclusion from LCO 3.0.3 is added per NUREG-1432. The existing APPLICABILITY is retained, i.e., "Whenever irradiated fuel assemblies are in the spent fuel storage pool."

~Bas': The fuel storage pool minimum boron concentration is currently specified in St. Lucie Unit 2 Specification 5.6.1.a.3. The same specification was retained in the proposed TS 5.6.1.a.3 of Reference

1. In telephone conferences held between the NRC staff (Hebdon, et al.) and FPL (Weinkam, et al.)

on November 12 and 13, 1998, the staff informed FPL that the TS proposed in Reference 1 should be revised to: (a) relocate the fuel storage pool minimum boron concentration requirements from Section 5.6.1, Design Features-Fuel Storage-Criticality, to a Limiting Conditions for Operation (LCO) section, (b) include required actions in the event that the boron concentration requirement is not met, and (c) include a surveillance requirement to verify the fuel storage pool boron concentration is within its limit once per 7 days consistent with the Standard TS for Combustion Engineering Plants (NUREG-1432).

St. Lucie Unit 2 L-98-294 Docket 50-389 Attachment Propqsed License Amendment: SFP Storage Capacity; So o C ed' o MA0666 Su e This supplement relocates the proposed fuel storage pool minimum boron concentration to LCO 3.9.11, and identifies the requirement as TS 3.9.11.b. The limit on soluble boron concentration is consistent with the minimum boron concentration specified for the Refueling Water Tank (RWT), and assures an additional subcritical margin to the value of + which is calculated in the spent fuel storage pool criticality safety analysis to satisfy the acceptance criteria of Specification 5.6.1. Other than being relocated from the Design Features section to an LCO in the TS, the requirement has not been altered, and the revision is simply an administrative change.

The proposed LCO 3.9.11 "ACTION b" addresses the condition where the fuel storage pool boron concentration is not within limit, and is the same action required by NUREG-1432, LCO 3.7.17, i.e., the action requires all movement of fuel assemblies in the fuel storage pool to be immediately suspended and action initiated to restore the boron concentration to within the required limit. To preclude an accident from happening or to mitigate the consequences of an accident in progress, use of the word "immediate" in the required actions is appropriate. Immediately suspending the movement of fuel assemblies, however, does not preclude the movement of fuel assemblies to a safe position.

SURVEILLANCE REQUIREMENT 4.9.11.1 is added to this LCO and requires that the fuel storage pool boron concentration be verified within limit at least once per 7 days. This requirement, as well as more stringent requirements applied during refueling operations, has been established for years in the plant's operating procedures as discussed in Reference 2. Operating experience has shown the verification frequency to be adequate. In addition, Reference 1 describes the basis for concluding that an inadvertent dilution of the spent fuel storage pool by the quantity of unborated water necessary to reduce the specified minimum boron concentration to a value that would invalidate the criticality safety analysis is not a credible event. The proposed surveillance frequency specified for verifying the boron concentration is consistent with NUREG-1432, SR 3.7.17.1, and satisfies, in part, acceptance criteria established by the NRC staff for approval of criticality safety analysis methods crediting soluble boron in the fuel pool water.

To accommodate the proposed soluble boron concentration requirements in LCO 3/4.9.11, the existing Specification 3.9.11 addressing the minimum water level over the top of irradiated fuel assemblies seated in the storage racks is re-stated as Specification 3.9.11.a. The required minimum water level has not been altered from existing requirements and the change is simply one involving format. The format is consistent with other St. Lucie TS that contain multiple requirements.

The existing ACTION for the condition of minimum water level requirement not satisfied is re-stated as LCO 3.9.11 "ACTION a" to accommodate the addition of the new "ACTION b" for boron concentration.

Editorial changes to the syntax are included for clarification and the word "immediately" is added, consistent with NUREG-1432, LCO 3.7.16, ACTION A.1, to ensure that a fuel handling accident would be effectively prevented from occurring. This, however, does not preclude moving a fuel assembly to a safe position.

"ACTION c" is added to make clear that LCO 3.0.3 does not apply. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operation. Therefore, in either case, inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown (Ref: NUREG-1432, LCO 3.7.16 and 3.7.17 Bases).

(4) a 3 -3 S S / 9 Oand3/49 W O SS a mmGEajnl  : This Bases page is updated to include summary statements of the bases or reasons for the specifications involving minimum boron concentration in the fuel storage pool that are being added to LCO 3/4.9.11. The revision is pursuant to 10 CFR 50.36(a).

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St. Lucie Unit 2 L-98-294 Docket 50-889 Attachment Proposed License Amendment: SFP Storage Capacity; So b o o Cred C o M 0666 'u lement INSE to -3 5 ttacbme t 3 ~BE SED 5.6.1 a. The spent fuel pool and spent fuel storage racks shall be maintained with:

A k,<< equivalent to less than 1.0 when flooded with unborated water, including a conservative allowance for biases and Safety'AnaJ.yslfs. Report.

2. A k,<< equivalent to less than or equal to 0.95 when flooded with water containing 520 ppm boron, including a conservative mi p:.!L-.of, tbe':DTdated rr'nel'.":safety:.:"A'n'a~3. aisle~a'r t:r

~3Q A nominal 8.96 inch center-to-center distance between fuel assemblies placed in the storage racks.

5.6.1 b. Fuel placed in Region I of the spent fuel storage racks shall be stored in a configuration that will assure compliance with 5.6.1 a.1 and 5.6.1 a.2, above, with the following considerations:

Fresh fuel shall'ave a nominal average U-235 enrichment of less than or equal to 4.5 weight percent.

2. The reactivity effect of CEAs placed in fuel assemblies may be considered.

3. The reactivity equivalencing effects of burnable absorbers may be considered.

4. The reactivity effects of fuel assembly burnup and decay time may be considered as specified in Figures 5.6-1c through 5 '-1e.

5.6.1 c. Fuel placed in Region II of the spent fuel storage racks shall be placed in a configuration that will assure compliance with 5.6.1 a.l and 5.6.1 a.2, above, with the following considexations:

Fuel placed in Region II shall meet the burnup and decay time requirements specified in Figure 5.6-1a or 5.6-1b.

2. The reactivity effect of CEAs placed in fuel assemblies may be considered.

3. The reactivity equivalencing effects of burnable absorbers may be considered.

s 5.6 ~ 1 d. The new fuel storage racks are designed for dry storage of unirradiated fuel assemblies having a U-235 enrichment less than or equal to 4.5 weight percent, while maintaining a k,<< of less than or equal to 0.98

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INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE RE UIREMENTS SECTION PAGE 3/4.8.2 D- C- SOURCES OPERATING. 3/4 8-10 5 HUTDOWNo o ~ ~ ~ o o r o o o o ~ ~ ~ ~ ~ o o o ~ ~ o ~ 3/4 8"13 3/4.8.3 ONSITE POWER DISTRIBUTION SYSTEMS OPERATING. 3/4 8-14 S HUTDOWN o ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ \ ~ o ~ ~ ~ ~ o ~ ~ ~ ~ ~ o o o ~ ~ ~ o ~ ~ ~ ~ 3/4 8"16 3/4.8. 4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES MOTOR-OPERATED VALVES THERMAL OVERLOAD PROTECTION BYPASS DEVICES....o-.o ..---.- . ~~~ - ~~~~ - ~~~~ - ~ - ~ ~ 3/4 8-17 3/4. 9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION..... - - - - - .. 3/4 9-1 3/4- 9. 2 INSTRUMENTATION 3/4 9-2 3/4. 9.3 DECAY TIME . 3/4 9-3 3/4. 9.4 CONTAINMENT BUILDING PENETRATIONS... 3/4 9-4 3/4. 9.5 COMMUNICATIONS 3/4 9-5 3/4. 9o 6 MANIPULATOR CRANE.. 3/4 9-6 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE POOL BUILDING......... 3/4 9"7 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION HIGH WATER LEVEL. 3/4 9-8 LOW WATER LEVEL....-.-.-....-.-...-.--.-.-...- 3/4 93 3/4. 9. 9 CONTAINMENT ISOLATION SYSTEM...... -....... 3/4 9-10 3/4.9.10 WATER LEVEL - REACTOR VESSEL. 3/4 9-11 3/4.9.11 SPENT FUEL STORAGE POOL. 3/4 9-12 QC+gc- 3/4.9.12 SPENT FUEL CASK CRANE 3/4 9-13 3/4.10 SPECIAL TEST EXCEPTIONS 3/4. 10. 1 SHUTDOWN MARGIN...... 3/4 10-1 3/4.10.2 MODERATOR TEMPERATURE COEFFICIENT, GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS . 3/4 10-2 3/4. 10. 3 REACTOR COOLANT LOOPS 3/4 10-3 3/4. 10. 4 CENTER CEA MISALIGNMENT............. 3/4 10-4 3/4.10.5 CEA INSERTION DURING ITC, MTC, AND POWER COEFFICIENT MEASUREMENTSooooro ~ o ~ ~ o o o o ~ o o o o o ~ o ~ ~ ~ ~ ~ o o 3/4 10-5 ST. LUCIE " UNIT 2 IX