ML17248A379

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Issuance of Amendments to Revise the Renewed Facility Operating Licenses Fire Protection License Conditions (CAC Nos. MF9681 and MF9682; EPID L-2017-LLA-0230)
ML17248A379
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 10/23/2017
From: Perry Buckberg
Plant Licensing Branch II
To: Nazar M
NextEra Energy
Buckberg P, NRR/DORL/LPL2-2, 415-1447
References
CAC MF9681, CAC MF9682, EPID L-2017-LLA-0230
Download: ML17248A379 (30)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 23, 2017 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division Florida Power & Light Co.

Mail Stop: EX/JB 700 Universe Blvd.

Juno Beach, FL 33408

SUBJECT:

ST. LUCIE PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS TO REVISE THE RENEWED FACILITY OPERATING LICENSES FIRE PROTECTION LICENSE CONDITIONS (CAC NOS. MF9681 AND MF9682; EPID L-2017-LLA-0230)

Dear Mr. Nazar:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment Nos. 242 and 193 to Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Unit Nos. 1 and 2, respectively. These amendments consist of changes to the license conditions in response to Florida Power & and Light Company's application dated May 2, 2017.

The amendments revise the St. Lucie Plant, Units Nos. 1 and 2, "Fire Protection" license conditions. The revisions would incorporate new references into these license conditions which propose and approve a revision to plant modifications previously approved in the March 31 ,

2016, NRC issuance of National Fire Protection Association Standard 805 (NFPA 805) license amendments.

A copy of our related safety evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

s7F Perry H. Buckberg, Senior Project Manager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389

Enclosures:

1. Amendment No. 242 to DPR-67
2. Amendment No. 193 to NPF-16
3. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-335 ST. LUCIE PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 242 Renewed License No. DPR-67

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power & Light Company (FPL, the licensee), dated May 2, 2017, 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 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.

Enclosure 1

2. Accordingly, Renewed Facility Operating License No. DPR-67 is amended as indicated in the attachment to this license amendment.
3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/~fir VT~,:;;

Undine Shoop, Chief f Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License Date of Issuance: October 23, 2017

ATTACHMENT TO LICENSE AMENDMENT NO. 242 ST. LUCIE PLANT, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-67 DOCKET NO. 50-335 Revise the Renewed Facility Operating License No. DPR-67 by removing the pages identified below and inserting the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3 3 4 4 6 6

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 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. 242 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 Uncovery 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. ~. 242

E. Fire Protection Florida Power &. Light Company (FPL) St. Lucie Plant Unit 1 shall implement and maintain in effect all provisions ofthe approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated March 22, 2013, and May 2, 2017, and supplements dated June 14, 2013, February 24, 2014, March 25, 2014, April 25, 2014, July 14, 2014, August 27, 2014, September 10, 2014, October 10, 2014, March 10, 2015, April 1, 2015, April 20, 2015, May 12, 2015, August 21, 2015, October 22, 2015, and as approved in the safety evaluations (SE) dated March 31, 2016, and October 23, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be-Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

(a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10-11year (yr) for CDF and less than 1 x 10-8 /yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

Renewed License No. DPR-67 Amendment No. 2J.1., 242

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk informed changes to Florida Power & Light Company fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2) above; (2) The licensee shall implement the modifications to its facility, as described in Table S-1 , "Plant Modifications Committed," Attachment S, of Florida Power & Light letter L-2017-058, dated May 2, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup of SL 1-28 (spring 2018) and SL2-24 (fall 2018) refueling outages after issuance of the SE. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications; and (3) The licensee shall implement the items listed in Attachment S , Table S-2, "Implementation Items," of FPL letter L-2015-211 dated August 21, 2015, with the exception of items 18 and 20, within 12 months after NRC approval unless that falls within a scheduled outage window, then in that case, completion will occur 60 days after startup from that scheduled outage. Implementation Item 18 is an exception because it is associated with modifications in Table S-1 and will be completed in accordance with Transition License Condition 2) above. Item 20 is also an exception because it is required to be completed prior to self-approval and will be completed prior to the startup of SL2-24 (fall 2018).

Renewed License No. DPR-67 Amendment No. ~. 242

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER AND 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. 193 Renewed License No. NPF-16

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power & Light Company (FPL, the licensee), dated May 2, 2017, 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 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.

Enclosure 2

2. Accordingly, Renewed Facility Operating License No. NPF-16 is amended as indicated in the attachment to this license amendment.
3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

~vik?Y Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License Date of Issuance: October 23, 2017

ATTACHMENT TO LICENSE AMENDMENT NO. 193 ST. LUCIE PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-16 DOCKET NO. 50-389 Revise the Renewed Facility Operating License No. NPF-16 by removing the pages identified below and inserting the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3 3 4 4 6 6

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 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 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).

B. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 193 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. 484, 193

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 FPL's 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 April 6, 2023, 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. Antitrust Conditions FPL shall comply with the antitrust conditions in Appendices C and D to this renewed license.

E. Fire Protection Florida Power & Light Company (FPL) St. Lucie Plant Unit 2 shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated March 22, 2013, and May 2, 2017, and supplements dated June 14, 2013, February 24, 2014, March 25, 2014, April 25, 2014, July 14, 2014, August 27, 2014, September 10, 2014, October 10, 2014, March 10, 2015, April 1, 2015, April 20, 2015, May 12, 2015, August 21, 2015, October 22, 2015, and as approved in the safety evaluations (SE) dated March 31, 2016, and October 23, 2017. Except where NRC approval for changes or deviations is required by 1 O CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Renewed License No. NPF-16 Amendment No.~. 4-8.:t-, 193

arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

  • "Fire Alarm and Detection Systems" (Section 3.8);
  • "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);
  • "Gaseous Fire Suppression Systems" (Section 3.1 O); and,
  • "Passive Fire Protection Features" (Section 3.11)

This License Condition does not apply to any demonstration of equivalency under Section 1. 7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC SE dated March 31, 2016, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk informed changes to Florida Power & Light Company fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2) above; (2) The licensee shall implement the modifications to its facility, as described in Table S-1 , "Plant Modifications Committed," Attachment S, of Florida Power & Light letter L-2017-058, dated May 2, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup of SL 1-28 (spring 2018) and SL2-24 (fall 2018) refueling outages after issuance of the SE. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications; and (3) The licensee shall implement the items listed in Attachment S, Table S-2, "Implementation Items," of FPLletterL-2015-211 dated August 21, 2015, with the exception of items 18 and 20, within 1 2 months after NRC approval unless that falls within a scheduled outage window, then in that case, completion will occur 60 days after startup from that scheduled outage. Implementation Item 18 is an exception because it is associated with modifications in Table S-1 and will be completed in accordance with Transition License Condition 2) above. Item 20 is also an exception because it is required to be completed prior to self-approval and will be completed prior to the startup of SL2-24 (fall 2018).

Renewed License No. NPF-16 Amendment No. -1$+, 193

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 242 AND 193 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-67 AND NPF-16 FLORIDA POWER AND LIGHT COMPANY. ET AL.

ST. LUCIE PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-335 AND 50-389

1.0 INTRODUCTION

1.1 Requested Licensing Action By application dated May 2, 2017 (Reference 1), Florida Power & Light Company (hereafter the licensee), submitted a license amendment request (LAR) to change Fire Protection License Condition 3.E. for the St. Lucie Unit Nos. 1 and 2 (hereafter St. Lucie 1 and 2, or Units 1 and 2)

Renewed Facility Operating Licenses (RFOLs). Specifically, the licensee requested to change required plant modifications Table S-1, "Plant Modifications Committed," which is an enclosure to the licensee's letter dated August 21, 2015 (Reference 2). This August 21, 2015, letter is referenced in the transition license conditions included in fire protection related RFOL Amendment Nos. 231 and 181.

1.2 Background On March 22, 2013 (Reference 3), the licensee, submitted a LAR to revise the St. Lucie 1 and 2, fire protection program (FPP) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c). On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC or the Commission) issued Amendment No. 231 to St. Lucie Unit 1 RFOL No. DPR-67 and Amendment 181 to St. Lucie Unit 2 RFOL No. NPF-16 with a corresponding Safety Evaluation (SE) (hereafter March 31, 2016, SE) (Reference 4). The license amendments consisted of changes to the RFOLs to transition the St. Lucie 1 and 2 FPP to a risk-informed (RI), performance-based (PB) (RI/PB) FPP based on National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" (2001 Edition) (NFPA 805) (Reference 5), in accordance with 10 CFR 50.48(c). NFPA 805 allows the use of PB methods such as fire modeling and RI methods such as fire probabilistic risk assessment (FPRA) to demonstrate compliance with the nuclear safety performance criteria.

Enclosure 3

2.0 REGULATORY EVALUATION

2.1 NFPA 805 Fire Protection Program NFPA 805 FPP is a RI and PB program based on the 2001 Edition of NFPA Standard 805. This standard describes the minimum fire protection requirements for a PB FPP utilizing methods, such as fire modeling, and RI methods, such as fire probabilistic risk assessment, to demonstrate compliance with nuclear safety performance criteria.

2.2 Description of Proposed Changes The proposed changes would revise previously approved modifications EC 274451 and EC 274456 as described in Table S-1. The proposed changes are described below:

  • EC 274451: The licensee originally determined that the overflow vent lines for the Unit 1 Diesel Oil Storage Tanks (DOSTs) 1A and 1B were undersized per NFPA 30, "Flammable and Combustible Liquids Code," 1973 edition (Reference 6). The licensee originally proposed to modify the overflow vent lines in order to comply with the standard. The licensee subsequently determined that the modification was not needed because the applicable section of NFPA 30 applies to indoor storage tanks and the Unit 1 DOSTs are located outside.
  • EC 27 4456: The licensee originally determined that the overflow vent lines for the Unit 2 DOSTs 2A and 2B were undersized per NFPA 30, 1973 edition. The licensee originally proposed to modify the overflow vent lines in order to comply with the standard. The licensee subsequently determined that the Unit 2 DOSTs did not comply with NFPA 30 because they did not have a suitable device to prevent overflow. The licensee revised the modification to install an automatic shutoff valve to meet the requirements of NFPA 30.

2.1 Regulatory Review The following regulations address fire protection:

  • Section 50.48(a)(1) of 10 CFR requires that each holder of an operating license, and holders of a combined license issued under Part 52, have a fire protection plan that satisfies General Design Criterion (GDC) 3, "Fire Protection," of Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants."
  • Section 50.48(c) of 10 CFR incorporates NFPA 805 (2001 Edition) by reference, with certain exceptions, modifications, and supplementation. This regulation establishes the requirements for using an RI/PB FPP in conformance with NFPA 805 as an alternative to the requirements associated with 10 CFR 50.48(b) and Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to 10 CFR Part 50, or the specific plant fire protection license condition.

Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the

probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Firefighting systems are designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.

Section 50.48, "Fire protection," of 10 CFR, provides the NRC requirements for nuclear power plant fire protection. The NRC regulations include specific requirements for requesting approval for an RI/PB FPP based on the provisions of NFPA 805.

Section 50.48(a)(1) requires each holder of an operating license, and holders of a combined license issued under Part 52 to have a fire protection plan that satisfies GDC 3 of Appendix A to 10 CFR Part 50 and states that the fire protection plan must describe the overall fire protection program; identify the positions responsible for the program and the authority delegated to those positions; and outline the plans for fire protection, fire detection and suppression capability, and limitation of fire damage. Section 50.48(a)(2) states that the fire protection plan must describe the specific features necessary to implement the program described in paragraph (a)(1) including administrative controls and personnel requirements for fire prevention and manual suppression activities; automatic and manual fire detection and suppression systems; and the means to limit fire damage to structures, systems, and components (SSCs) to ensure the capability to safely shut down the plant. Section 50.48(a)(3) requires that the licensee retain the fire protection plan and each change to the plan as a record until the Commission terminates the license and that the licensee retain each superseded revision of the procedures for 3 years.

Paragraph 50.48(c)(3)(i) of 10 CFR states, in part:

A licensee may maintain a fire protection program that complies with NFPA 805 as an alternative to complying with [10 CFR 50.48(b)] for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979. The licensee shall submit a request to comply with NFPA 805 in the form of an application for license amendment under

§ 50.90. The application must identify any orders and license conditions that must be revised or superseded, and contain any necessary revisions to the plant's technical specifications and the bases thereof.

Pursuant to 10 CFR 50.90, whenever a holder of a license desires to amend the license or permit, an application for an amendment must be filed with the Commission describing the changes desired, and following, as far as applicable, the form prescribed for original applications. Accordingly, a licensee who seeks to amend its NFPA 805 authorizations must file an amendment stating, as applicable, the desired changes to orders, license conditions, and technical specifications.

In addition, 10 CFR 50.48(c)(3)(i) states, in part:

The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that

the licensee has identified orders, license conditions, and the technical specifications that must be revised or superseded, and that any necessary revisions are adequate. Any approval by the Director or the designee must be in the form of a license amendment approving the use of NFPA 805 together with any necessary revisions to the technical specifications.

Paragraph 50.48(c)(3)(ii) of 10 CFR states:

The licensee shall complete its implementation of the methodology in Chapter 2 of NFPA 805 (including all required evaluations and analyses) and, upon completion, modify the fire protection plan required by paragraph (a) of this section to reflect the licensee's decision to comply with NFPA 805, before changing its fire protection program or nuclear power plant as permitted by NFPA 805.

The purpose of 10 CFR 50.48(c)(3)(ii) is explained in the statement of considerations for the Final Rule, "Voluntary Fire Protection Requirements for Light Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative" (69 FR 33536 through 69 FR 33548; June 16, 2004), which states, in part:

This paragraph requires licensees to complete all of the Chapter 2 methodology (including evaluations and analyses) and to modify their fire protection plan before making changes to the fire protection program or to the plant configuration. This process ensures that the transition to an NFPA 805 configuration is conducted in a complete, controlled, integrated, and organized manner. This requirement also precludes licensees from implementing NFPA 805 on a partial or selective basis (e.g., in some fire areas and not others, or truncating the methodology within a given fire area).

Pursuant to 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Under 10 CFR 50.40, common standards for issuance of licenses include considerations of safety and satisfaction of the requirements of the National Environmental Policy Act of 1969 as implemented in 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." Under 10 CFR 50.57(a), to issue an operating license, the Commission must find, among other things, that (1) there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public; (2) there is reasonable assurance that such activities will be conducted in compliance with the regulations in this chapter; and (3) the issuance of the license will not be inimical to the common defense and security or to the health and safety of the public. Additional findings required to issue amendments related to fire protection are provided in 10 CFR 50.48, as discussed below.

The regulations also allow for flexibility that was not included in the NFPA 805 standard.

Licensees who choose to adopt 10 CFR 50.48(c) but wish to use the PB methods permitted elsewhere in the standard to meet the fire protection requirements of NFPA 805, Chapter 3, "Fundamental Fire Protection Program and Design Elements," may do so by submitting a LAR in accordance with 10 CFR 50.48(c)(2)(vii). This regulation further provides:

The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the performance-based approach; (A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).

Alternatively, licensees may choose to use RI or PB alternatives to comply with NFPA 805 by submitting a LAR in accordance with 10 CFR 50.48(c)(4), which states, in part:

The Director of the Office of Nuclear Reactor Regulation, or designee of the Director, may approve the application if the Director or designee determines that the proposed alternatives:

(i) Satisfy the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (ii) Maintain safety margins; and (iii) Maintain fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).

In addition to the conditions outlined by the rule that require licensees to submit a LAR for NRC review and approval in order to adopt an RI/PB FPP, a licensee may submit additional elements of its FPP for which it wishes to receive specific NRC review and approval, as set forth in Regulatory Position C.2.2.1 of Regulatory Guide (RG) 1.205, Revision 1, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants" (Reference 7). Inclusion of these elements in the NFPA 805 LAR is meant to alleviate uncertainty in portions of the current FPP licensing bases as a result of the lack of specific NRC approval of these elements. RGs are not substitutes for regulations, and compliance with them is not required. Methods and solutions that differ from those set forth in RGs will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Commission. Accordingly, any submittal addressing these additional FPP elements needs to include sufficient detail to allow the NRC staff to assess whether the licensee's treatment of these elements meets the 10 CFR 50.48(c) requirements.

The purpose of the FPP established by NFPA 805, is to provide assurance through a defense-in-depth (DID) philosophy, that the NRC's fire protection objectives are satisfied.

NFPA 805 Section 1.2, "Defense-in-Depth," states:

Protecting the safety of the public, the environment, and plant personnel from a plant fire and its potential effect on safe reactor operations is paramount to this standard. The fire protection standard shall be based on the concept of

defense-in-depth. Defense-in-depth shall be achieved when an adequate balance of each of the following elements is provided:

( 1) Preventing fires from starting; (2) Rapidly detecting fires and controlling and extinguishing promptly those fires that do occur, thereby limiting fire damage; and (3) Providing an adequate level of fire protection for structures, systems and components important to safety, so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed.

In addition, in accordance with 10 CFR Part 50, Appendix A, GDC 3, fire detection and fighting systems must be designed such that their rupture or inadvertent operation does not significantly impair the ability of the SSCs important to safety to perform their intended safety functions.

Because the St. Lucie 1 construction permit was issued prior to the publication of 10 CFR Part 50, Appendix A, the St. Lucie 1 design approval for the construction phase was based on the proposed GDC published by the Atomic Energy Commission in the Federal Register (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) describe the St. Lucie 1 GDC. The St. Lucie 1 UFSAR description of GDC 3 reflects design requirements equivalent to those specified in the GDC. Therefore, St. Lucie 1 conforms to the same design standards as St. Lucie 2, which was designed and constructed in compliance with the GDC, as relevant to the

  • evaluation of this LAR.

2.1 Applicable NRC Staff Guidance The NRC staff review also relied on the following additional codes, RGs, and standards:

  • NFPA 30, "Flammable and Combustible Liquids Codes," 1973 Edition (Reference 6),

provides requirements for the safe storage and use of flammable and combustible liquids.

3.0 TECHNICAL EVALUATION

3.1 Fundamental Fire Protection Program Design Elements NFPA 805, Chapter 3 contains the fundamental elements of the FPP and specifies the minimum design requirements for fire protection systems and features.

NFPA 805, Section 3.3.1 includes the requirements for fire prevention for operational activities and states, in part:

The fire prevention program activities shall consist of the necessary elements to address the control of ignition sources and the use of transient combustible materials during all aspects of plant operations.

NFPA 805, Section 3.3.1.2, "Control of Combustible Materials, Sub-section (5) states:

Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

3.2 Flammable and Combustible Liquids NFPA 30, 1973, Section 2348 states:

Tanks storing Class I, Class II and Class lllA liquids inside buildings shall be equipped with a device, or other means shall be provided, to prevent overflow into the building. Suitable devises include, but are not limited to, a float valve, a preset meter on the fill lines, a valve actuated by the weight of the tank contents, a low head pump which is incapable of producing overflow, or a liquid-tight overflow pipe at least one pipe size larger than the fill pipe discharging by gravity back to the outside source of liquid or to an approved location.

3.3 Maintaining Defense-in-Depth and Safety Margins NFPA 805, Section 4.2.4.2, "Use of Fire Risk Evaluation," states:

" ..... use of fire risk evaluation for the performance-based approach shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins."

3.3.1 Defense-in-Depth (DID)

As a supplement to the definition of DID provided in NFPA 805, Section 1.2, the NRG-endorsed guidance in NEI 04-02, Section 5.3.5.2, states, in part:

In general, the defense-in-depth requirement is satisfied if the proposed change does not result in a substantial imbalance in:

  • Preventing fires from starting;
  • Detecting fires quickly and extinguishing those that do occur, thereby limiting fire damage; and
  • Providing adequate level of fire protection for structures, systems and components important to safety, so that a fire that is not promptly extinguished will not prevent essential plant safety functions [from] being performed.

3.3.2 Safety Margins Although not a part of NFPA 805, and thus not required under 10 CFR 50.48(c), NFPA 805, Appendix A, Section A.2.4.4.3, provides the following background related to the meaning of the term "safety margins":

An example of maintaining sufficient safety margins occurs when the existing calculated margin between the analysis and the performance criteria compensates for the uncertainties associated with the analysis and data.

Another way that safety margins are maintained is through the application of codes and standards. Consensus codes and standards are typically designed to ensure such margins exist.

NEI 04-02, Section 5.3.5.3, "Safety Margins," lists two specific criteria that should be addressed when considering the impact of plant changes on safety margins:

  • Codes and standards or their alternatives accepted for use by the NRC are met; and,
  • Safety analysis acceptance criteria in the licensing basis (e.g., FSAR

[Final Safety Analysis Report], supporting analyses) are met, or provides sufficient margin to account for analysis and data uncertainty.

3.4 Discussion As discussed in Section 1.0 of this evaluation, the March 31, 2016, SE implemented the licensee's transition to an RI/PB FPP based on NFPA 805, in accordance with 10 CFR 50.48(c).

Fire Protection License Condition 3.E includes Transition License Conditions that require Table S-1 plant modifications be completed for each unit following issuance of the March 31, 2016, SE, but prior to startup from the Unit 1 spring 2018 refueling outage (SL 1-28) and the Unit 2 fall 2018 refueling outage (SL2-24) respectively.

The proposed changes would revise previously approved modifications EC 274451 and EC 274456 as described in Attachment S, Table S-1. The proposed changes are described below:

  • EC 274451: The licensee originally determined that the overflow vent lines for the Unit 1 DOSTs 1A and 1B were undersized per the NFPA 30, 1973 edition. The licensee originally proposed to modify the overflow vent lines in order to comply with the standard. The licensee subsequently determined that the modification was not needed

because the applicable section of NFPA 30 applies to indoor storage tanks and the Unit 1 DOSTs are located outside.

  • EC 27 4456: The licensee originally determined that the overflow vent lines for the Unit 2 DOSTs 2A and 28 were undersized per the NFPA 30, 1973 edition. The licensee originally proposed to modify the overflow vent lines in order to comply with the standard. The licensee subsequently determined that the Unit 2 DOSTs did not comply with NFPA 30 because they did not have a suitable device to prevent overflow. The licensee revised the modification to install an automatic shutoff valve to meet the requirements of NFPA 30.

3.5 EC 274451: Modify Overflow Vent Lines for Unit 1 DOSTs 1A and 1B In its LAR to adopt NFPA 805, dated March 22, 2013 (Reference 3), the licensee included a modification to the overflow vent lines for the Unit 1 DOSTs 1A and 1B because they were undersized and did not meet the NFPA 30, 1973 edition. The licensee subsequently determined that the modification is not needed because the applicable section of NFPA 30 applies to indoor storage tanks and the Unit 1 DOSTs are located outside. This SE section will evaluate the licensee's proposal to delete this modification.

3.5.1 Risk Evaluation The modification is compliance-based and not included in the FPRA. The proposed deletion of the modification does not involve a change in risk, a change to FPRA models, or a change to accepted FPRA methods and approaches as summarized in the March 31, 2016, SE; therefore, the NRC staff concludes that a risk evaluation is not required.

3.5.2 Defense-in-Depth/Safety Margins The licensee stated that the proposed deletion of the modification complies with NFPA 30, Section 2348 and has no impact on any of the DID echelons, which are to: 1) Prevent fires from starting; 2) Rapidly detect, control and extinguish promptly those fires that do occur, thereby preventing fire damage; and 3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed.

The licensee stated in the LAR that keeping the Unit 1 DOSTs overflow lines "as-is" has no impact on fire prevention, has no impact on the ability to prevent fire damage, and has no impact on the performance of the essential safety functions of the Unit 1 DOSTs.

The licensee also stated in the LAR that adequate safety margins are maintained because the Unit 1 DOSTs are compliant "as-is" with Section 2348 of NFPA 30 and because the change does not impact any safety analysis acceptance criteria used in the licensing basis.

3.5.3 NRC Staff Evaluation In accordance with 10 CFR 50.48(c)(3)(i), the licensee submitted the LAR to revise its NFPA 805 transition License Condition 3.E. The NRC staff reviewed the LAR that included a code compliance discussion as well as discussions of the impact of the proposed change on risk, DID, and safety margins.

NFPA 805, Section 3.3.1.2, "Control of Combustible Materials," Sub-section (5) states:

Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

In Table 9.5A-1 of the licensee's UFSAR, the 1973 edition of NFPA 30 is listed as the code of record used during the original construction of St. Lucie Unit 2. Although not mentioned in Table 9.5A-2 of the Unit 1 UFSAR, as a code of record, on page 9.5A-324, the 1973 edition of NFPA 30 is listed as being applicable to the Unit 1 DOSTs. In addition, in Attachment A of the licensee's application dated March 22, 2013 (Reference 3), the license references a code compliance evaluation that uses the 1973 edition of NFPA 30.

NFPA 30, 1973, Section 2348 states:

Tanks storing Class I, Class II and Class lllA liquids inside buildings shall be equipped with a device, or other means shall be provided, to prevent overflow into the building. Suitable devises include, but are not limited to, a float valve, a preset meter on the fill lines, a valve actuated by the weight of the tank contents, a low head pump which is incapable of producing overflow, or a liquid-tight overflow pipe at least one pipe size larger than the fill pipe discharging by gravity back to the outside source of liquid or to an approved location.

In accordance with NFPA 30, flammable liquids are divided into three categories, Class I flammable liquids, and Class II and Ill combustible liquids. Class I flammable liquids have flashpoints below 100 degrees Fahrenheit (°F). Class II combustible liquids have flashpoints above 100 °F but below 140 °F, and Class Ill combustible liquids have flashpoints above 140 °F.

The flashpoint of diesel fuel is generally between 125 °F and 205 °F which makes diesel fuel a Class II or Ill combustible liquid.

Based on the information provided in the Unit 1 UFSAR, the NRC staff confirmed that Unit 1 DOSTs 1A and 1Bare located outside.

Based on the above, the NRC staff finds that the licensee properly evaluated the proposed change and that because the DOSTs are located outside, the overflow vent lines do not need to be modified to comply with NFPA 30, Section 2348.

In regards to risk, the NRC staff confirmed the proposed change is compliance based and not included in the FPRA and does not involve a change in risk, a change to the PRA models, or changes to accepted FPRA methods and approaches as summarized in the March 2016 SE.

In regards to DID and safety margins, the NRC staff determined that both DID and safety margin do not need to be evaluated because the proposed change is compliance based and not considered a PB approach; therefore, NFPA 805, Section 4.2.4.2 concerning fire risk evaluations (FREs), which requires evaluations of DID and safety margins is not applicable.

3.5.4 Conclusion for Section 3.5 Based on the above evaluation, the NRC staff concludes that the licensee's decision to delete modification EC 274451 is acceptable because the Unit 1 DOSTs 1A and 1Bare code

compliant "as-is" since they are located outside and the NFPA 30 requirement to prevent overflow into a building only applies to tanks that are located inside of buildings. The NRC staff concludes that because the modification is compliance based, is not included in the FPRA, and is not considered a PB approach, that a risk evaluation is not applicable to evaluate acceptability of the proposed change, nor are evaluations of DID and safety margin, which are only required per NFPA 805, Section 4.2.4.2 when a FRE is used.

3.6 EC 274456: Modify Overflow Vent Lines for Unit 2 DOSTs 2A and 2B In its LAR to adopt NFPA 805, dated March 22, 2013 (Reference 3), the licensee included a modification to modify the overflow vent lines for the Unit 2 DOSTs 2A and 2B because they were undersized and did not meet the NFPA 30, 1973 edition. The licensee subsequently decided to install an automatic shutoff valve instead of modifying the overflow vent lines. This SE section will evaluate the licensee's proposal to install an automatic shutoff valve to meet the requirements of NFPA 30.

Because the licensee is changing the proposed modification, the licensee has proposed a change to LAR Attachment S, Table S-1, "Plant Modifications Committed" as follows:

Modification "EC 274456" will be changed to "EC 288671."

Problem Statement, "The overflow vent lines are undersized per NFPA 30 1973 edition,"

will be changed to, "The U2 DOST tanks are nonconforming with NFPA 30 Section 2348 due to not having a suitable device to prevent overflow."

Proposed Modification, "Modify Diesel Oil Storage Tank 2A and 2B Overflow Line Modification," will be changed to, "An automatic shutoff valve will be implemented for use in conjunction with the U2 DOST fill skid."

3.6.1 Risk Evaluation The modification is compliance-based and not included in the FPRA. The revised modification does not involve a change in risk, a change to FPRA models, a change to accepted FPRA methods and approaches as summarized in the March 2016 SE; therefore, the NRC staff concludes that a risk evaluation is not required.

3.6.2 Defense-in-Depth/Safety Margins The licensee stated in the LAR that the proposed revision to the modification complies with NFPA 30, Section 2348 and has no impact on any of the DID echelons, which are to:

1) Prevent fires from starting; 2) Rapidly detect, control and extinguish promptly those fires that do occur, thereby preventing fire damage; and 3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed.

The licensee also stated in the LAR that adding an automatic shutoff valve to the Unit 2 DOSTs fill line has no impact on fire prevention, has no impact on the ability to prevent fire damage, and has no impact on the performance of the essential safety functions of the Unit 2 DOSTs, and that the new valve will be on the outside of the building and only opened to fill the tank.

The licensee also stated in the LAR that adequate safety margins are maintained because the Unit 2 DOSTs modification will be completed to comply with NFPA 30, Section 2348, and because the change does not impact any safety analysis acceptance criteria used in the licensing basis.

3.6.3 NRC Staff Evaluation In accordance with 10 CFR 50.48(c)(3)(i), the licensee submitted the May 2, 2017, LAR to revise its NFPA 805 Transition License Conditions. The NRC staff reviewed the LAR that included a code compliance discussion as well as discussions of the impact of the proposed change on risk, DID, and safety margins.

NFPA 805, Section 3.3.1.2, "Control of Combustible Materials," Sub-section (5) states:

Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

In Table 9.5A-1 of the licensee's Unit 2 UFSAR, the 1973 edition of NFPA 30 is listed as the code of record used during the original construction of St. Lucie Unit 2. Although not mentioned in Table 9.5A-2 of the Unit 1 UFSAR, as a code of record, on page 9.5A-324, the 1973 edition of NFPA 30 is listed as being applicable to the Unit 1 DOSTs. In addition, in Attachment A of the licensee's application dated March 22, 2013 (Reference 3), the license references a code compliance evaluation that uses the 1973 edition of NFPA 30.

NFPA 30, 1973, Section 2348 states:

Tanks storing Class I, Class II and Class lllA liquids inside buildings shall be equipped with a device, or other means shall be provided, to prevent overflow into the building. Suitable devices include, but are not limited to, a float valve, a preset meter on the fill lines, a valve actuated by the weight of the tank contents, a low head pump which is incapable of producing overflow, or a liquid-tight overflow pipe at least one pipe size larger than the fill pipe discharging by gravity back to the outside source of liquid or to an approved location.

In accordance with NFPA 30, flammable liquids are divided into three categories, Class I flammable liquids, and Class II and Ill combustible liquids. Class I flammable liquids have flashpoints below 100 °F. Class II combustible liquids have flashpoints above 100 °F but below 140 °F, and Class Ill combustible liquids have flashpoints above 140°F. The flashpoint of diesel fuel is generally between 125 °F and 205 °F, which makes diesel fuel a Class II or Ill combustible liquid.

Based on the above, the NRC staff finds that the licensee properly evaluated the proposed change and that installing an automatic shutoff valve to the Unit 2 DOSTs fill line is an allowable method of complying with NFPA 30, Section 2348.

In regards to risk, the NRC staff confirmed the proposed change is compliance based and not included in the FPRA and does not involve a change in risk, a change to the PRA models, or changes to accepted FPRA methods and approaches as summarized in the March 2016 SE.

In regards to DID and safety margins, the NRC staff determined that both DID and safety margin do not need to be evaluated because the proposed change is compliance based and not considered a PB approach and, therefore, NFPA 805, Section 4.2.4.2 concerning FREs, which requires evaluations of DID and safety margins is not applicable.

3.6.4 Conclusion for Section 3.6 Based on the above, the NRC staff concludes that the licensee's decision to install an automatic shutoff valve instead of modifying the overflow vent line as a method to comply with NFPA 30, 1973, Section 2348 for the Unit 2 DOSTs is acceptable because such a device is allowed by NFPA 30 as a method to prevent overflow into a building. The NRC staff concludes that because the modification is compliance based, is not included in the FPRA, and is not considered a PB approach, that a risk evaluation is not applicable to evaluate acceptability of the proposed change nor are evaluations of DID and safety margin, which are only required per NFPA 805, Section 4.2.4.2 when a FRE is used.

3.7 Technical Evaluation Summary and Conclusion The NRC staff reviewed the licensee's application to delete Unit 1 modification EC 274451 and to revise Unit 2 modification EC 27 4456. Both modifications are related to preventing overflow of respective DOSTs into buildings and are part of the licensee's RI/PB FPP being implemented in accordance with the requirements of 10 CFR 50.48(c) and NFPA 805. The licensee's application identified revisions to the St. Lucie 1 and 2 license condition as required by 10 CFR 50.48(c)(3)(i). The changes proposed by the licensee included a review of code-compliance, risk, DID, and safety margins. The NRC staff concludes that the licensee's application identified the appropriate license condition that would need to be revised as a result of the proposed changes, and concluded that the proposed revisions are adequate to authorize the proposed FPP changes, thereby satisfying the requirements of 10 CFR 50.48(c)(3)(i).

The NRC staff concludes that both of the licensee's proposed changes are acceptable because the changes are being made in accordance with NFPA 805, Section 3.3.1.2(5) and meet the requirements of NFPA 30, 1973, Section 2348, for preventing overflow from the DOSTs into buildings. The NRC staff also concludes that because the modifications are compliance based, are not included in the FPRA, and are not considered PB approaches, risk evaluations are not applicable to evaluate acceptability of the proposed changes. Nor are evaluations of DID and safety margin applicable, as these are only required per NFPA 805, Section 4.2.4.2 when a FRE is used.

Implementation of the RI/PB FPP under 10 CFR 50.48(c) must be in accordance with the fire protection license condition. The fire protection license condition references the list of modifications and implementation items that must be completed in order to support the NRC staff's conclusion, and establishes a date by which full compliance with 10 CFR 50.48(c) must be achieved. Before the licensee is able to fully implement the transition to an FPP based on NFPA 805 and apply the new fire protection license condition to its full extent, the modifications and implementation items must be completed within the timeframe specified.

4.0 FIRE PROTECTION LICENSE CONDITION In the March 31, 2016, SE (Reference 4), Amendment No. 231 and Amendment No. 181 revised the RFOL Nos. DPR-67 and NPF 16, fire protection license conditions to address the transition to an RI/PB FPP under NFPA 805, in accordance with 10 CFR 50.48(c)(3)(i). The

new license conditions adopted the guidelines of the standard fire protection license condition promulgated in RG 1.205, Revision 1, Regulatory Position C.3.1, as issued on December 18, 2009 (74 FR 67253). Plant-specific changes were made to the sample license condition; however, the plant-specific FPP license conditions are consistent with the standard fire protection license condition and incorporated all of the relevant features of the transition to NFPA 805 at St. Lucie 1 and 2.

In its May 2, 2017, LAR (Reference 1), the licensee requested a license amendment to modify the St. Lucie 1 and 2 Fire Protection License Condition 3. E. The licensee proposed that the license condition be revised to add the May 2, 2017, LAR, to add the issuance date of this SE to the first paragraph under 3.E, and to replace the reference to Table S-1 that was submitted by letter dated August 21, 2015, with a reference to Table S-1 submitted by the May 2, 2017, LAR.

No other changes to the license condition were requested by the licensee or identified by the NRC staff. As described in Sections 3.5 and 3.6 of this SE, the NRC staff reviewed the May 2, 2017, LAR and concludes that the proposed changes are acceptable. Therefore, the NRC staff concludes that the revision of the license conditions, identifying the associated submittal and SE dates, is appropriate and acceptable.

As revised, the first paragraph of St. Lucie 1 and 2 License Condition 3.E, the Fire Protection License Condition, will read as shown below (changes in bold):

Fire Protection Florida Power & Light Company (FPL) St. Lucie Plant Unit 1(2) shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 22, 2013, and May 2, 2017, and supplements dated June 14, 2013, February 24, 2014, March 25, 2014, April 25, 2014, July 14, 2014, August 27, 2014, September 10, 2014, October 10, 2014, March 10, 2015, April 1, 2015, April 20, 2015, May 12, 2015, August 21, 2015, October 22, 2015, and as approved in the safety evaluations (SE) dated March 31, 2016, and October 23, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

As revised, the second of three St. Lucie 1 and 2 Transition License Conditions, within License Condition 3.E, will read as shown below (changes in bold):

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," Attachment S, of Florida Power

& Light letter L 2016 211, dated August 21, 2016 L-2017-058, dated May 2, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) prior to startup of SL 1-28 (spring 2018) and SL2-24 (fall 2018) refueling outages after issuance of the SE. The licensee shall maintain appropriate compensatory measures in place until completion of the modifications; and

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, on August 31, 2017, 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) of the proposed issuance of the amendments. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

These amendments change inspection or surveillance requirements or requirements with respect to installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant change in the types, or significant increase in the amounts, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. By Federal Register notice dated July 5, 2017 (82 FR 31098), the Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on this finding.

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.

7.0 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 that such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

8.0 REFERENCES

1. DeBoer, Daniel, Florida Power & Light Company, letter to U.S. Nuclear Regulatory Commission, "St. Lucie Units 1 and 2, Renewed Facility Operating License Nos. DPR-67 and NPF-16, Docket- Nos. 50-335 and 50-389, Proposed License Amendment, License Amendment Request to Revise the National Fire Protection Association Standard 805 Modifications," May 2, 2017 (ADAMS Accession No. ML17144A294).
2. Costanzo, Christopher, R., Florida Power & Light Company, letter to U.S. Nuclear Regulatory Commission, "St. Lucie Units 1 and 2, Docket Nos. 50-335 and 50-3 89, Response to RAI Regarding LAR for Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)," dated August 21, 2015 (ADAMS Accession No. ML15238B597).
3. Jensen, Joseph, Florida Power & Light Company, letter to U.S. Nuclear Regulatory Commission, "St. Lucie Units 1 and 2, Docket Nos. 50-335 and 50-389, Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," dated March 22, 2013 (ADAMS Accession No ML13088A173).
4. Buckberg, Perry, U.S. Nuclear Regulatory Commission, letter to Nazar, Mano, Nextera Energy, "St. Lucie Plant, Unit Nos. 1 and 2 - Issuance of Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection program in Accordance with Title 1O of the Code of Deferal Regulations Section 50.48(c) (CAC Nos. MF1373 and MF1374),"

March 31, 2016 (ADAMS Accession No. ML15344A346).

5. National Fire Protection Association, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," Standard 805 (NFPA 805), 2001 Edition, Quincy, Massachusetts.
6. National Fire Protection Association, "Flammable and Combustible Liquids Code," Quincy, Massachusetts, Standard 30 (NFPA - 30), 1973.
7. U.S. Nuclear Regulatory Commission, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Regulatory Guide 1.205, Revision 1, December 2009 (ADAMS Accession No. ML092730314).
8. Nuclear Energy Institute, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," NEI 04-02, Revision 2, Washington, DC, April 2008 (ADAMS Accession No. ML081130188).

Principal Contributors: Jay E. Robinson Charles E. Moulton Date: October 23, 2017

SUBJECT:

ST. LUCIE PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS TO REVISE THE RENEWED FACILITY OPERATING LICENSES FIRE PROTECTION LICENSE CONDITIONS (CAC NOS. MF9681 AND MF9682; EPID L-2017-LLA-0230) DATED: OCTOBER 23, 2017 DISTRIBUTION:

PUBLIC RidsNrrDorlLpl2-2 JRobinson, NRR LPL2-2 R/F RidsNrrDssStsb RidsACRS_MailCTR RidsNrrPMStLucie RidsNrrDraAplb RidsNrrLABClayton CMoulton, NRR RidsRgn2MailCenter ADAMS Access1on No.: ML17248A379., BWI ML17248A368 *b1y memoran d um **by e-ma1*1 OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA DRA/APLB/BC* OGC-NLO**

NAME PBuckberg BClayton GCasto A Gosh DATE 09/22/2017 09/13/2017 07/12/2017 09/22/2017 OFFICE DORL/LPL2-2/BC DORL/LPL2-2/PM NAME UShoop PBuckberg DATE 10/23/2017 10/23/2017 OFFICIAL RECORD COPY

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