L-2018-161, License Amendment Request to Allow Performance of Selected Emergency Diesel Generator (EDG) Surveillance Requirements (Srs) During Power Operation

License Amendment Request to Allow Performance of Selected Emergency Diesel Generator (EDG) Surveillance Requirements (Srs) During Power Operation

ML18354A901
Person / Time
Site:	Saint Lucie
Issue date:	12/20/2018
From:	Deboer D Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2018-161
Download: ML18354A901 (41)

Text

oec 2 o2010

• FPL.

U. S. Nuclear Regulatory Commission L-2018-161 10 CFR 50.90 Attn: Document Control Desk Washington DC 20555-0001 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Renewed Facility Operating Licenses DPR-67 and NPF-16 License Amendment Request to Allow Performance of Selected Emergency Diesel Generator (EDG) Surveillance Requirements (SRs) During Power Operation Pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests amendments to Renewed Facility Operating Licenses DPR-67 for St. Lucie Nuclear Plant Unit 1 and NPF-16 for St. Lucie Nuclear Plant Unit 2. The proposed license amendments modify the St. Lucie Unit 1 and St. Lucie Unit 2 Technical Specifications (TS) by allowing the performance of selected Emergency Diesel Generator (EDG) surveillance requirements (SRs) during power operation and by relocating to licensee control, two EDG SRs that are not necessary to demonstrate operability.

The enclosure to this letter provides FPL's evaluation of the proposed changes. Attachment 1 to the enclosure provides the St. Lucie Unit 1 TS pages marked up to show the proposed changes. Attachment 2 provides the St. Lucie Unit 2 marked up TS pages. Attachment 3 provides the existing St. Lucie Unit 1 TS Bases pages marked up to show the proposed changes. Attachment 4 provides the St. Lucie Unit 2 TS Bases marked up pages. The TS Bases changes are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendments.

FPL has determined that the proposed changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and there are no significant environmental impacts associated with the change. The St. Lucie Plant Onsite Review Group (ORG) has reviewed the proposed license amendments. In accordance with 10 CFR 50.91 (b)(1 ), copies of the proposed license amendments are being forwarded to the State designee for the State of Florida.

FPL requests that the proposed changes are processed as a normal license amendment request, with approval within one year of the submittal date. Once approved, the amendments shall be implemented within 90 days.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Michael Snyder, St. Lucie Licensing Manager, at (772) 467-7036.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 2ci"-

__ day of Du e. ('("\ S-e..r 2 0 ) ou I

Sincerely, Daniel D. DeBoer Site Director, St. Lucie Nuclear Plant Florida Power & Light

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Page 2 of 2 Enclosure Attachments cc: USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Nuclear Plant, Units 1 and 2 USNRC Senior Resident Inspector, St. Lucie Nuclear Plant, Units 1 and 2 Ms. Cindy Becker, Florida Department of Health

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 1 of 39 ENCLOSURE Evaluation of the Proposed Changes St. Lucie Nuclear Plant, Units 1 and 2 License Amendment Request to Allow Performance of Selected Emergency Diesel Generator (EDG) Surveillance Requirements during Power Operation 1.0

SUMMARY

DESCRIPTION .............................................................................................................2 2.0 DETAILED DESCRIPTION ..............................................................................................................2 2.1 System Design and Operation .............................................................................................2 2.2 Current Technical Specifications Requirements .................................................................. 3 2.3 Description of the Proposed Changes ................................................................................ .4 2.4 Reason for the Proposed Change ....................................................................................... 6

3.0 TECHNICAL EVALUATION

............................................................................................................6

4.0 REGULATORY EVALUATION

...................................................................................................... 16 4.1 Applicable Regulatory Requirements/Criteria .................................................................... 16 4.2 Precedents ......................................................................................................................... 17 4.3 No Significant Hazards Consideration ............................................................................... 17 4.4 Conclusion .......................................................................................................................... 19

5.0 ENVIRONMENTAL CONSIDERATION

......................................................................................... 19

6.0 REFERENCES

............................................................................................................................... 19 - Proposed Unit 1 Technical Specification Pages (markup) .........................................21 - Proposed Unit 2 Technical Specification Pages (markup) ......................................... 25 - Proposed Unit 1 Technical Specification Bases Pages (markup) ................................ 31 - Proposed Unit 2 Technical Specification Bases Pages (markup) ................................ 35

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 2 of 39 1.0

SUMMARY

DESCRIPTION Florida Power & Light Company (FPL) requests amendments to Renewed Facility Operating Licenses DPR-67 for St. Lucie Nuclear Plant Unit 1 and NPF-16 for St. Lucie Nuclear Plant Unit

2. The proposed license amendments modify the St. Lucie Unit 1 and St. Lucie Unit 2 Technical Specifications (TS} by allowing the performance of selected Emergency Diesel Generator (EDG) surveillance requirements (SRs) during power operation and by relocating to licensee control, two EDG SRs that are not necessary to demonstrate operability.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.1.1 Off-Site Power System The off-site transmission system is designed to provide reliable facilities to accept the electrical output of the plant and to provide off-site power for supplying the plant auxiliary power system for station startup, shutdown, or any time that plant auxiliary power is unavailable. Two separate 230 kV transmission circuits connect the St. Lucie switchyard to the system transmission grid at the Midway substation and a third 230 kV circuit connects to the Treasure substation. These circuits are on three separate transmission lines located parallel to each other.

Each transmission circuit connecting the St. Lucie switchyard and the substations are capable of handling the total plant output of either St. Lucie Unit 1 or Unit 2.

A fourth transmission line connected to the St. Lucie Plant switchyard is located underground from the Turnpike substation. The Turnpike line has been sized to meet the same capabilities of each of the three transmission lines connected to the St. Lucie switchyard. A six bay 230 kV (nominal) switchyard provides switching capability for main generator output, each of two startup transformers per unit, and the four outgoing transmission lines. The main generator supplies electrical power at 22 kV through an isolated phase bus to the two main transformers and two auxiliary transformers. The main transformer steps up the voltage to 230 kV for transmission to the Bay in the switchyard. The auxiliary transformers step down the voltage and feed the units' 6.9 kV bus and 4.16 kV bus. Normal transfer of the 6.9 KV or 4.16 KV buses between the auxiliary transformer and the start-up transformer is performed by Control Room operators. Emergency transfer from the auxiliary to the start-up transformer is automatically initiated by protective relay action. In the event of a complete loss of offsite power (LOOP}, station on-site emergency ac power will be supplied by the on-site emergency diesel generators (EDGs) and station batteries.

2.1.2 On-site Power System The on-site auxiliary power system is designed to supply the functional requirements of all auxiliary loads required for all modes of plant operation. The auxiliary power distribution system distributes the electrical power to plant components through a network of busses, transformers, switches, and related equipment. Plant auxiliary power is distributed throughout the unit by the two 6.9 kV busses and five 4.16 kV busses. Each of the 6.9 kV busses supplies two reactor coolant pump motors and one feedwater pump motor. The 4.16 kV distribution system consists of two normal operation power busses that receive power from the auxiliary or startup transformers, and three emergency busses.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 3 of 39 Depending on plant conditions, the three emergency busses receive power from either the normal 4.16 kV busses or the two standby EDGs.

2.1.3 Emergency Diesel Generator (EOG)

The standby AC power source consists of two redundant, Class 1E, emergency diesel generator sets per Unit [EDGs 1A, and 1B for Unit 1; EDGs 2A, and 2B for Unit 2], each with an air starting system, fuel supply system and automatic control circuitry. Each EDG consists of two diesel engines mounted in tandem with a 3500 kilowatt (kW) [3800 kW for Unit 2] generator coupled directly between the engines. The diesel generator sets supply power to those electrical loads needed to achieve safe shutdown of the plant or to mitigate the consequences of design basis accident in the event of a loss of preferred AC power supplies. In the event of loss of normal sources of power to the onsite power system, each diesel generator set is automatically started and loaded by controls and circuitry that are independent of the controls and circuitry used to start and load the redundant unit. The EDGs have sufficient capacity to supply the minimum necessary engineered safeguards loads with only one generator operating. Local and control room alarms are provided for all conditions causing diesel generator lockout even if a lockout is overridden. Local and control room annunciation are also provided. Analyses demonstrate that both St. Lucie units can successfully withstand and recover from a loss of all offsite and onsite ac power in compliance with the station blackout (SBO) rule, 10 CFR 50.63.

Means are provided for periodic exercising of the diesel generator sets under load when normal bus supply is from the unit auxiliary transformer. If during exercising, normal ac power to the station is lost, the diesel generator breaker will open. After attaining normal frequency and voltage, the diesel generator breaker will close and, assuming normal ac power has been lost, will immediately start all loads belonging to the first block for which "starting required" signals are present from engineered safety features actuation (ESF) signals or from circuit conditions indicating that they were previously running. If normal ac power is still present, the diesel generator breaker will not close but the EDGs will remain at full frequency and voltage until shut down manually.

St. Lucie maintains an Emergency Diesel Generator Reliability Program for monitoring and maintaining EOG performance consistent with 10 CFR 50.65, Maintenance Rule, and the guidelines of Regulatory Guide (RG) 1.155 (Reference 6.1 ). These regulatory guide requirements are satisfied through St.

Lucie Unit 1 and 2 surveillance, administrative and maintenance procedures.

2.2 Current Technical Specifications Requirements TS 3/4.8.1 [Unit 1 and Unit 2] specifies the Limiting Conditions for Operation (LCO),

ACTION(s) and Surveillance Requirements (SRs) for the Electrical Power Systems, AC.

Sources - Operating, for MODES 1, 2, 3 and 4. SR 4.8.1.1.2.e specifies the EDG SRs that may only be performed during plant shutdown, as listed below:

• EDG single-load rejection testing

[SR 4.8.1.1.2.e.2 (Unit 1 and Unit 2)]

• EDG full-load rejection testing

[SR 4.8.1.1.2.e.3 (Unit 2 only)]

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 4 of 39

• EDG LOOP testing

[SR 4.8.1.1.2.e.3 (Unit 1); SR 4.8.1.1.2.e.4 (Unit 2)]

• EDG ESF actuation testing

[SR 4.8.1.1.2.e.4 (Unit 1); SR 4.8.1.1.2.e.5 (Unit 2)]

• EDG ESF actuation with concurrent LOOP testing

[SR 4.8.1.1.2.e.5 (Unit 1); SR 4.8.1.1.2.e.6 (Unit 2)]

• EDG 24-hour endurance testing

[SR 4.8.1.1.2.e.6 (Unit 1); SR 4.8.1.1.2.e.7 (Unit 2)]

• EDG 2000-hour rating verification testing

[sr 4.8.1.1.2.e. 7 (unit 1); SR 4.8.1.1.2.e.8 (Unit 2)]

• EDG simulated restoration of offsite power testing

[SR 4.8.1.1.2.e8 (Unit 1); SR 4.8.1.1.2.e. 9 (Unit 2)]

• EDG test mode override testing

[SR 4.8.1.1.2.e9 (Unit 1); SR 4.8.1.1.2.e.10 (Unit 2)]

• EDG fuel oil transfer pump cross-connection testing

[SR 4.8.1.1.2.e10 (Unit 1); SR 4.8.1.1.2.e.11 (Unit 2)]

• EDG load sequence timer testing

[SR 4.8.1.1.2.e11 (Unit 1); SR 4.8.1.1.2.e.12 (Unit 2)]

• EDG hot restart testing

[SR 4.8.1.1.2.e13 (Unit 2 only)]

2.3 Description of the Proposed Changes 2.3.1 The proposed change deletes the plant shutdown requirement of SR 4.8.1.1.2.e, as indicated below:

SR 4.8.1.1.2.e [Unit 1, Unit 2]

Each diesel generator shall be demonstrated OPERABLE:

e. In accordance with the Surveillance Frequency Control Program dur.'ng shutoovm by:

2.3.2 The proposed change adds a NOTE to the SRs for EDG partial-load rejection testing, EDG full-load rejection testing and EDG 24-hour endurance testing, as indicated below:

SR 4.8.1.1.2.e.2, SR 4.8.1.1.2.e.6 [Unit 1]

SR 4.8.1.1.2.e.2, SR 4.8.1.1.2.e.3, SR 4.8.1.1.2.e. 7 [Unit 2]

---

NO TE --------------------------------------------

Credit may be taken for unplanned events that satisfy this SR.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 5 of 39 The proposed change additionally modifies SR 4.8.1.1.2.e.2 by relocating the numerical value for the single largest post-accident load to licensee control, as indicated below:

SR 4.8.1.1.2.e.2 [Unit 1]

Verifying generator capability to reject a Jead @f greater thaR @r equa!

te 600 hp the single largest post-accident load while maintaining voltage at 4160 .:t. 420 volts and frequency at 60 .:t. 1.2 Hz.

SR 4.8.1.1.2.e.2 [Unit 2]

Verifying generator capability to reject a lead ef g."eater thaR er equa!

te 463 kW the single largest post-accident load while maintaining voltage at 4160 .:t. 420 volts and frequency at 60 .:t. 1.2 Hz.

2.3.3 The proposed change adds a NOTE to the SRs for EDG LOOP testing, EDG ESF actuation testing, EOG ESF actuation coincident with LOOP testing and EOG test mode override testing, as indicated below:

SR 4.8.1.1.2.e.3, SR 4.8.1.1.2.e.4, SR 4.8.1.1.2.e.5 and SR 4.8.1.1.2.e.9 [Unit 1]

SR 4.8.1.1.2.e.4, SR 4.8.1.1.2.e.5, SR 4.8.1.1.2.e.6 and SR 4.8.1.1.2.e.10 [Unit 2]

---

NO TE --------------------------------------------

This Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

The proposed change additionally removes the simulated signal requirement from the SRs to accommodate the proposed NOTE crediting unplanned events.

2.3.4 The proposed change adds a NOTE to the SRs for EDG load sequence timer testing, as indicated below:

SR 4.8.1.1.2.e.11 [Unit 1]

SR 4.8.1.1.2.e.12 [Unit 2]

---

NO TE --------------------------------------------

Th is Surveillance shall not normally be performedin MODE 1 or 2. However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

2.3.5 The proposed change adds a NOTE to the SRs for EOG restoration of offsite power testing, as indicated below:

SR 4.8.1.1.2.e.8 [Unit 1]

SR 4.8.1.1.2.e.9 [Unit 2]

---

NO TE --------------------------------------------

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 6 of 39 This Surveillance shall not normally be performed in MODE 1, 2, 3 or 4.

However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

The proposed change additionally removes the simulated signal requirement from the SRs to accommodate the proposed NOTE crediting unplanned events.

2.3.6 The proposed change relocates to licensee control the SRs for EOG 2000-hour rating verification testing, as indicated below:

SR 4.8.1.1.2.e. 7 [Unit 1]

DELETED V@rifyiFJfJ that ttrn aut@ @)FJFJ@@t@i .'gafis fig FJJt @>f@@@fi tlw 2QQQ lwur ratiFJf} gf 373Q Kw.

SR 4.8.1.1.2.e.8 [Unit 2]

DELETED '.4JF:ifyiFJf} that th@ atJt@ @)FJFJ@@t@i /gafis t@ @a@h di@s@.' f}@FJ@ratgr fig FJJt @X@@@fi th@ 2QQQ hgwr ratiFJf} gf 3fl3@ kW 2.3.7 The proposed change relocates to licensee control the SRs for EOG fuel oil transfer pump cross-connection testing, as indicated below:

SR 4.8.1.1.2.10 [Unit 1 SR 4.8.1.1.2.11 [Unit 2]

DELETED '.4JF:ifyiFJfJ that th@ fli@.' traFJsfcrplimf) traFJsfcrs fli@.' from @a@h fu@.'

st@raf}@ taFJk tg th@ @FJf}iFJ@ ffl)tJFJfoi taFJ,lfs gf @a@h di@s@.' v.ia th@ iFJstaU@fi @FJSS

@RR@ti@R #Res.

2.4 Reason for the Proposed Change The proposed change provides added flexibility in coordinating scheduled work and test activities, thereby potentially reducing plant shutdowns and outage critical path time. The proposed change serves to align the St. Lucie TS more closely with the regulatory guidance of NUREG 1432, Standard Technical Specifications - Combustion Engineering Plants, Volume 1, Specifications (Combustion Engineering STS) (Reference 6.2).

3.0 TECHNICAL EVALUATION

3.1 Deletion of Plant Shutdown Requirement from SR 4.8.1.1.2.e SR 4.8.1.1.2.e [Unit 1, Unit 2]

The proposed change deletes from SR 4.8.1.1.2.e, the restriction on performing the SRs listed under SR 4.8.1.1.2.e during power operation. The proposed change is facilitated by (1) allowing at-power performance of selected SRs listed under SR 4.8.1.1.2.e for the purpose of satisfying required surveillance testing, as discussed in Section 3.2 of this amendment request, (2) allowing at-power performance of selected SRs listed under SR 4.8.1.1.2.e for the purpose of restoring operability, as discussed in Section 3.3, and (3) relocating to licensee control, two SRs listed under SR 4.8.1.1.2.e that are not necessary

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 7 of 39 to demonstrate operability, as discussed in Section 3.4. The basis for the plant shutdown requirement is to prevent unnecessary perturbations to the electrical distribution system during MODES which could challenge steady-state operation and plant safety systems.

Since MODE restrictions are being relaxed, a discussion of the station's response to design basis events during at-power testing is warranted. The most challenging events would be a LOOP, loss of coolant accident (LOCA), or a LOOP coincident with a LOCA, with the EDG under test paralleled to the offsite electrical grid. Each is discussed below:

LOOP Response In MODES 1 and 2, receipt of a LOOP signal with an EDG operating in parallel with off-site power results in the diesel output breaker not immediately tripping and separating the EOG from off-site power. The closed EOG output breaker blocks the under-voltage protective relays that initiate load shed on the associated emergency bus. As the only source of power for loads connected to the emergency (safety) and normal (non-safety) 4.16 kV busses, the EOG under test will likely trip on over-current protection. Tripping on overcurrent protection generates a lockout signal which causes the EOG to shut down and trip open the output breaker. Once the output breaker opens, the load-shed 4.16 kV under-voltage protective relays automatically unblock, detect the loss of voltage, separate the emergency bus from the normal supply bus, and isolate the emergency bus by stripping its loads. During this time, the EDG is prevented from starting and the output breaker is prevented from closing and supplying power to the emergency bus. However within minutes, operators stationed in the vicinity of the EDG would manually reset the lockout relay allowing the EDG to restart, and after reaching nominal frequency and voltage, automatically closing the output breaker. The required safe shutdown loads would then be sequenced onto the emergency bus as designed. The redundant EDG and associated emergency loads would be unaffected by the EDG under test and would respond as designed. As such, the station would remain within its licensing basis in the event of a LOOP with an EDG under test operating in parallel with off-site power.

LOCA Response In MODES 1 and 2, with an EDG operating in parallel with off-site power, a LOCA would generate an ESF actuation signal which would immediately trip the EDG output breaker as well as the reactor, turbine and main generator. The main turbine trip causes a fast bus transfer from the auxiliary to the startup transformer such that the 6.9 kV and 4.16 kV busses are powered from off-site via the startup transformer. Since no loss of voltage is present on the 4.16 kV emergency bus, load shedding is not initiated and the EOG output breaker remains open with its EDG running in standby mode at rated frequency and voltage. All required safety related loads are subsequently connected to the emergency bus powered from the offsite electrical grid. Failure of the EDG output breaker to open and isolate the EDG from the emergency bus when in test mode would not affect LOCA load sequencing since the LOCA response loads would be connected to the emergency bus with total load shared between the EDG and off-site power. The redundant EDG and engineered safeguards actuation equipment train responds similarly to a LOCA signal by starting its EDG and leaving it disconnected from the emergency bus since off-site power is available. As such, the station would remain within its licensing basis in the event of a LOCA with an EDG under test operating in parallel with off-site power.

LOCA Coincident with LOOP Response In MODES 1 and 2, upon receipt of a LOOP preceding a LOCA, the EOG under test responds as addressed in the LOOP discussion above. In MODES 1 and 2, upon receipt of a LOOP following or coincident with a LOCA, there is no impact on proper loading of

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 8 of 39 the EDG under test. The LOCNLOOP signal with an EDG operating in parallel with offsite power results in the EDG output breaker tripping. Due to the LOCNLOOP signal, a trip of the reactor, turbine and main generator occurs. Loss of voltage on the 4.16 kV emergency bus causes it to automatically separate from the normal supply bus and trip its loads. With the EDG running at normal frequency and voltage, its output breaker recloses and commences load sequencing of the emergency loads. After the EDG reaches normal frequency and voltage, its output breaker closes and starts all loads belonging to the first load block. Subsequent loads required to mitigate the LOCA are sequenced back onto the bus in a predetermined order to prevent overloading the EDG.

The redundant EDG and engineered safeguards actuation equipment train will also respond to a LOCNLOOP condition by starting its EDG and shedding the emergency bus loads. As such, the station would remain within its licensing basis in the event a LOCNLOOP signal with an EDG under test operating in parallel with off-site power.

In summary, the occurrence of LOCA with or without a LOOP while an EDG under test is operating in parallel with offsite electrical grid would have no effect on the design basis LOCA response. A LOOP event with an EOG operating in parallel with off-site power could delay the EOG from powering its respective safeguards train. However, plant operators would be stationed in close proximity to restore the EOG capability to power its engineered safeguards equipment train in minutes. In addition, the redundant EDG would be available to power its associated safeguards train. As such, the station would remain within its licensing basis in response to the most challenging design basis event during the at-power EOG testing proposed by this amendment request.

3.2 Allow SR Performance At-Power to Satisfy Required Surveillance Testing The proposed change allows selected EOG SRs to be performed at-power for the purpose of satisfying required surveillance testing. Specifically, the proposed change would allow EOG partial load and full load [Unit 2 only] rejection testing, 24-hour endurance testing and hot restart testing to be performed at-power. The proposed change is based on NUREG 1432, Standard Technical Specifications - Combustion Engineering Plants, Bases (Combustion Engineering STS Bases) (Reference 6.3), which states in a "Reviewers Note" that the MODE restrictions may be deleted if it can be demonstrated that performing the SR in any MODE satisfy the three criteria listed below.

The Combustion Engineering STS Bases provides this "Reviewers Note" for EOG load rejection but not EDG 24-hour endurance testing. However, both SRs are evaluated below in the context of the three criteria. EDG hot restart testing is addressed separately.

1) Performance of the surveillance will not render any safety system or component inoperable; Performing the load rejection or 24-hour endurance run tests at-power would not render any safety system or component inoperable other than the intentional inoperability of the EDG under test. Declaring the tested EOG inoperable allows a relaxation of the single failure criterion for a duration specifically formulated to ensure that the likelihood of an event challenging plant safety is sufficiently low.

Moreover, the duration of load rejection and the 24-hour endurance testing are considerably less than the 14-day completion time allowed by ACTION (b) of TS 3.8.1.1 for an inoperable EDG. Though the EDG would be paralleled to the grid during the at-power testing, the station would remain within its licensing basis in response to the most challenging design basis event, as discussed in Section 3.1. Administrative controls prevent paralleling the redundant EDG to the offsite grid during the testing in order to prevent any disturbances to the electrical system from affecting the availability of emergency ac power. Additional

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 9 of 39 administrative controls prevent such testing during conditions of potential grid disturbances or electrical perturbations. Such controls include procedures which require any EDG paralleled to the offsite grid to be declared inoperable, online risk management risk factors such as inoperable vital equipment, switchyard maintenance, weather conditions, etc., and guarded equipment requirements.

Hence, EDG load rejection or 24-hour endurance run testing at-power would not unintentionally render any safety system or component inoperable.

2) Performance of the surveillance will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or plant systems; The electrical lineup for the 24-hour endurance testing is the same as for the EDG monthly surveillance run required by SR 4.8.1.1.2.a.5, the only difference being the length of time the EDG under test is paralleled to the grid. The 24-hour endurance test will not cause electrical perturbations since the testing involves no simulated signal which disrupts connectivity to the electrical distribution system. Moreover, administrative controls prevent paralleling the redundant EDG to the offsite grid during the testing in order to prevent any disturbances to the electrical system from affecting the availability of emergency ac power. In addition, the station would remain within its licensing basis in response to the most challenging design basis event during the at-power testing, as discussed in Section 3.1. Likewise, performance of the load rejection test will not result in significant disturbances to the electrical distribution system as evidenced by historical load rejection testing during plant shutdowns. Such testing has demonstrated little impact on the plant's electrical system because the voltage perturbation on the bus supplying the loads is not significant and protective instrumentation and relaying exist which mitigate the effects of any disturbances.

In addition, the "Loss of Power" protection instrumentation required by TS 3.3.2.1 (Unit 1) (TS 3.3.2 (Unit 2)] is available to protect plant loads in response to any sustained low grid-voltage condition. Historical testing has also demonstrated that the EDG remains within the allowable voltage and frequency limits, and thereby remains available for future use (i.e. does not trip on overspeed),

consistent with the intent of load rejection testing. Moreover, any significant electrical disturbance resulting from load rejection testing at-power would just as likely occur when testing during shutdown, and historically this has not occurred.

Hence, EOG load rejection and 24-hour endurance testing at-power will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or plant systems.

3) Performance or failure of the SR will not cause or result in an anticipated operational occurrence (AOO) with attendant challenge to plant safety systems.

During at-power performance of EDG load rejection or 24-hour endurance testing, the redundant EDG is available to mitigate AOOs or postulated design basis accidents. As discussed in Section 3.1, the station would remain within its licensing basis in response to the most challenging design basis event during the at-power testing. Any challenge to plant safety systems resulting from EOG 24-hour endurance testing at-power would just as likely occur during the EOG monthly run required by SR 4.8.1.1.2.a.5, which is without MODE restrictions.

Any challenge to plant safety systems resulting from load rejection testing at-power would likely have been observed during shutdown testing, which historically has not occurred. Moreover, any failure on the EDG under test, such

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 10 of 39 as failure of the feeder isolation tie breakers between the normal and emergency busses to open or failure of the EDG output breaker to open or reclose, would not affect the redundant EDG and associated electrical train. Hence, performance or failure of EDG load rejection testing or 24-hour endurance testing at-power will not cause, or result in an AOO with attendant challenge to plant safety systems.

In summary, EDG load rejection testing and 24-hour endurance testing during power operation will not adversely affect plant safety systems or cause significant electrical perturbations thatchallenge plant safety. Thereby, the three "Reviewers Note" criteria of the Combustion Engineering STS Bases (Reference 6.3) are met for removal of the MODE restrictions. The proposed changes to the SRs are discussed below.

3.2.1 EDG Load Rejection Testing SR 4.8.1.1.2.e.2 [Unit 1 and Unit 2]; SR 4.8.1.1.2.e.3 [Unit 2 only]

The subject SR verifies EDG capability to reject at least 600 HP [453 kW for Unit 21 while maintaining 4160 .:!:. 420 volts and 60 .:!:. 1.2 Hz, and [Unit 2 only] reject 3685 kW without tripping or exceeding 4784 volts. The proposed change would allow EDG single-load and full-load rejection testing [Unit 2 only] during power operation for the purpose of satisfying surveillance testing. The proposed change is facilitated by removing the plant shutdown requirement from SR 4.8.1.1.2.e, as discussed in Section 3.1 of this amendment request, such that no restriction on plant MODE would be imposed on SR 4.8.1.1.2.e.2 (Unit 1, Unit 2); and SR 4.8.1.1.2.e.3 (Unit 2 only). Consistent with the Combustion Engineering STS (Reference 6.2), the proposed change adds a NOTE which states that credit may be taken for unplanned events that satisfy the SR.

The purpose of EDG load rejection testing is to demonstrate that the EDG will not be degraded for future application as a result of a load rejection. The rejection testing is successful if the EDG can reject the largest post-accident load [and full post-accident load for Unit 2] without exceeding the allowable voltage and frequency limits and while maintaining a specified margin to the overspeed trip set point. Load rejection testing is typically performed during refueling outages as a part of the Engineered Safeguards Integrated Test. However such testing during power operation does not adversely impact safety. During rejection testing, the EDG is typically synchronized to the grid such that if the EDG breaker were opened (e.g. due to an ESF signal) during the surveillance the offsite circuit would continue to supply the bus loads. As discussed in Section 3.1, the station would remain within its licensing basis in response to the most challenging design basis event during the at-power testing. As discussed in Section 3.2, at-power load rejection testing will not adversely affect plant safety systems or cause significant electrical perturbations that challenge plant safety. During at-power rejection testing, the EDG would be declared inoperable for only a few hours of the 14-day completion time (CT) allotted by TS 3.8.1.1, ACTION (b).

Moreover, the amount of time paralleled to the grid would be less than the EDG's monthly surveillance run, which is not subject to MODE restrictions. Hence, the likelihood of a design basis event during the at-power testing is bounded by the monthly surveillance testing and the 14-day CT. Moreover, administrative controls preclude paralleling the redundant EDG to the offsite grid or performing the rejection testing during periods of grid instability, severe weather, switchyard maintenance, etc. The proposed change differs from SRs 3.8.1.9 and 3.8.1.10 of Combustion Engineering Plants STS (Reference 6.2), which restrict at-power

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 11 of 39 rejection testing except for the purpose of restoring operability. However, consistent with the Combustion Engineering STS Bases (Reference 6.3), the MODE restrictions can be deleted since the three criteria discussed in Section 3.2 are met. The proposed change is also consistent with precedents identified in Section 4.2.1 of this amendment request whereby licensees received amendments allowing rejection testing in MODE 1 or 2 for the purpose of satisfying surveillance testing, and is thereby reasonable.

Relatedly, the proposed change modifies the single-load rejection testing of SR 4.8.1.1.2.e.2 by relocating the numerical value for the single largest post-accident load to licensee control. Specifically, the numerical value of single largest post-accident load will be relocated to the TS Bases whereby future changes will be subject to the regulatory controls of 10 CFR 50.59. No changes are proposed to the method or acceptance criteria for single-load rejection testing. Relocating the numerical value of the single largest load to the TS Bases simply alleviates the need for an amendment request should changes to safety analysis assumptions (e.g. pump efficiency) necessitate a change to the required rejection load. The TS Bases will specify the largest post-accident load (Intake Cooling Water Pump) and the numerical value to be specified in plant test procedures. The proposed change is consistent with SR 3.8.1.9 of Combustion Engineering STS (Reference 6.1 ), which does not specify a numerical value for the required rejection load, and is thereby reasonable.

3.2.2 EDG 24-Hour Endurance Testing SR 4.8.1.1.2.e.6 [Unit 1]; SR 4.8.1.1.2.e.7 [Unit 2]

The subject SR verifies EDG capability to operate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with 3800 kW to 3960 kW for the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 3300 kW to 3500 kW thereafter, and achieving 4160 ::!:. 420 volts and 60 ::!:. 1.2 Hz within 10 seconds and maintaining the steady-state voltage and frequency thereafter. The proposed change would allow the EDG 24-hour endurance run to be performed during power operation for the purpose of satisfying required surveillance testing. The proposed change is facilitated by removing the plant shutdown restriction from SR 4.8.1.1.2.e, as discussed in Section 3.1 of this amendment request, such that no restriction on plant MODE would be imposed on SR 4.8.1.1.2.e.6 for Unit 1 and SR 4.8.1.1.2.e. 7 for Unit 2. Consistent with the Combustion Engineering STS (Reference 6.2), the proposed change adds a NOTE which states that credit may be taken for unplanned events that satisfy the SR The purpose of the 24-hour endurance run is to demonstrate the full load-carrying capability of the EDG for an extended period. Performance of the 24-hour run at-power is reasonable since the EDG is electrically configured the same, i.e. paralleled to offsite power grid, as during the monthly surveillance test required by SR 4.8.1.1.2.a.5, the only difference being the test duration.

Administrative controls ensure that the 24-hour endurance run would not be scheduled during periods of potential grid or bus disturbances such as severe weather conditions or maintenance activities affecting the electrical busses.

During the 24-hour endurance run, the EOG under test would be declared inoperable. However, the remaining EDGs and their support systems would remain operable with sufficient independence from the offsite power grid since no more than one EOG is operated in parallel with the offsite power grid at any time.

As discussed in Section 3.1, the station would remain within its licensing basis in response to the most challenging design basis event during the at-power testing.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 12 of 39 As discussed in Section 3.2, the testing will not adversely affect plant safety systems or cause significant electrical perturbations that challenge plant safety.

The proposed change differs from SR 3.8.1.14 of Combustion Engineering STS (Reference 6.2) which limits the testing to MODE 1 or 2 except for the purpose of restoring operability. The proposed change also differs with the Combustion Engineering STS Bases (Reference 6.3), which does not specify that the MODE restrictions may be removed if the three criteria discussed in Section 3.2 above are satisfied. However the proposed change is consistent with the precedent identified in Section 4.2.1 of this amendment request whereby licensees were granted permission to perform the 24-hour endurance run in MODE 1 or 2 for the purpose of satisfying required surveillance testing, and is thereby reasonable.

3.2.3 EDG Hot Restart Testing SR 4.8.1.1.2.e.13 [Unit 2 only]

The subject SR verifies EOG capability to restart within 5 minutes of shutting down after operating with 3450 kW to 3685 kW for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until temperatures have stabilized. The proposed change would allow the SR to be performed during power operation. The proposed change is facilitated by removing the plant shutdown requirement from SR 4.8.1.1.2.e, as discussed in Section 3.1 of this amendment request, such that no restriction on plant MODE would be imposed on SR 4.8.1.1.2.e.13 (Unit 2 only).

The current restriction on EOG hot restart testing at-power is unreasonable since the SR requires the EOG to be restarted in accordance with SR 4.8.1.1.2.a.4, which is without restriction on plant MODE. Restarting the EOG within 5 minutes of shutting down imposes no added risk to plant safety if performed at-power.

Moreover, the Unit 2 EDGs are water-cooled and maintained at hot standby conditions by means of heated cooling water and lubricating oil. As such, they are not subject to temperature rise transients upon being tripped and thereby are not prone to the restart failures typical of some air-cooled EDGs. Hence hot restart testing at-power is not likely to impact plant equipment or cause unplanned entry into TS ACTIONS. In Reference 6.4, FPL's request to separate hot restart testing from the 24-hour endurance testing requirement was granted.

However, the approved periodicity was based on improving outage critical path flexibility rather than any safety concern. The proposed change is consistent with SR 3.8.1.15 of Combustion Engineering STS (Reference 6.1 }, which does not impose MODE restrictions on EOG hot restart testing, and is thereby reasonable.

3.3 Allow SR Performance At-Power Operation for the Purpose of Restoring Operability The proposed change adds a NOTE to the selected SRs discussed below to allow performance during power operation for the purpose of restoring operability, (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated operability concerns during plant operation). Consistent with the Combustion Engineering STS (Reference 6.2), the NOTE states that the SR is not normally performed during the specified MODES and that an assessment must be completed which determines that plant safety is maintained or enhanced as a result of the restricted MODE testing. Consistent with the Combustion Engineering STS, the NOTE also states that credit may be taken for unplanned events that satisfy the SR. Consistent with Combustion Engineering STS, Bases (Reference 6.3), the proposed change modifies the St. Lucie TS Bases to specify that (1) the assessment must consider the potential outcomes and transients associated with a failed

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 13 of 39 surveillance, a successful surveillance, and a perturbation of the offsite or onsite system when tied together or when operated independently for the surveillance; as well as the operator procedures available to cope with these outcomes, (2) the assessment must be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the surveillance is performed in the normally restricted MODES, and (3) risk insights or deterministic methods may be used for the assessment. The proposed NOTE differs, depending upon the SR, in recognition that at-power performance of the entire SR could, in some cases, adversely impact plant safety. Consistent with the Combustion Engineering STS (Reference 6.2), the proposed NOTE limits performance of these SRs to only those portions of the surveillance needed to verify operability following satisfactory completion of the required assessment. The assessment thereby dictates on case-by-case basis which portions of the SR are necessary and safe for demonstrating operability following maintenance, etc. The proposed changes are as follows:

3.3.1 EDG LOOP Testing SR 4.8.1.1.2.e.3 [Unit 1]; SR 4.8.1.1.2.e.4 [Unit 2]

The SR simulates a LOOP to verify bus deenergization and load shedding, and verify bus re-energization within 10 seconds with the EOG maintaining shutdown loads for greater than 5 minutes at 4160 .:!:. 210 volts and 60 .:!:. 0.6 Hz. The proposed change adds a NOTE which allows portions of the SR to be performed in MODES 1 and 2 for the purpose of restoring operability provided an assessment determines that the safety of the plant is maintained or enhanced.

The NOTE additionally states that credit may be taken for unplanned events that satisfy the SR. To accommodate the NOTE crediting unplanned events, the proposed change makes minor editorial changes which support removal of the simulated signal requirement. The proposed change differs from SR 3.8.1.11 of the Combustion Engineering STS (Reference 6.2), which requires the assessment in MODES 1, 2, 3 and 4. However, the proposed change is consistent with the precedents identified in Section 4.2.2 of this amendment request, which require the assessment only in MODES 1 and 2, and is thereby reasonable.

3.3.2 EDG ESF Actuation Testing SR 4.8.1.1.2.e.4 [Unit 1]; SR 4.8.1.1.2.e.5 [Unit 2]

The subject SR simulates an ESF actuation signal to verify the EOG starts and maintains 4160 .:!:. 420 volts and 60 .:!:. 1.2 Hz within 10 seconds, and maintains 4160 .:!:. 210 volts and 60 .:!:. 0.6 Hz for greater than 5 minutes. The proposed change adds a NOTE which allows portions of the SR to be performed in MODES 1 and 2 for the purpose of restoring operability provided an assessment determines that the safety of the plant is maintained or enhanced. The NOTE additionally states that credit may be taken for unplanned events that satisfy the SR. To accommodate the NOTE crediting unplanned events, the proposed change removes the test signal requirement. The proposed change is consistent with SR 3.8.1.12 of the Combustion Engineering STS (Reference 6.2), which requires the assessment in MODES 1 and 2, and is thereby reasonable.

3.3.3 EOG ESF Actuation w/ Concurrent LOOP Testing SR 4.8.1.1.2.e.5 [Unit 1]; SR 4.8.1.1.2.e.6 [Unit 2]

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 14 of 39 The SR simulates an ESF actuation concurrent with a LOOP signal and verifies that the EOG starts, energizes its bus within 10 seconds and operates shutdown loads for greater than 5 minutes at 4160 .::!:. 210 volts and 60 .::!:. 0.6 Hz. The SR additionally verifies that all EOG trips are bypassed except the engine overspeed and generator differential trips. The proposed change adds a NOTE which allows portions of the SR to be performed in MODES 1 and 2 for the purpose of restoring operability provided an assessment determines that the safety of the plant is maintained or enhanced. The NOTE additionally states that credit may be taken for unplanned events that satisfy the SR. To accommodate the NOTE crediting unplanned events, the proposed change makes minor editorial changes which support removal of the simulated signal requirements. The proposed change differs from SR 3.8.1.19 of the Combustion Engineering STS (Reference 6.2), which requires the assessment in MODES 1, 2, 3 and 4. However, the proposed change is consistent with the precedents identified in Section 4.2.2 of this amendment request, which require the assessment only in MODES 1 and 2, and is thereby reasonable.

3.3.4 EOG Restoration of Offsite Power Testing SR 4.8.1.1.2.e.8 [Unit 1]; SR 4.8.1.1.2.e.9 [Unit 2]

The SR verifies EOG capability to synchronize with and transfer loads to the offsite power source and return to standby status upon a simulated restoration of offsite power. The proposed change adds a NOTE which allows the SR to be performed in MODES 1, 2, 3 and 4 for the purpose of restoring operability provided an assessment determines that the safety of the plant is maintained or enhanced. The NOTE additionally states that credit may be taken for unplanned events that satisfy the SR. To accommodate the NOTE crediting unplanned events, the proposed change removes the simulated signal requirement. The proposed change is consistent with SR 3.8.1.16 of the Combustion Engineering STS (Reference 6.2), which requires the assessment in MODES 1, 2, 3 and 4, and is thereby reasonable.

3.3.5 EOG Test Mode Override Testing SR 4.8.1.1.2.e.9 [Unit 1]; SR 4.8.1.1.2.e.10 [Unit 2]

The SR verifies that with the running EOG in test mode and connected to its emergency bus, an ESF signal energizes loads using offsite power and returns the EOG to standby status. The proposed change adds a NOTE which allows portions of the SR to be performed in MODES 1 and 2 for the purpose of restoring operability provided an assessment determines that the safety of the plant is maintained or enhanced. The NOTE additionally states that credit may be taken for unplanned events that satisfy the SR. To accommodate the NOTE crediting unplanned events, the proposed change removes the simulated signal requirement. The proposed change differs from SR 3.8.1.17 of the Combustion Engineering STS (Reference 6.2), which requires the assessment in MODES 1, 2, 3 and 4. However, the proposed change is consistent with the precedents identified in Section 4.2.2 of this amendment request, which require the assessment only in MODES 1 and 2, and is thereby reasonable.

3.3.6 EOG Load Sequence Timer Testing

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 15 of 39 SR 4.8.1.1.2.e.11 [Unit 1]; SR 4.8.1.1.2.e.12 [Unit 2]

The SR verifies load sequence timer operability by verifying each load block loads within .:!:. 1 second of the design interval. The proposed change adds a NOTE which allows the SR to be performed in MODES 1 and 2 for the purpose of restoring operability provided an assessment determines that the safety of the plant is maintained or enhanced. The NOTE additionally states that credit may be taken for unplanned events that satisfy the SR. The proposed change differs from SR 3.8.1.18 of the Combustion Engineering STS (Reference 6.2), which requires the assessment in MODES 1, 2, 3 and 4. However, the proposed change is consistent with the precedents identified in Section 4.2.2 of this amendment request, which require the assessment only in MODES 1 and 2, and is thereby reasonable.

3.4 Relocate EOG SRs Not Necessary to Demonstrate Operability The proposed change relocates to licensee control, two SRs listed under SR 4.8.1.1.2.e that are unnecessary to demonstrate operability. Specifically, the surveillances will be relocated to plant procedural control whereby future changes will be subject to the regulatory controls of 10 CFR 50.59. 10 CFR 50.36( c)(3) defines SRs as requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met. The SRs proposed for relocation concern design attributes, verified during pre-operational or post-modification testing, that cannot adversely impact plant safety analysis assumptions without physical change to the station. As such, the SRs are not necessary to demonstrate operability, as discussed below:

3.4.1 EDG 2000-Hour Rating Verification Testing at 3760 kW SR 4.8.1.1.2.e.7 [Unit 1]; SR 4.8.1.1.2.e.8 [Unit 2]

The SR verifies that the auto-connected loads do not exceed the EDG's 2000-hour/year rating of 3730 kW [3935 kW for Unit 2]. The proposed change relocates the SR to licensee control. The SR is conducted during safeguards testing by recording the total loading on the EDG during the first minute following a simulated LOOP coincident with an ESF signal. The SR derives from NRC Safety Guide 9, Selection of Diesel Generator Set Capacity for Standby Power Systems (Reference 6.6), which states that during the operating license stage of review, the predicted loads should be verified not to exceed the 2000-hour rating.

This sizing recommendation was not incorporated for periodic testing into RG 1.9 (Reference 6.5), the current NRC endorsed standard for EOG testing at nuclear power plants. Moreover, the 2000-hours/year rating is required to be exceeded during the first two hours of the EOG 24-hour endurance run imposed by SR 4.8.1.1.2.e.6 [SR 4.8.1.1.2.e. 7 for Unit 2]. The maximum post-accident loading has been historically verified to be less than the 2000-hours/year rating during safeguards testing and is not expected to change without a physical change to the station conducted in accordance with FPL's design control process. Since EOG testing in accordance RG 1.9 is an acceptable means to ensure plant safety analyses assumptions will be met, the 2000-hours/year rating verification test is unnecessary to demonstrate EOG operability. As such, the SR can be relocated to plant procedural control whereby future changes will be subject to the regulatory controls of 10 CFR 50.59. The proposed change is consistent with the Combustion Engineering STS (Reference 6.2), which does not include 2000-hours/year rating verification testing, and is thereby reasonable.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 16 of 39 3.4.2 EOG Fuel Oil Transfer Pump Cross-Connection Testing SR 4.8.1.1.2.e.10 [Unit 1]; SR 4.8.1.1.2.e.11 [Unit 2]

The SR verifies the capability of the EOG fuel oil transfer pumps to transfer fuel oil from either diesel oil fuel storage tank (DOST} to the engine-mounted tanks (aka day tanks) of each EOG via normally isolated, cross-tie piping connecting the fuel oil transfer trains. The proposed change relocates the SR to licensee control. The SRs derive from RG 1.108, (Reference 6. 7), which established the recommendation for stations which rely on switching from one fuel oil system to another in order to satisfy the on-site 7-day (plus margin) fuel oil supply recommended ANSI N195-1976 (Reference 6.8). Each fuel oil transfer pump is sized to supply fuel oil to both EOG sets simultaneously. Seismically qualified, safety-grade cross-tie piping lies between the suction and discharge headers to provide the capability of either pump to supply one EOG from both DOSTs. For St. Lucie Unit 2, TS 3/4.8.1.1 assures each DOST stores sufficient fuel to supply each EOG for 7-days. Hence the testing is unnecessary since reliance on the cross-tie piping is not needed to provide each EOG 7-days of fuel oil. For Unit 1, TS 3/4.8.1.1 assures each DOST stores sufficient fuel to supply either EOG for 7-days. Hence, both DOSTs and the cross-tie piping are relied upon to supply either EDG 7-days of fuel oil. However, RG 1.108 has since been superseded by RG 1.9 (Reference 6.5) which does not contain a fuel oil cross-connection testing requirement. Moreover, the cross-connection capability is a passive feature and cannot be changed without physical change to the station in accordance with FPL's design control process. Hence, the EDG fuel oil transfer cross-connection testing is unnecessary to demonstrate EDG operability and can be relocated to plant procedural control whereby future changes will be subject to the regulatory controls of 10 CFR 50.59. The proposed change is consistent with the Combustion Engineering STS (Reference 6.2), which does not require diesel fuel oil cross-connection testing, and is thereby reasonable.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

• 10 CFR 50.36(c}(3) requires a licensee's Technical Specifications to have surveillance requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operations are within safety limits, and that limiting conditions for operation (LCOs) will be met.

• 10 CFR 50.63 requires that each light-water-cooled nuclear power plant be able to withstand and recover from a station blackout (i.e. loss of the offsite electric power system concurrent with reactor trip and unavailability of the onsite emergency ac electric power system) of a specified duration.

• General Design Criteria (GDC) 17 of Appendix A to 10 CFR 50 states, in part, that nuclear power plants [shall] have onsite and offsite electric power systems to permit the functioning of structures, systems, and components that are important to safety.

The onsite system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 17 of 39

• GDC 18 of Appendix A to 10 CFR 50 states that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.

• Regulatory Guide (RG) 1.6, Revision 0, described a method acceptable to the NRC staff for an acceptable degree of independence between redundant standby (onsite) power sources and their distribution systems.

• RG 1.9, Revision 0, described a method acceptable to the NRC staff for the selection of diesel-generator sets of sufficient capacity and margin to implement GDC 17.

• RG 1.32 describes a method acceptable to the NRC staff for complying with Criteria 17 and 18 of 10 CFR 50, Appendix A, with respect to the design, operation and testing of safety-related electric power systems in all types of nuclear power plants.

• RG 1.155 describes a method acceptable to the NRC staff for complying with the Commission regulation that requires nuclear power plants to be capable of coping with a station blackout for a specified duration.

The proposed changes comply with the requirements of 10 50.36(c)(3) and 10 CFR 50.63, and do not alter the manner in which the St. Lucie Unit 1 and St. Lucie Unit 2 EDGs are operated and maintained, consistent with GDC 17, GDC 18, and RGs 1.6, 1.9, 1.32 and 1.155, as applicable. All regulatory requirements will continue to be satisfied as a result of the proposed license amendments.

4.2 Precedents In Reference 6.9 Wolf Creek Generating Station (Wolf Creek) received a license amendment allowing the performance of selected EOG SRs during Modes 1 and 2. In Reference 6.10, Callaway Unit 1 (Callaway), received a similar license amendment.

4.2.1 The cited precedents are similar to this amendment request since, in the event of a LOOP during 24-hour endurance testing at-power, both stations rely on operator action to manually reset the lockout relay in order for the EOG under test to restart and begin sequencing emergency loads onto the associated emergency bus. As with St. Lucie, this worst-case LOOP scenario would potentially delay the availability of the EOG under test by several minutes.

However as with St. Lucie, the response time is not critical, the affected bus would be restored well within the time needed for safe shutdown, and the response of the redundant train would be unaffected by the EOG under test.

4.2.2 The cited precedents are similar to this amendment request since the stations received permission to perform EOG load sequence timer testing and portions of EOG LOOP, LOCA w/ concurrent LOOP, and test mode override testing during MODES 1 and 2 for the purpose of restoring operability. As proposed for St.

Lucie, both stations first require that an assessment determine that plant safety is maintained or enhanced. As proposed for St. Lucie, both stations established assessment content requirements in their TS Bases consistent with the Combustion Engineering STS Bases (Reference 6.3).

4.3 No Significant Hazards Consideration The proposed license amendments modify the St. Lucie Unit 1 and St. Lucie Unit 2 Technical Specifications (TS) by allowing the performance of selected Emergency Diesel

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 18 of 39 Generator (EDG) surveillance requirements (SRs) during power operation and by relocating to licensee control two EDG SRs that are not necessary to demonstrate operability. As required by 10 CFR 50.91(a), FPL has evaluated the proposed changes using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

( 1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change modifies the allowable MODEs for selected EOG testing and relocates two EOG testing requirements to licensee control. EOG testing verifies the accident mitigation capabilities assumed in accident analyses. In some cases, the proposed changes could result in detectable electrical perturbations resulting from testing at-power. However, the perturbations do not exceed expected parameters or equipment capabilities, and do not trigger protective safety systems, and thereby cannot increase the likelihood of any accident. In some cases, the proposed changes could delay the ability of the EOG under test to respond to a loss of offsite power. However, the delay is insignificant, the testing would not affect redundant trains or equipment capabilities, and the plant would remain within its licensing basis in response to any postulated event. In addition, administrative controls ensure that the testing would not occur under conditions that could potentially challenge safe operation such as severe weather, etc. The testing selected for relocation to licensee control verify passive capabilities or capabilities verified during pre-operational testing that will not change without physical changes to the station. The proposed changes align the St. Lucie TS with the regulatory guidance of NUREG 1432, Revision 4, and industry precedent, and thereby cannot adversely affect safety.

Therefore, the proposed license amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change modifies the allowable MODEs for EDG testing and relocates two EOG testing requirements to licensee control. In some cases, the proposed change increases the length of time an EOG would be paralleled to the grid during power operation. During such testing, the EOG under test would be declared inoperable for a period well within the current licensing basis. Likewise, station response to any postulated event during such testing would be within its licensing basis. Hence, the proposed change would not introduce new accident initiators or new failure mechanisms and would not alter the expected outcome of any postulated event. The testing selected for relocation to licensee control verify passive equipment capabilities or capabilities verified during pre-operational testing that will not change without physical changes to the station.

Therefore, the proposed license amendments would not create the possibility of a new or different kind of accident from any previously evaluated.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 19 of 39 (3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change modifies the allowable MODEs for EOG testing and relocates two EDG testing requirements to licensee control. The proposed change does not affect any fission product barrier or modify any set points for which protective actions associated with accident detection or mitigation are initiated. The proposed change neither affects the design of plant equipment nor the manner in which the plant is operated. The proposed changes cannot adversely impact any safety limits or limiting safety settings.

Therefore, the proposed license amendment would not involve a significant reduction in the margin of safety.

Based upon the above analysis, FPL concludes that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment modifies a regulatory requirement with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or changes an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 Regulatory Guide (RG) 1.155, Station Blackout, August 1988 (ADAMS Accession No. ML003740034) 6.2 NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants, Revision 4.0, Volume 1, Specifications (ADAMS Accession No. ML12102A165) 6.3 NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants, Revision 4.0, Volume 2, Bases (ADAMS Accession No. ML12102A169)

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 20 of 39 6.4 NRG Letter to J. Goldberg, Florida Power & Light Company, St. Lucie Units 1 and 2 -

Issuance of Amendments RE: Testing Requirements of Emergency Diesel Generator (TAC NOS M92016 and M92017), June 29, 1995 (ADAMS Accession No.ML013600353) 6.5 RG 1.9, Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants, Revision 3, July 1993 (ML003739929) 6.6 Safety Guide 9, (aka RG 1.9, Revision 0) Selection of Diesel Generator Set Capacity for Standby Power Supplies, March 10, 1971 6.7 RG 1.108, Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants, Revision 1, August 1977 (ADAMS Accession No. ML12216A011) 6.8 ANSI N195-1976 / ANS 59-51, Fuel Oil Systems for Standby Diesel-Generators, April 12, 1976 6.9 Wolf Creek Generating Station - Issuance of Amendment RE: Technical Specifications 3.8.1 and 3.8.4 -AC and DC Sources (TAC NO. MB8763), July 12, 2004, (ADAMS Accession No. ML041970435) 6.10 Callaway Plant, Unit 1 - Issuance of Amendment RE: Technical Specifications 3.8.1 and 3.8.4 -AC and DC Sources (TAC NO. MB9664), June 14, 2004, (ADAMS Accession No. ML041700128)

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 21 of 39 Attachment 1 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

(4 pages follow)

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 22 of 39 Attachment 1 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of the Diesel Fuel Oil Testing Program.

d. DELETED

e. In accordance with the Surveillance Frequency Control Program~ ,r shutdewR by:

1. DELETED ~hie single largest post-accident load I Verifying generator capability to r e j e c t ~

~ t o GOO lrp while maintaining voltage at 4160 +/- 420 volts and frequency at 60 +/- 1.2 Hz.

fying upon oss o o site power by itself~:

a) ~energization of the emergency busses and load shedding from the emergency busses.

ST. LUCIE - UNIT 1 3/4 8-5 Amendment No. a:., 4W, 468, 2G7, 223

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 23 of 39 Attachment 1 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) b) \/erifyi~e diesel starts on the auto-start signal****,

energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage arid frequency of the emergency busses shall be maintained at 4160 :t. 210 volts and 60 .+/- 0.6 Hz during this test.

4 Verifying that on an ESF actua. tion.te6t-signal (without loss-of-offsite power) the diesel generator starts**** on the auto-start signal, and:

a) Within 10 seconds, generator voltage and frequency shall be 4160 +/-. 420 volts and 60 +/-. 1.2 Hz.

b) Operates on standby for greater than or equal to 5 minutes.

c) Steady-state generator voltage and frequency shall be 4160 .+/- 210 volts and 60 + 0.6 Hz and shall be maintained throughout this test.

~Verifying uponi Simulating a ioss-ot-otfs1te power in con*unction with an ESF actuation-testsignal;-afl1- Add colon(:)

a) Verifyi~energization of the emergency busses and load shedding from the emergency busses.

b) \lerifyi~e diesel starts on the auto~start signal****, energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected emergency (accident) loa*ds through the auto-sequ~ncer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After energization, the steady-state voltage and freq4ency o.fthe emergency busses shall be maintained at 4160 :!:. 21.0 volts and 60 .+/- 0.6 Hz during this test.

c) Verifying t~II automatic diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a safety injection signal.

• • • • This test may be conducted in accordance with the manufacturer's recommendations concerning engine prelube period.

ST. LUCIE* UNIT 1 3/4 8-6 Amendment No.~. 4G<l, 213

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ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

Verifying the diesel generator operates for at least 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s****. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded within a load band of 3800 to 3960 kW# and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded Within a load band of 3300 to 3500 kW#. The generator voltage and frequency shall be 4160 :!:. 420 volts and 60 :!:. 1.2 Hz within Add "DELETED" 10 seconds after the start signal; the steady state generator voltage and frequency shall be maintained within these limits during this test.

7. VeFifyil'l§ ti'lat the auto connected loads do not elweed the 2800-hour 1ati1,g of 3730 k'JV.

8 Verifying the diesel generator's capability to:

INSERT C . a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simYlateGf restoration of offsite power.

b) Transfer its load to the offsite power source, and c) Be restored to its standby status.

Verifying that with the diesel generator operating in a test mode (connected to its bus), a sil'l'lulateel safety injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizes the emergency loads with offsite power.

10. 'v'erifyi11g that the fuel transfe1 pump tra1,sfers fuel f,0111 eael,

-IA_d_d-"D_l_t_d_"

'-*___e_e_e____,_ V fuel sterage tanlc to U'le eA§ine !'l'lounteel taAks of eaeh diesel

• ,<ia the installed eross eonneotion lines.

11 Verifying that th.e automatic load sequence timers are operable with the interval beh,veen each load block within + 1 second of its design interval. -

f. In accordance with tho Surveillance Frequency Control Program or after any modification which ce>uld affect diesel generator independence by starting****

the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to approximately 900 rpm in less than or equal to 10 seconds.

1. This band is meant as guidance to avoid routine overloading of the engine.

Variations in load in excess of this band due to changing bus loads shall not invalidate this test.

• • • • This test may be conducted in accordance with the manufacturer's recommendations concerning engine prelube period.

ST. LUCIE - UNIT 1 3/4 8-6a Amendment No. 4-03, 442, 223

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 25 of 39 Attachment 1 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

INSERT A

---

- NO TE ------------------------------------------

Credit may be taken for unplanned events that satisfy this SR.

INSERTB1

---

NOTE ------------------------------------------

Th is Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines that the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

INSERTB2

---

- NOTE -------------------------------------------

Th is Surveillance shall not normally be performed in MODE 1 or 2. However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines that the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

INSERTC

---

.NO TE ------------------------------------------

Th is Surveillance shall not normally be performed in MODE 1, 2, 3 or 4.

However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines that the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 26 of 39 Attachment 2 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

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ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

c. Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of the Diesel Fuel Oil Testing Program.

d. DELETED

e. In accordance with the Surveillance Frequency Control Program~

-shutdown by:

1. DELETED ~the single largest post-accident load I 2 Verifying generator capability to reject a load ef

~ w h i l e maintaining voltage at 4160 +/- 420 volts and frequency at 60 +/- 1.2 Hz.

3 Verifying the generator capability to reject a load of 3685 kW without tripping. The generator voltage shall not exceed 4784 volts during and following the load rejection.

ST. LUCIE - UNIT 2 314 8-5 Amendment l~o. :.9,-444, 4ai>,

173

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 28 of 39 Attachment 2 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

ELECTRICAL POWER SYSTEMS

-'rf-f~,;..,~,,,,nergization of the emergency busses and load shedding from the emergency busses.

b. Verifyi~e diesel starts on the auto-start signal,****

energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected shutdown loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 +/-. 210 volts and 60 +/-. 0.6 Hz during this test.

Verifying that on an ESF actuation4eet-signal (without loss-of-offsite power) the diesel generator starts****

on the auto-start signal, and:

a) Within 10 seconds, generator voltage and frequency shall be 4160 +/- 420 volts and 60 +/- 1.2 Hz.

b) Operates on standby for greater than or equal to 5 minutes.

c) Steady-state generator voltage and frequency shall be 4160 +/- 210 volts and 60 +/- 0.6 Hz and shall be maintained throu hout this test.

Verifying upon a oss-o -o site power in con*unction with an ESF actuation~ signal,--afl'El Add colon (:)

a) Veri~iR!cenergization of the emergency busses and load shedding from the emergency busses.

b) 1/orifyi~e diesel starts on the auto-start signal,****

energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected emergency (accident) loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 +/-. 210 volts and 60 ;!: 0.6 Hz during this test.

• • • • This test may be conducted in accordance with the manufacturer's recommendations concerning engine prelube period.

ST. LUCIE - UNIT 2 3/4 8-6 Amendment No. ~. 163

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 29 of 39 Attachment 2 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) c) Verifying that all automatic diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a safety injection actuation signal.

Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.**** During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test; the diesel generator shall be loaded within a load band of 3800 to 3985 kW and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded within a load band of 3450 to 3685 kW.

~ - - - - - - - . The generator voltage and frequency shall be 4160 _+ 420 volts and 60 _+ 1.2 Add "DELETED" Hz within 10 seconds after the start signal; the steady-state generator voltage and frequency shall be maintained within these limits during this test.

Verifying ti ,at the flljto oonneeted loaas to eael'l Eliesel generator do not exceed the 2000 hem rating of 3935 lela"o'.

9J Verifying the diesel generator's capability to:

~a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power.

b) Transfer its load to the offsite power source, and c) Be restored to its standby status.

Verifying that with the diesel generator operating in a test mode (connected 1~ to its bus), a siR'!ulated safety injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically

~ energizes the emergency loads with offsite power.

11. V-erifying that tt=ie f'.uel trnnsror pump transfers fl:lel from oaoh fl:lel storage tank jAdd "Deleted"~:::~ eflgine 111olj1,ted tal'lks ef eael'l diesel 'via the iflstalled cross conneetitm

1. This band is meant as guidance to avoid routine overloading of the engine. Variations in load in excess of this band due to changing bus loads shall not invalidate this test.

• • • • This test may be conducted in accordance with the manufacturer's recommendations concerning engine prelube period.

ST. LUCIE - UNIT 2 3/4 8-7 Amendment No. ~. 00, +3, 89

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 30 of 39 Attachment 2 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 12 Veri.fying that the automatic load sequence timers are operable. with the interval between each load block within +/-1 second of its design interval.

Perform1ng .

. Surveillance Requirement 48

.. 1.1.2a.4 within .

. 5 minutes of 13.

shutting down the diesel generator after it has operated within a load band of 3450 kW to 3685 kW# for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until operating temperatures have stabilized.

f. In accordance with the Surveillance Frequency Control Program or after any modifications which could affect diesel generator interdependence by starting****

the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to approximately 900 rpm in less than or equal to 1O seconds.

g. In accordance with the Surveillance Frequency Control Program by performing a ,r pressure test of those portions of the diesel fuel oil system designed to Section Ill, subsection ND of the ASME Code in accordance with the lnservice Inspection Program.

4:8.1 .1.3 Reports - (Not Used).

4.8.1.1.4 The Class 1E underground cable system shall be demonstrated OPERABLE within 30 days after the movement of any loads in excess of 80% of the ground surface design basis load over the cable ducts by pulling a mandrel with a diameter of at least 80% of the duct's inside diameter through a duct exposed to the maximum loading (duct nearest the ground's surface) and verifying that the duct has not been damaged.

1. This band is meant as guidance to avoid routine overloading of the engine. Variations in load in excess of this band due to changing bus loads shall not invalidate this test.

• • • • This test may be conducted in accordance with the manufacturer's recommendations concerning engine prelube period.

ST. LUCIE - .Ul~IT 2 3/4 8-?a Amendment No. d9, +ll, 4;!4, 4N, 183

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 31 of 39 Attachment 2 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)

INSERT A

---

NOTE ------------------------------------------

Credit may be taken for unplanned events that satisfy this SR.

INSERTB1

---

NOTE ------------------------------------------

Th is Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines that the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

INSERTB2

---

NO TE -------------------------------------------

Th is Surveillance shall not normally be performed in MODE 1 or 2. However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines that the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

INSERTC

---

NO TE -------------------------------------------

Th is Surveillance shall not normally be performed in MODE 1, 2, 3 or 4.

However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines that the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 32 of 39 Attachment 3 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES (MARKUP)

(3 pages follow)

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 33 of 39 Attachment 3 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES (MARKUP)

Section No.

,J FPL ST. LUCIE UNIT 1 TECHNICAL SPECI Fl CATIONS BASES ATTACHMENT 10 0 F ADM-25.04 SAFETY RELATED 3/4.8 Attachment No.

10 Current Revision No.

~

Hie:

ELECTRICAL POWER SYSTEMS Responsible Department: Licensing REVISION

SUMMARY

Revision 7 - Incorporated PCR 2087288 based on NRC approval ofTSTF-422, Cr1ange in Technical Specifications End States (CE t*JPSD,1186'). (Author: t'-.1. Davidson) I Revision 6 - Incorporated PCR 2053666 based on NRC apprcrval ofH1e TSTF-425 LAR tt1at implements the Surveillance Frequency control Program. (Author: K. Frer1afer)

Revision 5 - Incorporated PCR 1948779 to modify TS requirements for Mode change limitations in LCO 3. 0. 4 and SR 4.0.4. (Author: N. Elmore)

Revision 4 - Incorporated PCR 1880845 to update DC battery sur,,1eillance TS changes required. (Author: K. Frehafer)

Revision 3 - Incorporated PCR 09-2643 to update EOG fuel oil testing ASTM standards.

(Author: K.W. Frehafer)

Revision 2 - Implemented License Amendment 207 and 155. Procedure cr1angesto implement EOG Fuel Oil Test Program LAR were reviewed in ORG 08-034 on 6/26/08 as part of the license amendment subrrittal. (Author: K.\IV. Frehafer)

Revision 1- Implemented License Amendment *J 80. (K.V\r'. Frehafer, 12/11.io-1)

Revision o - Bases for Technical Specifications. (E. Weinkarn, 08130/01)

Revision Approved By Approval Date UNIT# UNIT 1 DATE 0 R.G. West 00130.01 DOCT PROCEDURE DOCN secw1 :J.'L8 SYS 7 R. C off;t 001261'15 STATUS COUPLETED REV 7

1. OF PGS

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C;B

;TIJ N 10.: P,0/3 E: .

TITLE: TECHNICAL SPECIFIC.A.Tl ONS 314.8 BASES ATI.A.CHM ENT 10 OF ADM-25.04 4 of.8 R EVISIJII NO.: ELECTRICAL POWER SYSTEMS 7 ST. LUCIE Uf'.JIT 1 314.8 ELECTRICAL POVIIER SYSTEMS (continued)

BASES (continued)

TS 3.8:1.1, ACTlON "b" prcwides an allowed outage/action completion time (AOT) of up to *14 days toto restore a single inoperable diesel generator to operable status. n,is AOT is t,ased on the findings ofa deterministic and probabilistic safety analysis and is referred to as a "risk-informed" AOT.

Entry- into this action requires that a risk assessment be performed in accordance 11vith the Configuration Risk Management Program (CRM P),

vv*hich is described in the .A.dministrative Procedure that implements the Maintenance Rule pursuant to 1o CF R 50.65.

All EDG inoperabilities must be irwestigated for common-c:ause failures regardless of hcrw long the EDG inoperabillt\1 persists. When one diesel generator is inoperable, required ACTI Ot\JS 3.8. *1. *1. band 3.8.1 :1.c provide an allowance to avoid unnecessar\1 testing of EDGs. If it can be determined that the cause of the inoperable EDG does not exist on the remaining OPERA.BLE EDG, then SR 4.8.1.1.2.a,4 does not ha\1e to be petfotrned.

Eight (8) hours is reasonable to confirrnthatthe OPERABLE EOG is not affected b\1 the same problem as the inoperable EDG. lfit cannot othervvise be determined that the cause Ofthe initial inoperable EDG does not exist on the remainingEDG,then satisfactory performance of SR 4.8.1 ,1.2.a.4 suffices to provide assurance of continued OPERABILITY of that EDG.

lfthe cause of the initial inoperabillty exists on Uie remaining OPERABLE EDG, tr,at EDG would also be declared inoperable upon discover11, and ACTION 3.8.1.1.e would be entered. Once the failure is repaired (on either EDG), the common:cause failure no longer exists.

.A.ct ion g prohibits the application of LCO 3.0.4.b to an inoperable diesel generator. There is an increased risk associated with entering a Mo DE or other specified condition in the Appljcability with an inoperable diesel generator and the provisions of LCO 3.0.4.b, wtiich allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, sho.uld not be appUed in this circumsiance.

Ambient conditions are the normal standby conditions for the diese.l engines. Any normally running 1,,varmupsystems should be in service and operating, and manufacturer's recommendations for engirie oil and water

..._ temperatures and other parameters should be follOl/\18d.

II NE:ERT next page ...~*.

The OPEPJ\.81 UTY of the minimum specified A. C. and D.C. power sources and associated distribution S\istems during shutdown and refueling ensures that 1) the facility can be maintained intt*,e shutdo\hlfl or refueling condition for extended time periods and 2) sufficientinstrumentation and control

• capabilit{ is available for mo11itoring and rraintaining the facility status.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 35 of 39 Attachment 3 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES (MARKUP)

INSERT for ST. LUCIE UNIT 1 TS BASES For SR 4.8.1.1 .2.e, the prohibition from normally performing EOG surveillances in restricted MODES may be supplemented by a NOTE allowing the surveillance, or portions thereof, to be performed for the purpose of reestablishing OPERABILITY (e.g.,

post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns). An assessment must first be completed which determines that plant safety is maintained or enhanced by the restricted MODE testing. As a minimum, the assessment shall consider the potential outcomes and transients associated with a failed surveillance, a successful surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the surveillance, or portions thereof, is performed in the normally restricted MODE. Risk insights or deterministic methods may be used for this assessment. The applicable NOTE specifies the allowable MODES for the restricted testing and whether the entire or only portions of the surveillance may be performed.

The assessment thereby dictates on case-by-case basis which portions of the SR are necessary and safe for reestablishing OPERABILITY in the restricted MODES.

SR 4.8.1.1.2.e.2 requires verification of EOG capability to reject the single largest post-accident load while maintaining EOG voltage within 10% of the nominal voltage and EOG frequency within 2% of the nominal frequency. Based on the EOG Load List (see drawing 8770-C-453), the single largest post-accident load is the Intake Cooling Water (ICW) pump, which has a nameplate horsepower of 600 HP. Since horsepower cannot be directly measured, plant procedures specify the required rejection load in kilowatts (kW). Rejecting an ICW pump load greater than or equal to 453 kW while maintaining EOG voltage and frequency within the allowable limits demonstrates satisfactory completion of SR 4.8.1.1.2.e.2. [Ref: AR 2280368; PSL-1-FJE-90-0013]

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 36 of 39 Attachment 4 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES (MARKUP)

(3 pages follow)

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 37 of 39 Attachment 4 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES {MARKUP)

Section No.

ST. LUCIE UNIT 2 fJ 3/4.8 Attachment.No.

TECHNICAL SPECI Fl CATIONS 10 BASES ATTACHMENT 10 Current RevisionN OF ADM-25.04 FPL SAFETY RELATED

Title:

ELECTRICAL POWER SYSTEMS Responsible Department: Licensing REVISION

SUMMARY

Revision 8 - Incorporated PCR 2087288 based on NRC appraval ofTSTF-422, Change in Technical Specifications End States (CE NPSD-1186). (Author: N. Davidson)

Revision 7 - Incorporated PCR 2053666 based on r*-mc approval oft he TSTF-425 LAR that implements the Surveillance Frequency control Program. (Author: K. Frehafet')

Revision 6 - Incorporated PCR 1948783 to modify TS requirements for Mode cr1ange limitations in LCO 3. O. 4 and SR 4.0.4. (Author: ~~- Elmore)

Revision 5 - Incorporated PCR 1671445 to update Diesel Fuel o ii Testing program TS changes required. (Author: K. Frehafer)

Revision 4 - Incorporated PCR 1880845 to update DC battery sur,,eillance TS changes required. (Author: K. Frehafer)

Revision J...., Incorporated PCR 09-2643 to update EDG fuel oil testing ASTM standards.

(Author: K.VV. Frehafer)

Revision 2 - Implemented License Amendment 207 and 155. Procedure ct*1anges to implement EOG Fuel Oil Test Program LAR were revievved in ORG 08-034 on 6126108 as part of the license amendment subrrittal. (Author: K.\N. Frehafer)

Revision 1 ...., Implemented License Amendment 123. (K. \IV. Frehafer, 12/17101)

Revision O - Bases for Technical Specifications. (E. V\ieinkam, 08/30101)

Revision Approved By Approval Date UNIT# UNIT2 DATE 0 R.G.Wes:t 03130.01 D.OCT PROCEDURE D.OCN ~ 01))1 3/t .B SYS 8 R. Coff~ 03126/15 STATUS COI.IPLETED REV 8

1. OFPGS

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B::TIJ N to .: PAGE:

nm: TECHNICJI.L SPEC! FICATI ONS 3!4.8 BASES ATTACHMENT 10 OF ADM-25.04 R Eo'ISIJ N NO.: ELECTRICAL POWER SYSTEMS 8 ST. LUCIE UNIT 2

/4.8 ELECTRICAL POWER SYSTEMS (continued)

BASES (continued) 14.8.1, 3/4.8.2 and 3/4.8.3. A.C. SOURCES, D.C. SOURCES and ON SITE POWER DISTRIBUTION SYSTEMS (continued)

Action g prohibits the application of LCO 3.0.4.b to an inoperable diesel generator. There is an increased risl,; associated with entering a MO DE or other specified condition in the Applicability- vvith an inoperable diesel generator and n,e provisions of LCO 3.0.4.b, wt1ich all aw entry- into a MO DE or other specified condition in Urn Applicability vvith the LCO not met after performance of a risk assessment addressii1g inoperable systems and components, should not be applied in tt1is circumstance.

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The OPERA Bl UT/ of the. minimum specified A. C: and D.C . power sources and associated distributionsystems during shutdov,..n and refueling ensures that 1) the facilit11 can be maintained in the shutdov,..n or refueling condition for extended time periods and 1) sufficient instrumentation and control capability is available for monitoring and maintaining H*1eunit status.

If the inoperable A. C. pawer source and associated distribution system or D.C. po*wer source and associated distribution sy-stern cannot be restored to an OPERABLE status within the .alloi,vable outage time, the plant must be brought to a MO DE in which overall plant ris.k is minimized. To achieve this status, the plant must be brougrit to at least HOT STANDBY witr1in 6 r1ours and to HOT SHUTDOWN within the follcwing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Remaining vvithin the Applicability of the LCO is acceptable because the plant risk in HOT SHUTDO\IVN is similar to or lov,;er than COLD SHUTDOINN (reference CE NPSD-1186-A, Technical Justification for the Risk I nfofrned Modification to Selected Required Action End States for C.EOG PVVRs, October 2001). In HOT SHUTDOWN there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal meclrnnlsrns tt1an in COLD SHUTDOVVN. Ho>>vever, voluntary entry into COLD SHUTDOWN may be made as it is also an acceptable low-risk state.These ACTIONs are modified by aNotethat states that LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN, Jr1isNote prohibits the use of LCO .3.0.4.a to enterHOT SHUTDOWN during startup with the LCO not met.

Hcrwever, there is no restriction on the use of LCO 3. 0. 4. b, if applicable, because LCO 3.0.4:b requires performance of a risk assessment addressing inoperable systems and components, consideration ofthe results, determination of the acceptabiUty. of entering HOT SHUTDOWN, and establishment of risk management actions, ifappropriate. LCO 3.0, 4 is not applicable to, and the Note does not preclude, changes in MODES or ottier specifiedconditions in the Applicability* that are required to comp~, v1~th ACTIONS or that are. part of a strntdovim of the unit.

St. Lucie Nuclear Plant L-2018-161 Docket Nos. 50-335 and 50-389 Enclosure Page 39 of 39 Attachment 4 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES (MARKUP)

INSERT for ST. LUCIE UNIT 2 TS BASES Ambient conditions are the normal standby conditions for the diesel engines. Any normally running warmup systems should be in service and operating, and manufacturer's recommendations for engine oil and water temperatures and other parameters should be followed.

For SR 4.8.1.1 .2.e, the prohibition from normally performing EOG surveillances in restricted MODES may be supplemented by a NOTE allowing the surveillance, or portions thereof, to be performed for the purpose of reestablishing OPERABILITY (e.g.,

post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns). An assessment must first be completed which determines that plant safety is maintained or enhanced by the restricted MODE testing. As a minimum, the assessment shall consider the potential outcomes and transients associated with a failed surveillance, a successful surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the surveillance, or portions thereof, is performed in the normally restricted MODE. Risk insights or deterministic methods may be used for this assessment. The applicable NOTE specifies the allowable MODES for the restricted testing and whether the entire or only portions of the surveillance may be performed.

The assessment thereby dictates on case-by-case basis which portions of the SR are necessary and safe for reestablishing OPERABILITY in the restricted MODES.

SR 4.8.1.1 .2.e.2 requires verification of EOG capability to reject the single largest post-accident load while maintaining EOG voltage within 10% of the nominal voltage and EOG frequency within 2% of the nominal frequency. Based on the EOG Load List (see drawing 2998-C-453), the single largest post-accident load is the Intake Cooling Water (ICW) pump, which has a nameplate horsepower of 600 HP. Since horsepower cannot be directly measured, plant procedures specify the required rejection load in kilowatts (kW). Rejecting an ICW pump load greater than or equal to 453 kW while maintaining EOG voltage and frequency within the allowable limits demonstrates satisfactory completion of SR 4.8.1.1.2.e.2. [Ref: AR 2280368; PSL-2-FJE-90-0020]