View source for L-2016-008, Application for Technical Specification Change Regarding Moderator Temperature Coefficient (Mtc) Surveillance Test Elimination at the End of Cycle

{{Adams
| number = ML16033A472
| issue date = 01/19/2016
| title = Application for Technical Specification Change Regarding Moderator Temperature Coefficient (Mtc) Surveillance Test Elimination at the End of Cycle
| author name = Costanzo C
| author affiliation = Florida Power &amp; Light Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000335, 05000389
| license number = 
| contact person = 
| case reference number = L-2016-008
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Bases Change
| page count = 25
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:0January                     FPL~
                            !I=111 19, 2016
                                                   *10 L-20 16-008 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re:       St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance Test Elimination at the End of Cycle.
Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requests to amend Facility Operating License DPR-67 for St. Lucie Unit 1 and NPF- 16 for St. Lucie Unit 2.
The proposed amendment would modify the Technical Specifications (TS) to implement elimination of the end-of-cycle moderator temperature coefficient (MTC) surveillance test as supported by NRC-Approved Topical Report CE NPSD-91 1-A and Amendment 1-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specifcation End of Cycle Negative MTC Limit, and St. Lucie specific supporting information. This amendment request also proposes to add a previously NRC approved Westinghouse PARAGON Topical Report WCAP- 16045-P-A, Revision 0 to the list of COLR methodologies in TS 6.9.1 .11 .b for use in future licensing applications for both the St. Lucie Units.
The Enclosure provides FPL's evaluation of the proposed changes. Attachment 1 to the Enclosure provides the existing TS pages marked up to show the proposed changes. Attachment 2 to the Enclosure provides the clean TS pages with the changes incorporated. Attachment 3 to the Enclosure provides an informational copy of the proposed changes to the TS Bases.
This letter contains no new or revised regulatory commitments.
FPL requests that the LAR be processed normally, with approval of the proposed amendment within one year and the amendment being implemented within 90 days of NRC approval.
The license amendment proposed by FPL has been reviewed bY the St. Lucie Plant Onsite Review Group. In accordance with 10 CFR 50.91(b)(1), a copy of the proposed license amendment is being forwarded to the State Designee for the State of Florida.
Please contact Mr. Eric Katzman, Licensing Manager at 772-467-7734 if there are any questions about this submittal.
Florida Power & Light Company                                                                   ,, ,
6501 S. Ocean Drive, Jensen Beach, FL 34957

L-20 16-008 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on January                 ,2016 Sincerely, Christopher R. Costauzo Site Vice President St. Lucie Plant CRC/KWF Enclosure cc:     NRC Region II Administrator St. Lucie Plant NRC Senior Resident Inspector Ms. Cindy Becker, Florida Department of Health

L-20 16-008 Enclosure Page 1 of 23 ENCLOSURE Evaluation of the Proposed Change TABLE OF CONTENTS:
1.0    

==SUMMARY==
DESCRIPTION .................................................................... 2 2.0    DETAILED DESCRIPTION..................................................................... 2 2.1   Proposed TS Changes........................................................................... 2

==3.0    TECHNICAL EVALUATION==
................................................................... 3 3.1   MTC Surveillance .............................................................................. 3 3.2   COLR Methodology ............................................................................ 6

==4.0    REGULATORY EVALUATION==
 ...............................................................                6 4.1   Applicable Regulatory Requirements/Criteria ...............................................        6 4.2   Precedent ........................................................................................ 7 4.3   No Significant Hazards Consideration Determination.......................................          7 4.4   Conclusions...................................................................................... 9

==5.0    ENVIRONMENTAL CONSIDERATION==
 ..................................................... 9

==6.0    REFERENCES==
................................................................................... 10 ATTACHMENTS
: 1. Markup of Technical Specification Pages............................................ 11
: 2.      Word Processes Technical Specification Pages ...................................... 16
: 3. Proposed Technical Specification Bases Changes (Information Only)................. 21

L-2016-008 Enclosure Page 2 of 23 Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance Test Elimination at the End of Cycle.
1.0     

==SUMMARY==
DESCRIPTION The proposed amendment would modify Technical Specifications (TS) for St. Lucie Units 1 and 2 to implement elimination of the end-of-cycle (EOC) moderator temperature coefficient (MTC) surveillance test as supported by Topical Report CE NPSD-91 1-A and Amendment 1-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specification End of Cycle Negative .MTC Limit [Reference 1], and the additional St. Lucie plant specific justification provided in this amendment request. The proposed amendment also adds the Westinghouse Topical Report WCAP-16045-P-A, Revision 0, Qualificationof the Two-Dimensional Transport Code PARAGON [Reference 2], to the St. Lucie Units 1 and 2 TS list of Core Operating Limits Report (COLR) methodologies.
2.0     DETAILED DESCRIPTION 2.1     Proposed TS Changes Technical Specifications   - Section 3.1.1.4, Moderator Temperature Coefficient This licensee amendment request (LAR) revises St. Lucie Units 1 and 2 surveillance requirements related to TS 3.1.1.4, "'ModeratorTemperature Coefficient". The proposed changes are based on Topical Report (TR) CE NPSD-91 1-A and Amendment 1-A, Analysis of ModeratorTemperature Coefficients in Support of a Change in the Technical Specification End of Cycle Negative MTC Limit. TS Surveillance Requirement (SR) 4.1.1.4.2 is proposed to be revised as shown in Attachment 1.
The changes proposed are also consistent with the guidance from Revision 2 of TSTF-406-T, predictingEnd-Of-Cycle MTC andDeleting Need for End-Of-Cycle ]MTC Verification (NPSD-911-A), when considering the St. Lucie Units 1 and 2 MTC Surveillance requirements approved by the NRC for the implementation of Startup Testing Activity Reduction (STAR) program (Reference 3).
SR 4.1.1.4.2 currently provides for testing the MTC lower limit specified in the COLR, during each refueling cycle within 7 effective full power days (EFPDs) of reaching 2/3 of expected core burnup. If the MTC is more negative than the lower limit specified in the COLR when extrapolated to EOC, the testing may be repeated. Plant shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.
The proposed change for both the St. Lucie Units includes adding the following note to the SR 4.1.1.4.2:

L-20 16-008 Enclosure Page 3 of 23 Only requiredifthe MTC determined in SR 4.1.1.4.1 is not within     +/- 1.6pcm/&deg;F of the correspondingdesign values.
Technical Specifications  - Section 6.9.1.11. Core Operating Limits Report (COLR)
This LAR adds the following Topical Report WCAP-16045-P-A, to the analytical methods listed in TS 6.9.1.11.b.
WCAP-16045-P-A, Revision 0, "Qualificationof the Two-Dimensional TransportCode PARAGON, "August 2004 (Westinghouse Proprietary).
3.0     TECIHNICAL EVALUATION 3.1     MTC Surveillance Topical Report CE NPSD-91 1-A provides the technical justification for this change. CE NPSD-911l-A, Analysis of Moderator Temperature Coefficients in support of a change in the Technical Specification End-of-Cycle Negative MTC limit, CEOG Task 764, analyzed a database of measured and calculated MTCs at CE-designed plants and established that if the measured beginning-of-cycle (BOC) moderator temperature coefficients fall within +0.16* 10E-4 Ap/&deg;F (same as ++/-1.6pcm/&deg;F) of the design value, then it can be assumed that the EOC coefficient will also be within +1.6 pcm/&deg;F of the design value. Therefore, the BOC surveillance becomes unnecessary. Note that the tolerance limit of+1l.6 pcm/0 F, which is based on the measurement data for isothermal temperature coefficient (ITC), remains applicable for both ITC and MTC as long as consistent fuel temperature coefficient (FTC) is used in the design calculation and in obtaining MTC from the measured ITC.
CE NPSD-91 1-A and Amendment 1-A, which were approved by the NRC on June 14, 2000
[Reference 4], require that the best estimate MTC (design value) must be based on the CE methodology. The use of alternate method for cycle design along with the MTC surveillance requirements applicable to St. Lucie Units 1 and 2 with the implementation of Startup Testing Activity Reduction (STAR) program is addressed below.
The NRC approved CE NPSD-91 1-A and Amendment 1-A subject to the five conditions below:
: 1.      In order to ensure that the moderator temperature coefficient will not exceed the Technical Specifcation limit with a confidence/tolerance of 95/95 percent, the cycle must be designed, using the CE methodology, such that the best estimate MTC is..
: a.      more negative than the BOC Technical Specification limit by the design margin,
: b.      more positive than the EOC Technical Specification limit by the design margin.
This condition requires that the cycle design must be performed using the CE methodology with the calculated best estimate MTC at BOC and EOC having a defined design margin to the respective TS/COLR limit. St. Lucie Units 1 and 2 nuclear design

L-20 16-008 Enclosure
                                                                                   *Page 4 of 23 currently is performed using the Westinghouse ANC/PHOENIX-P code system. To justify the application of CE NPSD-91 1-A without using the CE methodology, Westinghouse performed benchmark calculations to support the use of ANC/PHOENIX-P and ANC/PARAGON in place of DIT/ROCS, the CE methodology.
As part of generating a 95/95 percent confidence/tolerance limit for the MTC generated with other than CE methodology, Westinghouse performed benchmarks using DIT/ROCS, PHOENIX-P/ANC and PARAGON/ANC codes based on measurements from several CE-NSSS plants, including St. Lucie Units 1 and 2. The results from the benchmarks showed similar agreement of the codes with the measured data, and determined that the design margin of +/-1.6 pcnm/&deg;F determined in CE NPSD-91 1-A and Amendment 1-A for MTC verification using DIT/ROCS continues to remain applicable for ANC/PHIOENIX-P and ANC/PARAGON code packages. The benchmark results with ANC/PARAGON were previously provided by Westinghouse to the NRC in letter LTR-NRC-05-37 [Reference 5]. Presented below are the benchmark results of ANC/PHOENIX-P based on 61 separate measurements from several CE-NSSS plants, including St. Lucie Units 1 and 2. The use of ANC/PHOENIX-P or ANC/PARAGON methodology in place of DIT/ROCS code for St. Lucie Units 1 and 2 to generate the design MTC value for use in the EOC MTC elimination process is thus justified.
ANC/PHOENIX-P Benchmark Results1 Standard Deviation                                 0.58 pcm/&deg;F 9 5/95 Tolerance Limit                             1.17 pcm/&deg;F Uncertaintyr Allowance+/-16pmF (Design margin)                      _____________
St. Lucie Units 1 and 2 specific comparison data, for the past few cycles, of the MTC measured and design values generated with the ANC/PHOENIX-P code package is presented below in Tables 1 and 2. To satisfy the EOC MTC elimination TS requirements, Florida Power & Light Company will continue to use the Westinghouse APA code package (ANC/PHOENIX or ANC/PARAGON) for the core design with a design margin of +/-1.6 pcm/&deg;F to the respective BOC and BOC MTC TS/COLR limits.
: 2. The design margin is determined to be 1.6pcm/&deg;F at all times in life.
The design margin used for St. Lucie Units 1 and 2 will be 1.6 pcm/&deg;F at all times in core life. This margin is applicable for cycle designs done using ANC/PARAGON as well as ANC/PHOENIX-P codes as justified above.
: 3. The analysis of the revised data base, including the most recent measured and calculatedMTCs, has establishedthat if the measured beginning-of-cycle moderator temperature coefficients are within 1.6pcm/&deg;F of the best estimate prediction, then it can

L-201 6-008 Enclosure Page 5 of 23 be assumed that the end-of-cycle coefficient will also be within 1.6pcm/&deg;F of the prediction and its measurement is not required.
The proposed TS changes are consistent with this condition and the EOC MTC measurement will not be required if MTC determined at BOC is within 1.6 pcm/&deg;F of the design value. This is based on the evaluation which shows that the EOC MTC will also be within 1.6 pcn/&deg;F of the design value. Cycle design performed using this design margin will thus ensure that the analysis assumptions with respect to the MTC will continue to be met.
The reload analysis for each cycle design calculates a conservative end-of-cycle MTC based on limiting operating conditions allowed by the TS/COLR and using an allowed cycle bumnup that bounds the planned cycle operation. Any changes to the plant operation which could impact the calculated limiting BOC MTC design value are re-evaluated to ensure that the cycle MTC design value remains within 1.6 pcm/&deg;F of the respective COLR limit in the conservative direction. This process ensures that the safety analysis requirements for MTC will continue to be met for all times in life.
Tables 1 and 2 show the comparison of the design and measured MTC data for St. Lucie Units 1 and 2 for the last 3 cycles.
______________________      Table 1 (St. Lucie Unit 1)     _____________
BOC HZP                            BOC HFP                             EOC HFP (M - P) MTC pcm/&deg;F                 (M - P) MTC pcm/&deg;F                 (M - P) MTC pcm/&deg;F Cycle        Cycle           Cycle Cycle   TCycle        Cycle       Cycle       Cycle     Cycle 24            25            26     24         25        26           24           25       26 0.39          0.32          0.50   0.17__{-0.35         STAR        -0.17__      -0.68
* M =Measured value                     P  = Predicted (design) value              *=  EOC not reached
_____________________       Table 2 (St. Lucie Unit 2)     ____________
BOC HZP                            BOC HFP                             EOC HFP (M - P) MTC pcm/&deg;F                 (M - P) MTC pcm/&deg;F                 (M - P) MTC pcm/&deg;F Cycle        Cycle           Cycle Cycle      Cycle      Cycle       Cycle       Cycle     Cycle 20            21            22     20         21        22           20           21       22
 -0.56         -0.11          -0.14 -1.52      STAR       STAR        -0.66         0.58
* M = Measured value                     P = Predzcted (design) value               = gut&#xa2; not reached

L-2016-008 Enclosure Page 6 of 23
: 4.       The measured data reduction must be based on the current CE methodology as describedin the report.
As stated in Westinghouse letter LTR-NRC-05-37 to the NRC, with the merger of the nuclear businesses of ABB-CE and Westinghouse Electric Company, there has been an ongoing effort to replace CE DIT/ROCS nuclear design package with the Westinghouse equivalent NRC-approved ANC/PARAGON and ANC/PHOENIX-P code packages.
Westinghouse has performed several benchmarks of DIT/ROCS, ANC/PHOENJX-P and ANC/PARAGON using measurements from several CE-NSSS plants and determined that the same design margin of+/-1 .6 pcm/&deg;F for MTC verification continues to remain applicable for ANC/PHOENIX-P and ANC/PARAGON code packages.
St. Lucie Units 1 and 2 have been using ANC/PHOENIX-P code for neutronics design for the past several cycles and have found good agreement of the design data with the physics testing measurement data. Comparison of the design and measured MTC values for the past few cycles is presented above in Tables 1 and 2.
: 5.       If the beginning-of-cycle measurementsfail the acceptance criteriaof +/-l.6 pcm/&deg;F and the discrepancy cannot be resolved, the end-of cycle surveillance test must be performed The proposed changes to the MTC surveillance requirements are consistent with this condition and the failure to meet the +/--1.6 pcm!&deg;F acceptance criteria, in the beginning of cycle MTC measurement, will result in performing the MTC surveillance test, at the end of cycle, within 7 EFPD of reaching 2/3 of the expected cycle burnup. The beginning of cycle MTC surveillance requirements for the St. Lucie units, subsequent to the implementation of STAR, are defined in SR 4.l.l.4.la and 4.l.1.4.lb.
3.2      COLR Methodology WCAP-16045-P-A, Revision 0, "Qualificationof the Two-Dimensional TransportCode PARAGON,"' has been approved by the NRC on March 18, 2004, with the conclusion in the safety evaluation that the PARAGON code can be used as a replacement for the PHOENIX-P lattice code, wherever the PHOENIX-P code is used in NRC-approved methodologies. Both the St. Lucie Units are currently licensed to use the PHOENIX-P code in reload analysis, and thus the inclusion of PARAGON code in the list of COLR methodologies in TS 6.9.1.1 1.b is justified for both St. Lucie Units.

==4.0      REGULATORY EVALUATION==

4.1      Applicable Regulatory Requirements/Criteria In 10 CFR 50.36, the NRC established the regulatory requirements related to the content of the TS. Pursuant to 10 CFR 50.36, the TS are required to include items in the following five specific categories related to station operation:

L-2016-008 Enclosure Page 7 of 23 (1)     Safety limits, limiting safety system settings, and limiting control settings; (2)     Limiting conditions for operation (LCOs);
(3)     Surveillance requirements (SRs);
(4)     Design features; and (5)     Administrative controls.
Although the proposed changes modify the MTC surveillance requirements, the MTC surveillance requirements continue to remain in the TS. None of the other categories are impacted by the proposed amendment to the MTC verification requirement.
Also, the proposed addition of the PARAGON Topical Report WCAP-16045-P-A, Revision 0 to TS 6.9.1.11 .b remains consistent with the regulatory requirement with respect to the above category number five (Administrative Controls).
4.2     Precedent A previous submittal for EOC MTC test elimination for Combustion Engineering plant designs such as St. Lucie was approved by the NRC for Arizona Public Service Company (APS) Palo Verde Units on March 30, 2015 [Reference 6]. The TS amendment approved was very similar to the proposed TS changes contained in this submittal with the support of Topical Report CE-NPSD-91 1-A and Amendment 1-A.
Other CE-design TS amendments related to BOC MTC test elimination that used CE-NPSD-91 1-A with Amendment 1-A were issued to Waterford Unit 3 and Arkansas Nuclear One, Unit 2
[References 7 and 8]. The LARs for these plants were approved in April 2000 and November 2001, respectively, and provided the same design margin tolerance of +/--1.6 pcmi/&deg;F from the TR.
4.3     No Significant Hazards Consideration Determination The proposed amendment would modify Technical Specifications (TS) for St. Lucie Units 1 and 2 to implement elimination of the end-of-cycle (EOC) moderator temperature coefficient (MTC) surveillance test as supported by Topical Report CE NPSD-91 1-A and Amendment 1-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specification End of Cycle Negative MTC Limit. The proposed amendment also adds the Westinghouse Topical Report WCAP-16045-P-A, Revision 0, Qualificationof the Two-Dimensional Transport Code PARAGON, to the St. Lucie Units 1 and 2 TS list of Core Operating Limits Report (COLR) methodologies.
Florida Power & Light Company has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

L-20 16-008 Enclosure Page 8 of 23
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
A change is proposed to eliminate the measurement of end-of-cycle (BOC) moderator temperature coefficient (MTC) if the beginning-of-cycle (BOC) measurements are within a given tolerance of the design values. MTC is not an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased.
The BOC MTC value is an important assumption in determining the consequences of accidents previously evaluated. The analysis presented in the Topical Report CE NPSD-911-A and Amendment 1-A, with additional justification provided in this amendment request, determined that the BOC MTC will be within design limits if the BOC MTC design values are within a given tolerance of the measured values. Therefore, the BOC MTC will continue to be within design limits and the consequences of accidents will continue to be as previously evaluated.
The addition of WCAP-16045-P-A, which has been previously approved by the NRC for licensing applications to TS 6.9.1.11 .b, is an adnministrative change which has no impact on the probability or consequences of any accident previously evaluated.
As a result, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
A change is proposed to eliminate the measurement of EOC MTC if the BOC measurements are within a given tolerance of the design values. Also, a new previously approved methodology is proposed to be included in the TS list of COLR methodologies.
The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

L-20 16-008 Enclosure Page 9 of 23
: 3.      Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
A change is proposed to eliminate the measurement of EOC MTC if the BOC measurements are within a given tolerance of the design values. The Topical Report CE NPSD-9 11-A and Amendment 1-A, with additional justification provided in this amendment request, concluded that the risk of not measuring the EOC MTC is acceptably small provided that the BOC measured values are within a specific tolerance of the design values. Also, WCAP-16045-P-A proposed to be added to TS 6.9.1.11, has been previously approved by the NRC for licensing applications to be used consistent with the approved methodologies. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above, Florida Power & Light Company concludes that the proposed amendment(s) do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92, and, accordingly, a finding of "no significant hazards consideration" is justified.
4.4     Conclusions Topical Report CE NPSD-91 1-A and Amendment 1-A provide the supporting documentation for plants of original CE type design eliminating the need to perform EOC MTC surveillance testing. CE NPSD-91 1-A and Amendment 1-A were approved by the NRC via Safety Evaluation on June 14, 2000. The proposed changes in this LAR are consistent with CE NPSD-911-A and Amendment 1-A, and therefore, the proposed changes are considered acceptable for St. Lucie Units 1 and 2.
The NRC has approved, via Safety Evaluation on March 18, 2004, the use of PARAGON code as a replacement for the PHOENIX-P lattice code in the NRC-approved methodologies. The addition of PARAGON code Topical Report to the list of COLR methodologies is thus justified for both St. Lucie Units which currently use the PHOENIX-P lattice code for reload cycle design.
Based on the considerations discussed above, it is concluded that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

==5.0      ENVIRONMENTAL CONSIDERATION==

A review has determined that this TS amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or

L-2016-008 Enclosure Page 10 of 23 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. The NRC has previously issued a proposed finding that similar amendments to the CE STS involve no significant hazards considerations, and there was no public comment on the finding.
Accordingly, the proposed changes meet 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 to be prepared in connection with the proposed amendments.

==6.0     REFERENCES==
: 1.      Combustion Engineering Owners Group Topical Report, CE-NPSD-91 1-A and Amendment 1-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specification End-of-Cycle Negative MTC Limits, dated September 15, 2000.
: 2.      Westinghouse Topical Report WCAP-16045-P-A, Revision 0, Qualification of the Two-Dimensional Transport Code PARAGON, August 2004, and NRC Safety Evaluation for the Topical Report, dated March 18, 2004.
: 3.      US Nuclear Regulatory Commission Safety Evaluation, St. Lucie Plant, Unit Nos. 1 and 2 - Issuance of Amendments Regarding Moderator Temperature Coefficient Surveillance Requirements (TAC No s. MF 1888 and MF 1889), dated September 16, 2014.
: 4.      US Nuclear Regulatory Commission Letter, Acceptance for Referencing of CE NPSD-911, "Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specifications End-of-Cycle Negative MTC Limit", and Amendment 1 (TAC NO. MA9036), dated June 14, 2000.
: 5.      Westinghouse Letter LTR-NRC-05-37 to NRC (ADAMS Accession No. ML051740481),
EOL MTC Elimination Informational Benchmark, dated June 17, 2005.
: 6.      US NRC Safety Evaluation, Palo Verde Generating Station, Units 1, 2, and 3 - Issuance of Amendments Re: Technical Specification Change Regarding Moderator Temperature Coefficient Surveillance For Startup Test Activity Reduction Program (TAC Nos.
M\F3 143, MIF3 144, and MF3 145). dated March 30, 2015.
: 7.      US NRC Safety Evaluation, Waterford Steam Electric Station, Unit 3 - Issuance of Amendment Re: Moderator Temperature Coefficient Test Near End of Each Cycle (TAC No. MA378 1), dated April 21, 2000.
: 8.      US NRC Safety Evaluation, Arkansas Nuclear One, Unit No. 2 - Issuance of Amendments Re: Deletion of Moderator Temperature Coefficient (MTC) Determination at Two-Thirds Core Burnup (TAC No. MB 1840), dated November 16, 2001.

L-20 16-008 Enclosure Page 11 of 23 Attachment 1 Markup of Technical Specification Pages Unit 1 3/4 1-6 6-1 9b Unit 2 3/4 1-5 6-20e

L-20 16-008 Enclosure Page 12 of 23 Attachment 1 FffACItVITY COWTROL SYSTEMS SURVEILLANCE REOUIREMENTS tcntflued}                                                                   .
4.11 42_3*      \ eri~ MTc :is    - inthNe low*er limit Specif itd.in~ the.C Each fuiel :c~c e *n~hnn 7 EFFO of reach~ho f3f       dexpeced core bumiup.
If MIC is more ne..ative: tlian the low*er limit *pec~ied .inthe: CCLR *&#xa2;1.en e;*tnapvlated to the~endl of cycl, 4.11.4*2 may be repeated;. Shutdowq :must occur prior to exceeding the minimum altOoabie boron :concerntra*ont wthic MTC *s projected to e. teed :the ot Li oi_ - UNT 'I

L-20 16-008 Enclosure Page 13 of 23 Attachment 1
.ADINIS*ITRATIVE C'PNTROLS coRE OPENRAING LiMITS REzPORT-(co~ntinued}
: 20. EMF:-I961 (PA){A :Statfs tel Setpontiranien~t Methodolcgy forr Con *busfion Engineering .Type Reactors"
: 21. EMF*-2310{ P)A). "SRP Chlapter 151Nor-LOCA M1ethodcolg! for Pres*surized Wate Reac~crs," Revision* 1; as sup emnerded b.
ANP-*3OtX(Pl,. "St.Lucie Unit I' EPIJ - lnfonnatinr to Suppo*rt License Amendment Requea.L' R~evisiorn 0.
: 22. EMF-2328(PJ A] 'PWR Small Break LOCA Evaluation Mcde*, 5-RELARS Etased? Revision 0;: as supplemented by AN P-3D*00{P), "StL.Lucvie Unit "I EPU1 - lnfoirnatb.n to ,up ornUcense A~mendment Recquest? Revision &.
: 23. E F*-2 03(P{A.), &deg;Realistic Large Brea~kLOCA M~eloology for Pressuri.ed Jater Reacors* Revson %        ;as sapplen ented$by ANP-2903(P}, ='St. Lucie N uclear Plant.Linit.1 EPUI Cycle Realistic Large BreaIk LOICA sumniar Report wilb Zr-4. Fue Clt            "~Re ""    1..
: 24. *-AW-IQ240(P (A) Revisin 0, incrporation f M5 Properie ir                            '
Frana~toire AN{P Appr oved M~ethods?".
sTr LUC;IE- urrr!1I                                                    AzN.nendnent Nc44 Ig4;   , 4-41-..

L-2016-008 Enclosure Page 14 of 23 Attachment 1 REAG1VITY COH*TROI_ SYSTEM:S MOPERAOR TETAPERA lRE COEFFICIE1m L1uITImJG CONDITION FOP OPEPJTION specifed in the ,COLR_ The m~aximu*m upj*er lImit shal be +5.pe dtF at 70Z%of.RATED:
THERMAL POWEP* with a :lix~ar ramp. from +5 pcm-)~W at 70% o~f RATE) ThER:MAL SPOWER to 0 pan. F at 100%!* R:ATD ThIPRMAL POW'*ER.
APPLIgAP:IUTY; :MODES IND 2"#.'
ACTION:
J*lt the modlerator           ipe~*reture imetllen* oue~d; *I. 'ere ef the ab~te ruita, be in a*t l~act H-oT
  *S-TANDEY *,i~in 6 h~ours.
* IJPVEILIANCE PE             ~t:IPEMFNTN 4A. iA-4A*1   ,eify, MTC i:s, wi-hin       seupper uin- specifi~ed in LCO 3.. IA:..
a:        :Prior toentelirg IMODE 1:.after each fuel load~g: and
: b.        Each fu~e cycle Wid[h 7:effe& efull              er*days {ErDI)ofreacing*4D EFPB:
core I unup.*
  #       See: Special Test *.eplin 310t2 a~nd 3:10.5.
* V [:h
* reaterl*aflot equa! t i o.
:**:    Only requi~red to :beerform~ed when".f MlC d~ete~rr*,hed prior to eteting.MO:DE ! is verifed* using ad*u cp edc-tecd MC:.                  :"...."
fM
       .* T&TC.is    more n egati ve a.n tlhe lower IiTt specified in the COLR when e rapolatec to the en~d of :cycle, 4: 1 4.2 maybe repea ed.* Shutdown* must occitr prir to exceeding: the mirnimu aliowab e boron concetraton at               ir~cMTC Ls projected io exc.eed the [ower limi.
lulired if be       TC dot rufoed
~          Lorras ot~ iii~ eegn ~elue.                       ~n SR 4.11.       1 is not     'bin +  tO      ni Fof the ST; LL*E -UNiT 2:                                     *,&,*: t -5,           ST.
Arrec    ent N~4~~/4 LLCE~UNff.       1-5.   ~,  4~

L-2016-008 Enclosure Page 15 of 23 Attachment 1 ANAIWSTRAT1VF CONTROl S rintinned CORE OPERATiNG UNIITS REPORT (COLRI (tOrlU
: b.  (CO nued
: 61.        ATh11397-PA Rro~detary~, 'Rev<sedTherrnat Design Procedure~'ApnI 19&9~
              &#xa3;2     WCAP4456&$A ~Prop4etary,, PRE-O Modt ng and Oval cat                         ~&
Ptai&utaed Wa ~React&r Non.LOCA                       ~jdratjiicSa    An       t, OtM*r 1999.
              ~3       CAP.145         AAOdeneiuml" attica              ofAEBCrlfica1fie~tFlu Correlations          PREOl ode, May 2001
: 64. Letter. N~ Jelferson Jr FPL) to Document Con liDesk USNRC), tSL Lu& U 2 Docket No. 5D-2~99 Proposed Ucens~ Amendriieat '~CAP-.
9272 Reload Methodology and I omen op 3QV Steam GrwatorT U     t-20D3~275.Dece           ZOOd NRCSEa telI January 1, ettqrSTNtg ey NRC) ig4A$lo!l FPL TAC~MC                         t
: 65. W&AP-14502PAR ~U 'RETRAN-O2                             wind         ilt    for Was              Pressunzed Water Reac~ NOUVLOCA Sat Aniysas~
Apri 1909.
              &#xa3;6,      GAP-79O9- Re 0 TACTRAN-A FORTRAN fVCade form Transients m a 1J02 Fuel Rod', Decemlxr 1929.
              ~r     AOAW 799~              va MNKkE~Af                 DimenalonalNeut erqpd~ January 1975
                & WOAP~75$6 Re IA'ME a. tonoP R~Ele&onAcctentin Wesingliouse Pressurized Wa er geactnt~               Special ~netlCs a       at January 1975.
: c. The core operahng aSts shall be deterorned suth that appbcdblern4se g, fuel thermal mechanIcal P         cOre hennal          Ii linus         enw~Otre Cool big Sytnis'(ECCS             , 6u ear keats.       as SHUTDCVJJ MARITht ant       jss ctsts, and accident anal~srs ~m tS ~fTh# safety anatysts 3W
: 4. iie COLR.         ud g      mid        re ~K i's   supplem&rts shall be           #4 upos        ancefornc reload cycleon eNRC; V       -  ss4r       ReVsionW          at c ti jno to           niftiest   ~p       K Tm oriCQil PARAI                At Ansi       DOt ST. LLICtE L   2                                   -20&                An~endrrent Nn~4~~J-,t-~33y-3t, rr~ ma

L-20 16-008 Enclosure Page 16 of 23 Attachment 2 Word Processed Technical Specification Pages Unit 1 3/4 1-6 6-19b Unit 2 3/4 1-5 6-20e

L-20 16-008 Enclosure Page 17 of 23 Attachment 2 REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (continued) 4.1.1 .4.2***    Verify MTC is within the lower limit specified in the COLR.****
Each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup.
k'' If MTC is more negative than the lower limit specified in the COLR when extrapolated to the end of cycle, 4.1.1.4.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.
Only Required ifthe MTC determined in SR 4.1.1.4.1 is not within _+1.6 pcmPF of the corresponding design value.
ST. LUCIE - UNIT 1                                3/4 1-6                ST.
LCIE UNIT13/1-6Amendment No. 2~~-9,

L-20 16-008 Enclosure Page 18 of 23 Attachment 2 ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT (continued)
: 20. EMF-1 961 (P)(A), "Statistical Setpoint/Transient Methodology for Combustion Engineering Type Reactors"
: 21. EMF-2310(P)(A), "SRP Chapter 15 Non-LOCA Methodology for Pressurized Water Reactors," Revision 1, as supplemented by ANP-3000(P), "St. Lucie Unit 1 EPU - Information to Support License Amendment Request," Revision 0.
: 22. EMF-2328(P)(A), "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based," Revision 0, as supplemented by ANP-3000(P), "St. Lucie Unit 1 EPU - Information to Support License Amendment Request," Revision 0.
: 23. EMF-2103(P)(A), "Realistic Large Break LOCA Methodology for Pressurized Water Reactors," Revision 0, as supplemented by ANP-2903(P), "St. Lucie Nuclear Plant Unit 1 EPU Cycle Realistic Large Break LOCA summary Report with Zr-4 Fuel Cladding," Revision 1.
: 24. BAW-1 0240(P)(A) Revision 0, "Incorporation of M5 Properties in Framatome ANP Approved Methods."
: 25. WCAP-1 6045-P-A, Revision 0, "Qualification of the Two -Dimensional Transport Code PARAGON," August 2004.
ST. LUCIE - UNIT 1                               6-19b                  Amendment No. -16, 4-T-1, l:4-4, 2-13,248

L-20 16-008 Enclosure Page 19 of 23 Attachment 2 REACTIVITY CONTROL SYSTEMS MODERATOR TEMPERATURE COEFFICIENT LIMITING CONDITION FOR OPERATION 3.1.1.4       The moderator temperature coefficient (MTC) shall be maintained within the limits specified in the COLR. The maximum upper limit shall be +5 pcm/&deg;F at < 70% of RATED THERMAL POWER, with a linear ramp from +5 pcm/&deg;F at 70% of RATED THERMAL POWER to 0 pcm/&deg;F at 100% RATED THERMAL POWER.
APPLICABILITY: MODES 1 AND 2*#.
ACTION:
With the moderator temperature coefficient outside any one of the above limits, be in at least HOT STANDBY within 6 hours.
SURVEILLANCE REQUIREMENTS 4.1.1.4.1     Verify MTC is within the upper limit specified in LCO 3.1.1.4.
: a.       Prior to entering MODE 1 after each fuel loading, and
: b.       Each fuel cycle within 7 effective full power days (EFPD) of reaching 40 EFPD core burnup.   **
4.1.1.4.2"**       Verify MTC is within the lower limit specified in the COLR.*~**
Each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup.
#      See Special Test Exception 3.10.2 and 3.10.5.
* With Keff greater than or equal to 1.0.
**     Only required to be performed when MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC.
**     If MTC is more negative than the lower limit specified in the COLR when extrapolated to the end of cycle, 4.1.1.4.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.
   ... Only Required if the MTC determined in SR 4.1.1.4.1 is not within +_1.6 pcm/&deg;F of the corresponding design value.
ST. LUCIE - UNIT 2                                3/4 1-5              Amendment No. 44, 26, 86, 92, 426,,
468

L-20 16-008 Enclosure Page 20 of 23 Attachment 2 ADMINISTRATIVE CONTROLS (,continued)
CORE OPERATING LIMITS REPORT (COLR) (continued)
: b.     (continued)
: 61. WCAP-1 1397-P-A, (Proprietary), 'Revised Thermal Design Procedure," April 1989.
: 62. WCAP-14565-P-A, (Proprietary), 'V/IPRE-Ol Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis,"
October 1999.
: 63. WCAP-14565-P-A, Addendum 1, "Qualification of ABB Critical Heat Flux Correlations with VIPRE-O1 Code," May 2003.
: 64. Letter, W. Jefferson Jr. (FPL) to Document Control Desk (USNRC), 'St.
Lucie Unit 2 Docket No. 50-389: Proposed License Amendment WCAP-9272 Reload Methodology and Implementing 30%* Steam Generator Tube Plugging Limit," L-2003-276, December 2003 (NRC SER dated January 31, 2005, Letter B.T. Moroney (NRC) to J.A. Stall (FPL), TAC No. MC1566).
: 65. WCAP-14882-P-A, Rev. 0, "RETRAN-02 Modeling and Qualification for Westinghouse Pressurized Water Reactor Non-LOCA Safety Analyses",
April 1999.
: 66. WCAP-7908-A, Rev. 0, "FACTRAN-A FORTRAN IV Code for Thermal Transients in a UO2 Fuel Rod", December 1989.
: 67. WCAP-7979-P-A, Rev. 0, "TWINKLE - A Multi-Dimensional Neutron Kinetics Computer Code", January 1975.
: 68. WCAP-7588, Rev. 1-A, "An Evaluation of the Rod Ejection Accident in Westinghouse Pressurized Water Reactors Using Special Kinetics Methods", January 1975.
: 69. WCAP-1 6045-P-A, Revision 0, 'Qualification of the Two-Dimensional Transport Code PARAGON," August 2004.
: c. The core operating limits shall be determined such that all applicable limits (e.g.,
fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SHUTDOWN MARGIN, transient analysis limits, and accident analysis limits) of the safety analysis are met.
: d. The COLR, including any mid cycle revisions or supplements, shall be provided upon issuance for each reload cycle on the NRC.
ST. LUCIE - UNIT 2                                  6-20e                 Amendment No.4-05,1448, 4,=%,42,8, 44-7, 46,

L-2016-008 Enclosure Page 21 of 23 Attachment 3 Proposed Technical Specification Bases Change (Information Only)
INSERT A:
SR 4.1.1.4.2 is only required if the MTC determined in SR 4.1.1.4.1 is not within +/-1.6 pcm/&deg;F of the corresponding design value when the difference cannot be reconciled. Analysis has shown that if the results of the beginning of cycle moderator temperature coefficient verification fall within +1.6 pcm/ 0 F of the corresponding design values, then it can be assumed that the end of cycle coefficient will also agree with the design value within +/-1.6 pcm/&deg;F and the measurement at EOC is not required.

L-20 16-008 Enclosure Page 22 of 23 Attachment 3
                            *_*    TECHNICAL .SPESCIE-CATION',S                               .*-...
      .....                     BASES ATTACH EtC*S* A             *OF sif2o4 *
:3141.1i;    B ORATION :CONTROL (tCOfur*nid)!
3/4.1..1:.41  MODE{RATOR TEMPERATURE C:OEFFICIENT !MTC) (continu~ed}:
SR 4.:11 :4]2 is moied by a No*eawvih'h indicates that iti[he extrapolatedl SutveXl~nce: may :be repeca~d;     andthe .uldormd .must occur pnrf :toi exceeding the minimum allo; abie,boron Icon can ra onI1                  ic~t:ii4 I.
JTC   :is*
pro~ec ed to exceed: h~e i ccelimi~t' Ad ev ualon :to detarin te li s; iiThe saTely alyexpcS:* iesriot violgateda.ort**odirs:
             *:Ttherequireer:nt     or meaurene         w*tsin e *FPI v*"Bofm       *reahn   23itcire a:
bump,atisfie T::*sirmiantoycte the co                      i the~ mosta -ative        IT aue pre.     ~atd EQ_ MT        "ieeautdIeoer&ro                         ~     ~~ ece peiniit; direct cmaiso          h    T         lsspcfe       nteCL

L-20 16-008 Enclosure Page 23 of 23 Attachment 3
       *c~~qc~~o.:                    t       TECHNICAL SPECIFICATIOgNS                    #:E*. i.,:  *.
         *so*;:- ..............          .. :REACTIVilY CONTROL SYSTEM~S" S....                      ... S:T. LUCIE UNIT. 2      ....
                 .BASES: (con inued) 3 41*.*1.4:        MODERATOR TEMNPERATURE COEFFICIENT (co0itned) e ceed~ing the minirnm ailo ;*a e-tb*i:on centration at *hich M*TC; *S.
                 *in h!e sfe!t aniIyss is.no! 'iolated; T *e requireent for mreasuremnt,,,( iiin"7 EFPDof r"*eachin8 123 co0re up, sasfe ~cthec nfi~rmaotlt*ectof       whe.no~t nghe      MTC vati lu4hte.
Tkeaor.Oooasu nt              pSfore a d any, te TeHERMALe      Pes ER~
5so; TIh pOjEc            LEOC s~TC nta sbem    evaubbated' bfore h~e rea.tcr ..p~ essehesse isEO i:S       cbove on.aa R.TC. a-es etra.e: "e"k :o an.... ....... a"
:SERmi          ieT:&A       rie oeM               issee          nteCt

0January                     FPL~
                            !I=111 19, 2016
                                                   *10 L-20 16-008 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re:       St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance Test Elimination at the End of Cycle.
Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requests to amend Facility Operating License DPR-67 for St. Lucie Unit 1 and NPF- 16 for St. Lucie Unit 2.
The proposed amendment would modify the Technical Specifications (TS) to implement elimination of the end-of-cycle moderator temperature coefficient (MTC) surveillance test as supported by NRC-Approved Topical Report CE NPSD-91 1-A and Amendment 1-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specifcation End of Cycle Negative MTC Limit, and St. Lucie specific supporting information. This amendment request also proposes to add a previously NRC approved Westinghouse PARAGON Topical Report WCAP- 16045-P-A, Revision 0 to the list of COLR methodologies in TS 6.9.1 .11 .b for use in future licensing applications for both the St. Lucie Units.
The Enclosure provides FPL's evaluation of the proposed changes. Attachment 1 to the Enclosure provides the existing TS pages marked up to show the proposed changes. Attachment 2 to the Enclosure provides the clean TS pages with the changes incorporated. Attachment 3 to the Enclosure provides an informational copy of the proposed changes to the TS Bases.
This letter contains no new or revised regulatory commitments.
FPL requests that the LAR be processed normally, with approval of the proposed amendment within one year and the amendment being implemented within 90 days of NRC approval.
The license amendment proposed by FPL has been reviewed bY the St. Lucie Plant Onsite Review Group. In accordance with 10 CFR 50.91(b)(1), a copy of the proposed license amendment is being forwarded to the State Designee for the State of Florida.
Please contact Mr. Eric Katzman, Licensing Manager at 772-467-7734 if there are any questions about this submittal.
Florida Power & Light Company                                                                   ,, ,
6501 S. Ocean Drive, Jensen Beach, FL 34957

L-20 16-008 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on January                 ,2016 Sincerely, Christopher R. Costauzo Site Vice President St. Lucie Plant CRC/KWF Enclosure cc:     NRC Region II Administrator St. Lucie Plant NRC Senior Resident Inspector Ms. Cindy Becker, Florida Department of Health

L-20 16-008 Enclosure Page 1 of 23 ENCLOSURE Evaluation of the Proposed Change TABLE OF CONTENTS:
1.0    

==SUMMARY==
DESCRIPTION .................................................................... 2 2.0    DETAILED DESCRIPTION..................................................................... 2 2.1   Proposed TS Changes........................................................................... 2

==3.0    TECHNICAL EVALUATION==
................................................................... 3 3.1   MTC Surveillance .............................................................................. 3 3.2   COLR Methodology ............................................................................ 6

==4.0    REGULATORY EVALUATION==
 ...............................................................                6 4.1   Applicable Regulatory Requirements/Criteria ...............................................        6 4.2   Precedent ........................................................................................ 7 4.3   No Significant Hazards Consideration Determination.......................................          7 4.4   Conclusions...................................................................................... 9

==5.0    ENVIRONMENTAL CONSIDERATION==
 ..................................................... 9

==6.0    REFERENCES==
................................................................................... 10 ATTACHMENTS
: 1. Markup of Technical Specification Pages............................................ 11
: 2.      Word Processes Technical Specification Pages ...................................... 16
: 3. Proposed Technical Specification Bases Changes (Information Only)................. 21

L-2016-008 Enclosure Page 2 of 23 Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance Test Elimination at the End of Cycle.
1.0     

==SUMMARY==
DESCRIPTION The proposed amendment would modify Technical Specifications (TS) for St. Lucie Units 1 and 2 to implement elimination of the end-of-cycle (EOC) moderator temperature coefficient (MTC) surveillance test as supported by Topical Report CE NPSD-91 1-A and Amendment 1-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specification End of Cycle Negative .MTC Limit [Reference 1], and the additional St. Lucie plant specific justification provided in this amendment request. The proposed amendment also adds the Westinghouse Topical Report WCAP-16045-P-A, Revision 0, Qualificationof the Two-Dimensional Transport Code PARAGON [Reference 2], to the St. Lucie Units 1 and 2 TS list of Core Operating Limits Report (COLR) methodologies.
2.0     DETAILED DESCRIPTION 2.1     Proposed TS Changes Technical Specifications   - Section 3.1.1.4, Moderator Temperature Coefficient This licensee amendment request (LAR) revises St. Lucie Units 1 and 2 surveillance requirements related to TS 3.1.1.4, "'ModeratorTemperature Coefficient". The proposed changes are based on Topical Report (TR) CE NPSD-91 1-A and Amendment 1-A, Analysis of ModeratorTemperature Coefficients in Support of a Change in the Technical Specification End of Cycle Negative MTC Limit. TS Surveillance Requirement (SR) 4.1.1.4.2 is proposed to be revised as shown in Attachment 1.
The changes proposed are also consistent with the guidance from Revision 2 of TSTF-406-T, predictingEnd-Of-Cycle MTC andDeleting Need for End-Of-Cycle ]MTC Verification (NPSD-911-A), when considering the St. Lucie Units 1 and 2 MTC Surveillance requirements approved by the NRC for the implementation of Startup Testing Activity Reduction (STAR) program (Reference 3).
SR 4.1.1.4.2 currently provides for testing the MTC lower limit specified in the COLR, during each refueling cycle within 7 effective full power days (EFPDs) of reaching 2/3 of expected core burnup. If the MTC is more negative than the lower limit specified in the COLR when extrapolated to EOC, the testing may be repeated. Plant shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.
The proposed change for both the St. Lucie Units includes adding the following note to the SR 4.1.1.4.2:

L-20 16-008 Enclosure Page 3 of 23 Only requiredifthe MTC determined in SR 4.1.1.4.1 is not within     +/- 1.6pcm/&deg;F of the correspondingdesign values.
Technical Specifications  - Section 6.9.1.11. Core Operating Limits Report (COLR)
This LAR adds the following Topical Report WCAP-16045-P-A, to the analytical methods listed in TS 6.9.1.11.b.
WCAP-16045-P-A, Revision 0, "Qualificationof the Two-Dimensional TransportCode PARAGON, "August 2004 (Westinghouse Proprietary).
3.0     TECIHNICAL EVALUATION 3.1     MTC Surveillance Topical Report CE NPSD-91 1-A provides the technical justification for this change. CE NPSD-911l-A, Analysis of Moderator Temperature Coefficients in support of a change in the Technical Specification End-of-Cycle Negative MTC limit, CEOG Task 764, analyzed a database of measured and calculated MTCs at CE-designed plants and established that if the measured beginning-of-cycle (BOC) moderator temperature coefficients fall within +0.16* 10E-4 Ap/&deg;F (same as ++/-1.6pcm/&deg;F) of the design value, then it can be assumed that the EOC coefficient will also be within +1.6 pcm/&deg;F of the design value. Therefore, the BOC surveillance becomes unnecessary. Note that the tolerance limit of+1l.6 pcm/0 F, which is based on the measurement data for isothermal temperature coefficient (ITC), remains applicable for both ITC and MTC as long as consistent fuel temperature coefficient (FTC) is used in the design calculation and in obtaining MTC from the measured ITC.
CE NPSD-91 1-A and Amendment 1-A, which were approved by the NRC on June 14, 2000
[Reference 4], require that the best estimate MTC (design value) must be based on the CE methodology. The use of alternate method for cycle design along with the MTC surveillance requirements applicable to St. Lucie Units 1 and 2 with the implementation of Startup Testing Activity Reduction (STAR) program is addressed below.
The NRC approved CE NPSD-91 1-A and Amendment 1-A subject to the five conditions below:
: 1.      In order to ensure that the moderator temperature coefficient will not exceed the Technical Specifcation limit with a confidence/tolerance of 95/95 percent, the cycle must be designed, using the CE methodology, such that the best estimate MTC is..
: a.      more negative than the BOC Technical Specification limit by the design margin,
: b.      more positive than the EOC Technical Specification limit by the design margin.
This condition requires that the cycle design must be performed using the CE methodology with the calculated best estimate MTC at BOC and EOC having a defined design margin to the respective TS/COLR limit. St. Lucie Units 1 and 2 nuclear design

L-20 16-008 Enclosure
                                                                                   *Page 4 of 23 currently is performed using the Westinghouse ANC/PHOENIX-P code system. To justify the application of CE NPSD-91 1-A without using the CE methodology, Westinghouse performed benchmark calculations to support the use of ANC/PHOENIX-P and ANC/PARAGON in place of DIT/ROCS, the CE methodology.
As part of generating a 95/95 percent confidence/tolerance limit for the MTC generated with other than CE methodology, Westinghouse performed benchmarks using DIT/ROCS, PHOENIX-P/ANC and PARAGON/ANC codes based on measurements from several CE-NSSS plants, including St. Lucie Units 1 and 2. The results from the benchmarks showed similar agreement of the codes with the measured data, and determined that the design margin of +/-1.6 pcnm/&deg;F determined in CE NPSD-91 1-A and Amendment 1-A for MTC verification using DIT/ROCS continues to remain applicable for ANC/PHIOENIX-P and ANC/PARAGON code packages. The benchmark results with ANC/PARAGON were previously provided by Westinghouse to the NRC in letter LTR-NRC-05-37 [Reference 5]. Presented below are the benchmark results of ANC/PHOENIX-P based on 61 separate measurements from several CE-NSSS plants, including St. Lucie Units 1 and 2. The use of ANC/PHOENIX-P or ANC/PARAGON methodology in place of DIT/ROCS code for St. Lucie Units 1 and 2 to generate the design MTC value for use in the EOC MTC elimination process is thus justified.
ANC/PHOENIX-P Benchmark Results1 Standard Deviation                                 0.58 pcm/&deg;F 9 5/95 Tolerance Limit                             1.17 pcm/&deg;F Uncertaintyr Allowance+/-16pmF (Design margin)                      _____________
St. Lucie Units 1 and 2 specific comparison data, for the past few cycles, of the MTC measured and design values generated with the ANC/PHOENIX-P code package is presented below in Tables 1 and 2. To satisfy the EOC MTC elimination TS requirements, Florida Power & Light Company will continue to use the Westinghouse APA code package (ANC/PHOENIX or ANC/PARAGON) for the core design with a design margin of +/-1.6 pcm/&deg;F to the respective BOC and BOC MTC TS/COLR limits.
: 2. The design margin is determined to be 1.6pcm/&deg;F at all times in life.
The design margin used for St. Lucie Units 1 and 2 will be 1.6 pcm/&deg;F at all times in core life. This margin is applicable for cycle designs done using ANC/PARAGON as well as ANC/PHOENIX-P codes as justified above.
: 3. The analysis of the revised data base, including the most recent measured and calculatedMTCs, has establishedthat if the measured beginning-of-cycle moderator temperature coefficients are within 1.6pcm/&deg;F of the best estimate prediction, then it can

L-201 6-008 Enclosure Page 5 of 23 be assumed that the end-of-cycle coefficient will also be within 1.6pcm/&deg;F of the prediction and its measurement is not required.
The proposed TS changes are consistent with this condition and the EOC MTC measurement will not be required if MTC determined at BOC is within 1.6 pcm/&deg;F of the design value. This is based on the evaluation which shows that the EOC MTC will also be within 1.6 pcn/&deg;F of the design value. Cycle design performed using this design margin will thus ensure that the analysis assumptions with respect to the MTC will continue to be met.
The reload analysis for each cycle design calculates a conservative end-of-cycle MTC based on limiting operating conditions allowed by the TS/COLR and using an allowed cycle bumnup that bounds the planned cycle operation. Any changes to the plant operation which could impact the calculated limiting BOC MTC design value are re-evaluated to ensure that the cycle MTC design value remains within 1.6 pcm/&deg;F of the respective COLR limit in the conservative direction. This process ensures that the safety analysis requirements for MTC will continue to be met for all times in life.
Tables 1 and 2 show the comparison of the design and measured MTC data for St. Lucie Units 1 and 2 for the last 3 cycles.
______________________      Table 1 (St. Lucie Unit 1)     _____________
BOC HZP                            BOC HFP                             EOC HFP (M - P) MTC pcm/&deg;F                 (M - P) MTC pcm/&deg;F                 (M - P) MTC pcm/&deg;F Cycle        Cycle           Cycle Cycle   TCycle        Cycle       Cycle       Cycle     Cycle 24            25            26     24         25        26           24           25       26 0.39          0.32          0.50   0.17__{-0.35         STAR        -0.17__      -0.68
* M =Measured value                     P  = Predicted (design) value              *=  EOC not reached
_____________________       Table 2 (St. Lucie Unit 2)     ____________
BOC HZP                            BOC HFP                             EOC HFP (M - P) MTC pcm/&deg;F                 (M - P) MTC pcm/&deg;F                 (M - P) MTC pcm/&deg;F Cycle        Cycle           Cycle Cycle      Cycle      Cycle       Cycle       Cycle     Cycle 20            21            22     20         21        22           20           21       22
 -0.56         -0.11          -0.14 -1.52      STAR       STAR        -0.66         0.58
* M = Measured value                     P = Predzcted (design) value               = gut&#xa2; not reached

L-2016-008 Enclosure Page 6 of 23
: 4.       The measured data reduction must be based on the current CE methodology as describedin the report.
As stated in Westinghouse letter LTR-NRC-05-37 to the NRC, with the merger of the nuclear businesses of ABB-CE and Westinghouse Electric Company, there has been an ongoing effort to replace CE DIT/ROCS nuclear design package with the Westinghouse equivalent NRC-approved ANC/PARAGON and ANC/PHOENIX-P code packages.
Westinghouse has performed several benchmarks of DIT/ROCS, ANC/PHOENJX-P and ANC/PARAGON using measurements from several CE-NSSS plants and determined that the same design margin of+/-1 .6 pcm/&deg;F for MTC verification continues to remain applicable for ANC/PHOENIX-P and ANC/PARAGON code packages.
St. Lucie Units 1 and 2 have been using ANC/PHOENIX-P code for neutronics design for the past several cycles and have found good agreement of the design data with the physics testing measurement data. Comparison of the design and measured MTC values for the past few cycles is presented above in Tables 1 and 2.
: 5.       If the beginning-of-cycle measurementsfail the acceptance criteriaof +/-l.6 pcm/&deg;F and the discrepancy cannot be resolved, the end-of cycle surveillance test must be performed The proposed changes to the MTC surveillance requirements are consistent with this condition and the failure to meet the +/--1.6 pcm!&deg;F acceptance criteria, in the beginning of cycle MTC measurement, will result in performing the MTC surveillance test, at the end of cycle, within 7 EFPD of reaching 2/3 of the expected cycle burnup. The beginning of cycle MTC surveillance requirements for the St. Lucie units, subsequent to the implementation of STAR, are defined in SR 4.l.l.4.la and 4.l.1.4.lb.
3.2      COLR Methodology WCAP-16045-P-A, Revision 0, "Qualificationof the Two-Dimensional TransportCode PARAGON,"' has been approved by the NRC on March 18, 2004, with the conclusion in the safety evaluation that the PARAGON code can be used as a replacement for the PHOENIX-P lattice code, wherever the PHOENIX-P code is used in NRC-approved methodologies. Both the St. Lucie Units are currently licensed to use the PHOENIX-P code in reload analysis, and thus the inclusion of PARAGON code in the list of COLR methodologies in TS 6.9.1.1 1.b is justified for both St. Lucie Units.

==4.0      REGULATORY EVALUATION==

4.1      Applicable Regulatory Requirements/Criteria In 10 CFR 50.36, the NRC established the regulatory requirements related to the content of the TS. Pursuant to 10 CFR 50.36, the TS are required to include items in the following five specific categories related to station operation:

L-2016-008 Enclosure Page 7 of 23 (1)     Safety limits, limiting safety system settings, and limiting control settings; (2)     Limiting conditions for operation (LCOs);
(3)     Surveillance requirements (SRs);
(4)     Design features; and (5)     Administrative controls.
Although the proposed changes modify the MTC surveillance requirements, the MTC surveillance requirements continue to remain in the TS. None of the other categories are impacted by the proposed amendment to the MTC verification requirement.
Also, the proposed addition of the PARAGON Topical Report WCAP-16045-P-A, Revision 0 to TS 6.9.1.11 .b remains consistent with the regulatory requirement with respect to the above category number five (Administrative Controls).
4.2     Precedent A previous submittal for EOC MTC test elimination for Combustion Engineering plant designs such as St. Lucie was approved by the NRC for Arizona Public Service Company (APS) Palo Verde Units on March 30, 2015 [Reference 6]. The TS amendment approved was very similar to the proposed TS changes contained in this submittal with the support of Topical Report CE-NPSD-91 1-A and Amendment 1-A.
Other CE-design TS amendments related to BOC MTC test elimination that used CE-NPSD-91 1-A with Amendment 1-A were issued to Waterford Unit 3 and Arkansas Nuclear One, Unit 2
[References 7 and 8]. The LARs for these plants were approved in April 2000 and November 2001, respectively, and provided the same design margin tolerance of +/--1.6 pcmi/&deg;F from the TR.
4.3     No Significant Hazards Consideration Determination The proposed amendment would modify Technical Specifications (TS) for St. Lucie Units 1 and 2 to implement elimination of the end-of-cycle (EOC) moderator temperature coefficient (MTC) surveillance test as supported by Topical Report CE NPSD-91 1-A and Amendment 1-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specification End of Cycle Negative MTC Limit. The proposed amendment also adds the Westinghouse Topical Report WCAP-16045-P-A, Revision 0, Qualificationof the Two-Dimensional Transport Code PARAGON, to the St. Lucie Units 1 and 2 TS list of Core Operating Limits Report (COLR) methodologies.
Florida Power & Light Company has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

L-20 16-008 Enclosure Page 8 of 23
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
A change is proposed to eliminate the measurement of end-of-cycle (BOC) moderator temperature coefficient (MTC) if the beginning-of-cycle (BOC) measurements are within a given tolerance of the design values. MTC is not an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased.
The BOC MTC value is an important assumption in determining the consequences of accidents previously evaluated. The analysis presented in the Topical Report CE NPSD-911-A and Amendment 1-A, with additional justification provided in this amendment request, determined that the BOC MTC will be within design limits if the BOC MTC design values are within a given tolerance of the measured values. Therefore, the BOC MTC will continue to be within design limits and the consequences of accidents will continue to be as previously evaluated.
The addition of WCAP-16045-P-A, which has been previously approved by the NRC for licensing applications to TS 6.9.1.11 .b, is an adnministrative change which has no impact on the probability or consequences of any accident previously evaluated.
As a result, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
A change is proposed to eliminate the measurement of EOC MTC if the BOC measurements are within a given tolerance of the design values. Also, a new previously approved methodology is proposed to be included in the TS list of COLR methodologies.
The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

L-20 16-008 Enclosure Page 9 of 23
: 3.      Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
A change is proposed to eliminate the measurement of EOC MTC if the BOC measurements are within a given tolerance of the design values. The Topical Report CE NPSD-9 11-A and Amendment 1-A, with additional justification provided in this amendment request, concluded that the risk of not measuring the EOC MTC is acceptably small provided that the BOC measured values are within a specific tolerance of the design values. Also, WCAP-16045-P-A proposed to be added to TS 6.9.1.11, has been previously approved by the NRC for licensing applications to be used consistent with the approved methodologies. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above, Florida Power & Light Company concludes that the proposed amendment(s) do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92, and, accordingly, a finding of "no significant hazards consideration" is justified.
4.4     Conclusions Topical Report CE NPSD-91 1-A and Amendment 1-A provide the supporting documentation for plants of original CE type design eliminating the need to perform EOC MTC surveillance testing. CE NPSD-91 1-A and Amendment 1-A were approved by the NRC via Safety Evaluation on June 14, 2000. The proposed changes in this LAR are consistent with CE NPSD-911-A and Amendment 1-A, and therefore, the proposed changes are considered acceptable for St. Lucie Units 1 and 2.
The NRC has approved, via Safety Evaluation on March 18, 2004, the use of PARAGON code as a replacement for the PHOENIX-P lattice code in the NRC-approved methodologies. The addition of PARAGON code Topical Report to the list of COLR methodologies is thus justified for both St. Lucie Units which currently use the PHOENIX-P lattice code for reload cycle design.
Based on the considerations discussed above, it is concluded that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

==5.0      ENVIRONMENTAL CONSIDERATION==

A review has determined that this TS amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or

L-2016-008 Enclosure Page 10 of 23 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. The NRC has previously issued a proposed finding that similar amendments to the CE STS involve no significant hazards considerations, and there was no public comment on the finding.
Accordingly, the proposed changes meet 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 to be prepared in connection with the proposed amendments.

==6.0     REFERENCES==
: 1.      Combustion Engineering Owners Group Topical Report, CE-NPSD-91 1-A and Amendment 1-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specification End-of-Cycle Negative MTC Limits, dated September 15, 2000.
: 2.      Westinghouse Topical Report WCAP-16045-P-A, Revision 0, Qualification of the Two-Dimensional Transport Code PARAGON, August 2004, and NRC Safety Evaluation for the Topical Report, dated March 18, 2004.
: 3.      US Nuclear Regulatory Commission Safety Evaluation, St. Lucie Plant, Unit Nos. 1 and 2 - Issuance of Amendments Regarding Moderator Temperature Coefficient Surveillance Requirements (TAC No s. MF 1888 and MF 1889), dated September 16, 2014.
: 4.      US Nuclear Regulatory Commission Letter, Acceptance for Referencing of CE NPSD-911, "Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specifications End-of-Cycle Negative MTC Limit", and Amendment 1 (TAC NO. MA9036), dated June 14, 2000.
: 5.      Westinghouse Letter LTR-NRC-05-37 to NRC (ADAMS Accession No. ML051740481),
EOL MTC Elimination Informational Benchmark, dated June 17, 2005.
: 6.      US NRC Safety Evaluation, Palo Verde Generating Station, Units 1, 2, and 3 - Issuance of Amendments Re: Technical Specification Change Regarding Moderator Temperature Coefficient Surveillance For Startup Test Activity Reduction Program (TAC Nos.
M\F3 143, MIF3 144, and MF3 145). dated March 30, 2015.
: 7.      US NRC Safety Evaluation, Waterford Steam Electric Station, Unit 3 - Issuance of Amendment Re: Moderator Temperature Coefficient Test Near End of Each Cycle (TAC No. MA378 1), dated April 21, 2000.
: 8.      US NRC Safety Evaluation, Arkansas Nuclear One, Unit No. 2 - Issuance of Amendments Re: Deletion of Moderator Temperature Coefficient (MTC) Determination at Two-Thirds Core Burnup (TAC No. MB 1840), dated November 16, 2001.

L-20 16-008 Enclosure Page 11 of 23 Attachment 1 Markup of Technical Specification Pages Unit 1 3/4 1-6 6-1 9b Unit 2 3/4 1-5 6-20e

L-20 16-008 Enclosure Page 12 of 23 Attachment 1 FffACItVITY COWTROL SYSTEMS SURVEILLANCE REOUIREMENTS tcntflued}                                                                   .
4.11 42_3*      \ eri~ MTc :is    - inthNe low*er limit Specif itd.in~ the.C Each fuiel :c~c e *n~hnn 7 EFFO of reach~ho f3f       dexpeced core bumiup.
If MIC is more ne..ative: tlian the low*er limit *pec~ied .inthe: CCLR *&#xa2;1.en e;*tnapvlated to the~endl of cycl, 4.11.4*2 may be repeated;. Shutdowq :must occur prior to exceeding the minimum altOoabie boron :concerntra*ont wthic MTC *s projected to e. teed :the ot Li oi_ - UNT 'I

L-20 16-008 Enclosure Page 13 of 23 Attachment 1
.ADINIS*ITRATIVE C'PNTROLS coRE OPENRAING LiMITS REzPORT-(co~ntinued}
: 20. EMF:-I961 (PA){A :Statfs tel Setpontiranien~t Methodolcgy forr Con *busfion Engineering .Type Reactors"
: 21. EMF*-2310{ P)A). "SRP Chlapter 151Nor-LOCA M1ethodcolg! for Pres*surized Wate Reac~crs," Revision* 1; as sup emnerded b.
ANP-*3OtX(Pl,. "St.Lucie Unit I' EPIJ - lnfonnatinr to Suppo*rt License Amendment Requea.L' R~evisiorn 0.
: 22. EMF-2328(PJ A] 'PWR Small Break LOCA Evaluation Mcde*, 5-RELARS Etased? Revision 0;: as supplemented by AN P-3D*00{P), "StL.Lucvie Unit "I EPU1 - lnfoirnatb.n to ,up ornUcense A~mendment Recquest? Revision &.
: 23. E F*-2 03(P{A.), &deg;Realistic Large Brea~kLOCA M~eloology for Pressuri.ed Jater Reacors* Revson %        ;as sapplen ented$by ANP-2903(P}, ='St. Lucie N uclear Plant.Linit.1 EPUI Cycle Realistic Large BreaIk LOICA sumniar Report wilb Zr-4. Fue Clt            "~Re ""    1..
: 24. *-AW-IQ240(P (A) Revisin 0, incrporation f M5 Properie ir                            '
Frana~toire AN{P Appr oved M~ethods?".
sTr LUC;IE- urrr!1I                                                    AzN.nendnent Nc44 Ig4;   , 4-41-..

L-2016-008 Enclosure Page 14 of 23 Attachment 1 REAG1VITY COH*TROI_ SYSTEM:S MOPERAOR TETAPERA lRE COEFFICIE1m L1uITImJG CONDITION FOP OPEPJTION specifed in the ,COLR_ The m~aximu*m upj*er lImit shal be +5.pe dtF at 70Z%of.RATED:
THERMAL POWEP* with a :lix~ar ramp. from +5 pcm-)~W at 70% o~f RATE) ThER:MAL SPOWER to 0 pan. F at 100%!* R:ATD ThIPRMAL POW'*ER.
APPLIgAP:IUTY; :MODES IND 2"#.'
ACTION:
J*lt the modlerator           ipe~*reture imetllen* oue~d; *I. 'ere ef the ab~te ruita, be in a*t l~act H-oT
  *S-TANDEY *,i~in 6 h~ours.
* IJPVEILIANCE PE             ~t:IPEMFNTN 4A. iA-4A*1   ,eify, MTC i:s, wi-hin       seupper uin- specifi~ed in LCO 3.. IA:..
a:        :Prior toentelirg IMODE 1:.after each fuel load~g: and
: b.        Each fu~e cycle Wid[h 7:effe& efull              er*days {ErDI)ofreacing*4D EFPB:
core I unup.*
  #       See: Special Test *.eplin 310t2 a~nd 3:10.5.
* V [:h
* reaterl*aflot equa! t i o.
:**:    Only requi~red to :beerform~ed when".f MlC d~ete~rr*,hed prior to eteting.MO:DE ! is verifed* using ad*u cp edc-tecd MC:.                  :"...."
fM
       .* T&TC.is    more n egati ve a.n tlhe lower IiTt specified in the COLR when e rapolatec to the en~d of :cycle, 4: 1 4.2 maybe repea ed.* Shutdown* must occitr prir to exceeding: the mirnimu aliowab e boron concetraton at               ir~cMTC Ls projected io exc.eed the [ower limi.
lulired if be       TC dot rufoed
~          Lorras ot~ iii~ eegn ~elue.                       ~n SR 4.11.       1 is not     'bin +  tO      ni Fof the ST; LL*E -UNiT 2:                                     *,&,*: t -5,           ST.
Arrec    ent N~4~~/4 LLCE~UNff.       1-5.   ~,  4~

L-2016-008 Enclosure Page 15 of 23 Attachment 1 ANAIWSTRAT1VF CONTROl S rintinned CORE OPERATiNG UNIITS REPORT (COLRI (tOrlU
: b.  (CO nued
: 61.        ATh11397-PA Rro~detary~, 'Rev<sedTherrnat Design Procedure~'ApnI 19&9~
              &#xa3;2     WCAP4456&$A ~Prop4etary,, PRE-O Modt ng and Oval cat                         ~&
Ptai&utaed Wa ~React&r Non.LOCA                       ~jdratjiicSa    An       t, OtM*r 1999.
              ~3       CAP.145         AAOdeneiuml" attica              ofAEBCrlfica1fie~tFlu Correlations          PREOl ode, May 2001
: 64. Letter. N~ Jelferson Jr FPL) to Document Con liDesk USNRC), tSL Lu& U 2 Docket No. 5D-2~99 Proposed Ucens~ Amendriieat '~CAP-.
9272 Reload Methodology and I omen op 3QV Steam GrwatorT U     t-20D3~275.Dece           ZOOd NRCSEa telI January 1, ettqrSTNtg ey NRC) ig4A$lo!l FPL TAC~MC                         t
: 65. W&AP-14502PAR ~U 'RETRAN-O2                             wind         ilt    for Was              Pressunzed Water Reac~ NOUVLOCA Sat Aniysas~
Apri 1909.
              &#xa3;6,      GAP-79O9- Re 0 TACTRAN-A FORTRAN fVCade form Transients m a 1J02 Fuel Rod', Decemlxr 1929.
              ~r     AOAW 799~              va MNKkE~Af                 DimenalonalNeut erqpd~ January 1975
                & WOAP~75$6 Re IA'ME a. tonoP R~Ele&onAcctentin Wesingliouse Pressurized Wa er geactnt~               Special ~netlCs a       at January 1975.
: c. The core operahng aSts shall be deterorned suth that appbcdblern4se g, fuel thermal mechanIcal P         cOre hennal          Ii linus         enw~Otre Cool big Sytnis'(ECCS             , 6u ear keats.       as SHUTDCVJJ MARITht ant       jss ctsts, and accident anal~srs ~m tS ~fTh# safety anatysts 3W
: 4. iie COLR.         ud g      mid        re ~K i's   supplem&rts shall be           #4 upos        ancefornc reload cycleon eNRC; V       -  ss4r       ReVsionW          at c ti jno to           niftiest   ~p       K Tm oriCQil PARAI                At Ansi       DOt ST. LLICtE L   2                                   -20&                An~endrrent Nn~4~~J-,t-~33y-3t, rr~ ma

L-20 16-008 Enclosure Page 16 of 23 Attachment 2 Word Processed Technical Specification Pages Unit 1 3/4 1-6 6-19b Unit 2 3/4 1-5 6-20e

L-20 16-008 Enclosure Page 17 of 23 Attachment 2 REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (continued) 4.1.1 .4.2***    Verify MTC is within the lower limit specified in the COLR.****
Each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup.
k'' If MTC is more negative than the lower limit specified in the COLR when extrapolated to the end of cycle, 4.1.1.4.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.
Only Required ifthe MTC determined in SR 4.1.1.4.1 is not within _+1.6 pcmPF of the corresponding design value.
ST. LUCIE - UNIT 1                                3/4 1-6                ST.
LCIE UNIT13/1-6Amendment No. 2~~-9,

L-20 16-008 Enclosure Page 18 of 23 Attachment 2 ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT (continued)
: 20. EMF-1 961 (P)(A), "Statistical Setpoint/Transient Methodology for Combustion Engineering Type Reactors"
: 21. EMF-2310(P)(A), "SRP Chapter 15 Non-LOCA Methodology for Pressurized Water Reactors," Revision 1, as supplemented by ANP-3000(P), "St. Lucie Unit 1 EPU - Information to Support License Amendment Request," Revision 0.
: 22. EMF-2328(P)(A), "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based," Revision 0, as supplemented by ANP-3000(P), "St. Lucie Unit 1 EPU - Information to Support License Amendment Request," Revision 0.
: 23. EMF-2103(P)(A), "Realistic Large Break LOCA Methodology for Pressurized Water Reactors," Revision 0, as supplemented by ANP-2903(P), "St. Lucie Nuclear Plant Unit 1 EPU Cycle Realistic Large Break LOCA summary Report with Zr-4 Fuel Cladding," Revision 1.
: 24. BAW-1 0240(P)(A) Revision 0, "Incorporation of M5 Properties in Framatome ANP Approved Methods."
: 25. WCAP-1 6045-P-A, Revision 0, "Qualification of the Two -Dimensional Transport Code PARAGON," August 2004.
ST. LUCIE - UNIT 1                               6-19b                  Amendment No. -16, 4-T-1, l:4-4, 2-13,248

L-20 16-008 Enclosure Page 19 of 23 Attachment 2 REACTIVITY CONTROL SYSTEMS MODERATOR TEMPERATURE COEFFICIENT LIMITING CONDITION FOR OPERATION 3.1.1.4       The moderator temperature coefficient (MTC) shall be maintained within the limits specified in the COLR. The maximum upper limit shall be +5 pcm/&deg;F at < 70% of RATED THERMAL POWER, with a linear ramp from +5 pcm/&deg;F at 70% of RATED THERMAL POWER to 0 pcm/&deg;F at 100% RATED THERMAL POWER.
APPLICABILITY: MODES 1 AND 2*#.
ACTION:
With the moderator temperature coefficient outside any one of the above limits, be in at least HOT STANDBY within 6 hours.
SURVEILLANCE REQUIREMENTS 4.1.1.4.1     Verify MTC is within the upper limit specified in LCO 3.1.1.4.
: a.       Prior to entering MODE 1 after each fuel loading, and
: b.       Each fuel cycle within 7 effective full power days (EFPD) of reaching 40 EFPD core burnup.   **
4.1.1.4.2"**       Verify MTC is within the lower limit specified in the COLR.*~**
Each fuel cycle within 7 EFPD of reaching 2/3 of expected core burnup.
#      See Special Test Exception 3.10.2 and 3.10.5.
* With Keff greater than or equal to 1.0.
**     Only required to be performed when MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC.
**     If MTC is more negative than the lower limit specified in the COLR when extrapolated to the end of cycle, 4.1.1.4.2 may be repeated. Shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.
   ... Only Required if the MTC determined in SR 4.1.1.4.1 is not within +_1.6 pcm/&deg;F of the corresponding design value.
ST. LUCIE - UNIT 2                                3/4 1-5              Amendment No. 44, 26, 86, 92, 426,,
468

L-20 16-008 Enclosure Page 20 of 23 Attachment 2 ADMINISTRATIVE CONTROLS (,continued)
CORE OPERATING LIMITS REPORT (COLR) (continued)
: b.     (continued)
: 61. WCAP-1 1397-P-A, (Proprietary), 'Revised Thermal Design Procedure," April 1989.
: 62. WCAP-14565-P-A, (Proprietary), 'V/IPRE-Ol Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis,"
October 1999.
: 63. WCAP-14565-P-A, Addendum 1, "Qualification of ABB Critical Heat Flux Correlations with VIPRE-O1 Code," May 2003.
: 64. Letter, W. Jefferson Jr. (FPL) to Document Control Desk (USNRC), 'St.
Lucie Unit 2 Docket No. 50-389: Proposed License Amendment WCAP-9272 Reload Methodology and Implementing 30%* Steam Generator Tube Plugging Limit," L-2003-276, December 2003 (NRC SER dated January 31, 2005, Letter B.T. Moroney (NRC) to J.A. Stall (FPL), TAC No. MC1566).
: 65. WCAP-14882-P-A, Rev. 0, "RETRAN-02 Modeling and Qualification for Westinghouse Pressurized Water Reactor Non-LOCA Safety Analyses",
April 1999.
: 66. WCAP-7908-A, Rev. 0, "FACTRAN-A FORTRAN IV Code for Thermal Transients in a UO2 Fuel Rod", December 1989.
: 67. WCAP-7979-P-A, Rev. 0, "TWINKLE - A Multi-Dimensional Neutron Kinetics Computer Code", January 1975.
: 68. WCAP-7588, Rev. 1-A, "An Evaluation of the Rod Ejection Accident in Westinghouse Pressurized Water Reactors Using Special Kinetics Methods", January 1975.
: 69. WCAP-1 6045-P-A, Revision 0, 'Qualification of the Two-Dimensional Transport Code PARAGON," August 2004.
: c. The core operating limits shall be determined such that all applicable limits (e.g.,
fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SHUTDOWN MARGIN, transient analysis limits, and accident analysis limits) of the safety analysis are met.
: d. The COLR, including any mid cycle revisions or supplements, shall be provided upon issuance for each reload cycle on the NRC.
ST. LUCIE - UNIT 2                                  6-20e                 Amendment No.4-05,1448, 4,=%,42,8, 44-7, 46,

L-2016-008 Enclosure Page 21 of 23 Attachment 3 Proposed Technical Specification Bases Change (Information Only)
INSERT A:
SR 4.1.1.4.2 is only required if the MTC determined in SR 4.1.1.4.1 is not within +/-1.6 pcm/&deg;F of the corresponding design value when the difference cannot be reconciled. Analysis has shown that if the results of the beginning of cycle moderator temperature coefficient verification fall within +1.6 pcm/ 0 F of the corresponding design values, then it can be assumed that the end of cycle coefficient will also agree with the design value within +/-1.6 pcm/&deg;F and the measurement at EOC is not required.

L-20 16-008 Enclosure Page 22 of 23 Attachment 3
                            *_*    TECHNICAL .SPESCIE-CATION',S                               .*-...
      .....                     BASES ATTACH EtC*S* A             *OF sif2o4 *
:3141.1i;    B ORATION :CONTROL (tCOfur*nid)!
3/4.1..1:.41  MODE{RATOR TEMPERATURE C:OEFFICIENT !MTC) (continu~ed}:
SR 4.:11 :4]2 is moied by a No*eawvih'h indicates that iti[he extrapolatedl SutveXl~nce: may :be repeca~d;     andthe .uldormd .must occur pnrf :toi exceeding the minimum allo; abie,boron Icon can ra onI1                  ic~t:ii4 I.
JTC   :is*
pro~ec ed to exceed: h~e i ccelimi~t' Ad ev ualon :to detarin te li s; iiThe saTely alyexpcS:* iesriot violgateda.ort**odirs:
             *:Ttherequireer:nt     or meaurene         w*tsin e *FPI v*"Bofm       *reahn   23itcire a:
bump,atisfie T::*sirmiantoycte the co                      i the~ mosta -ative        IT aue pre.     ~atd EQ_ MT        "ieeautdIeoer&ro                         ~     ~~ ece peiniit; direct cmaiso          h    T         lsspcfe       nteCL

L-20 16-008 Enclosure Page 23 of 23 Attachment 3
       *c~~qc~~o.:                    t       TECHNICAL SPECIFICATIOgNS                    #:E*. i.,:  *.
         *so*;:- ..............          .. :REACTIVilY CONTROL SYSTEM~S" S....                      ... S:T. LUCIE UNIT. 2      ....
                 .BASES: (con inued) 3 41*.*1.4:        MODERATOR TEMNPERATURE COEFFICIENT (co0itned) e ceed~ing the minirnm ailo ;*a e-tb*i:on centration at *hich M*TC; *S.
                 *in h!e sfe!t aniIyss is.no! 'iolated; T *e requireent for mreasuremnt,,,( iiin"7 EFPDof r"*eachin8 123 co0re up, sasfe ~cthec nfi~rmaotlt*ectof       whe.no~t nghe      MTC vati lu4hte.
Tkeaor.Oooasu nt              pSfore a d any, te TeHERMALe      Pes ER~
5so; TIh pOjEc            LEOC s~TC nta sbem    evaubbated' bfore h~e rea.tcr ..p~ essehesse isEO i:S       cbove on.aa R.TC. a-es etra.e: "e"k :o an.... ....... a"
:SERmi          ieT:&A       rie oeM               issee          nteCt}}