View source for L-2017-139, License Amendment Request to Add New Required Actions for an Inoperable Auxiliary Feedwater Pump Steam Supply

{{Adams
| number = ML17257A300
| issue date = 09/14/2017
| title = License Amendment Request to Add New Required Actions for an Inoperable Auxiliary Feedwater Pump Steam Supply
| author name = Deboer D
| author affiliation = Florida Power &amp; Light Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000335, 05000389
| license number = DPR-067, NPF-016
| contact person = 
| case reference number = L-2017-139
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 27
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:SEP 1 4 2017                                       L-2017-139 10 CPR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 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 Add New Required Actions for an Inoperable Auxiliary F eedwater Pump Steam Supply Pursuant to 10 CPR 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 establishing newTS required ACTION(s) for an inoperable Auxiliary Feedwater (AFW) pump steam supply and for an inoperable AFW putnp steam supply concurrent with an inoperable motor-driven AFW putnp. The proposed license amendments additionally renumber existing TS required ACTION(s) for the AFW system to accotntnodate the newTS required ACTION(s).
The enclosure to this letter provides FPL's evaluation of the proposed changes. Attachment 1 to the enclosure provides the existing 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 St. Lucie Unit 1 retyped (clean copy) TS pages with revision bars to identify the proposed changes. Attachment 4 provides the St. Lucie Unit 2 retyped TS pages. Attachment 5 provides the existing St. Lucie Unit 1 TS Bases pages marked up to show the proposed changes. Attachment 6 provides the St. Lucie Unit 2 TS Bases marked up pages. The St. Lucie Unit 1 and St. Lucie Unit 2 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 CPR 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 CPR 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.

St. Lucie Nuclear Plant                                                      L-2017 -139-Docket Nos. 50-335 and 50-389                                                Page 2 of2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on SEP 1 4 2017 Sincerely, Dan DeBoer Site Director Florida Power & Light Enclosure 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-2017-139 Docket Nos. 50-335 and 50-389                                                                                                              Enclosure Page 1 of25 ENCLOSURE Evaluation of the Proposed Changes St. Lucie Nuclear Plant, Units 1 and 2 License Amendment Request to Add New Required Actions for an Inoperable Auxiliary F eedwater Pump Steam Supply 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

==3.0     TECHNICAL EVALUATION==
 ..................................................................................................... 5

==4.0     REGULATORYEVALUATION==
 ................................................................................................. 7 4.1    Applicable Regulatory Requirements/ Criteria .................................................................... 7 4.2    No Significant Hazards Consideration ................................................................................. 9 4.3    Conclusion .............................................................................................................................. 10

==5.0     ENVIRONMENTAL CONSIDERATION==
 ........................................................................... 11

==6.0     REFERENCES==
 ............................................................................................................................... 11  -Proposed Unit 1 Technical Specification Pages (markup) ............................. 12  - Proposed Unit 2 Technical Specification Pages (markup) ............................. 14  Proposed Unit 1 Technical Specification Pages (clean copy) ........................ 16 - Proposed Unit 2 Technical Specification Pages (clean copy) .......................... 18 - Proposed Unit 1 Technical Specification Bases Pages (markup) ....................... 20 - Proposed Unit 2 Technical Specification Bases Pages (markup) ....................... 23

St. Lucie Nuclear Plant                                                                       L-2017-1J9 Docket Nos. 50-335 and 50-389                                                                  Enclosure Page 2 of25 1.0     

==SUMMARY==
DESCRIPTION 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 establishing TS required ACTION(s) for an inoperable turbine-driven Auxiliary F eedwater (AFW) pump steam supply and for an inoperable turbine-driven AFW pump steam supply concurrent with an inoperable motor-driven AFW pump. The proposed license amendments additionally renumber existing TS required ACTION(s) for the AFW system to accommodate the newTS required ACTION(s). The proposed license amendm~nts serve to align the St. Lucie Unit 1 and St.
Lucie Unit 2 TS more closely with NUREG-1432, Standard Technical Specifications-Combustion Engineering Plants, Volume 1, Specifications (NUREG-1432, STS) (Reference 6.1).
2.0     DETAILED DESCRIPTION 2.1     System Design and Operation 2.1.1   AF\V System The function of the Auxiliary Feedwater (AF\V) system is to ensure a sufficient supply of cooling water to the Steam Generators when main feedwater is not available. This includes, amongst other design basis requirements, providing cooling water to either one or both Steam Generators (SGs) during normal shutdown and accident conditions in order to,
* Provide sufficient capability for the removal of sensible and decay heat from the reactor coolant system (RCS) during forced or natural circulation cooldown, assuming a single active failure concurrent with a loss of offsite power, and
* Provide sufficient capacity to reduce RCS temperature to 325F (Entry conditions for the Shutdown Cooling System (SDCS) under normal conditions), assuming a single active failure and loss of offsite power.
The AFW system consists of one greater than full-flow capacity turbine-driven AFW pump, two full-flow capacity motor-driven AFW pumps, and associated motor-operated steam-inlet valves, flow control valves, instrumentation, etc. The turbine-driven pump receives steam from the two main steam lines upstream of the main steam isolation valves and exhausts to atmosphere. The two motor driven pumps are powered from independent Class 1E power supplies and the emergency diesel generators in case of a loss

St. Lucie Nuclear Plant                                                                   L-2017-139 Docket Nos. 50-335 and 50-389                                                               Enclosure Page 3 of25 of normal power. The two motor driven AFW pumps discharge to their respective SGs, though normally-isolated cross-connection piping is available to enable either motor driven pump to discharge flow to either SG. The turbine-driven AFW pump discharges to both SGs by means of two lines that are independent of the motor-driven pump pathways and each with their own flow control valve. All three AF\V pumps take suction from the condensate storage tank (CST) which provides the TS minimum gallons of demineralized water for start-up, hot standby and cooldown operations. The Unit 1 and Unit 2 AFW pumps, valves, instrumentation and associated CSTs are independent of each other.
AFW system diversity is provided by virtue of the diverse pump drivers, motor-driven versus steam turbine driven, and the associated AC versus DC valve operators. The design features which assure diversity of power sources are:
* Each motor-driven AFW pump is aligned to a separate diesel generator, with its associated normally closed, motor-operated flow control valves being fed from the same diesel as the pump.
* The turbine-driven AFW pump and its associated normally closed steam inlet and discharge flow control valves are fed from a DC power supply which may be aligned to either the "A" or "B" DC power source.
The AFW system is provided with complete sensor and control instrumentation to enable the system to automatically respond to a loss of SG inventory. The system is automatically initiated from the Control Room.
In addition, AFW can be manually actuated from either the Control Room or locally. The AFW automatic actuation system (AFAS) circuitry resides in the Control Room. The AFAS measurement channels include four SG level signals from each SG. The Control Room operators have the capability for manual operation of the AFW valves before and after AFAS actuation.
During startup, hot standby and cooldown the AFW system is controlled manually by the Control Room operators.
2.2    Current Technical Specifications Requirements 2.2.1   TS 3/4.7.1.2, Auxiliary Feedwater System, establish Limiting Conditions for Operation (LCOs), ACTION(s), Completion Times and Surveillance Requirements (SRs) for the AFW system requirements specified in the St.
Lucie Unit 1 and the St. Lucie Unit 2 TS.
2.2.2   TS 3.7.1.2, ACTION(s) a, band c specify the required ACTION(s) and Completion Times for an inoperable AFW pump, for two inoperable AFW pumps and for three inoperable AFW pumps, respectively.

St. Lucie Nuclear Plant                                                                     L-2017-139 Dbcket Nos. 50-335 and 50-389                                                                Enclosure Page 4 of25 2.2.3    TS 3.7.1.2, ACTION d, states that LCO 3.0.4.b is not applicable. [LCO 3.0.4.b allows entry into a MODE or other applicability condition when a LCO is not met provided a risk assessment is performed addressing the risk-related considerations specified therein.]
2.3    Description of the Proposed Changes 2.3.1    NewTS ACTION for an Inoperable Turbine--DrivenAFWPump Steam
                        ~
The proposed change creates a newTS ACTION for an inoperable AFW pump steam supply and establishes a 7-day Completion Time to restore the inoperable AF\V pump steam supply to OPERABLE status or the affected Unit must be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
The newTS ACTION for an inoperable AFW pump steam supply is numbered TS 3.7.1.2, ACTION a. Accordingly, the existing TS 3.7.1.2, ACTION a, for one inoperable AFW pump is renumbered to become TS 3.7.1.2, ACTION b, as described in Section 2.3.3 below. The proposed changes apply to the St. Lucie Unit 1 and the St. Lucie Unit 2 TS.
2.3.2   NewTS ACTION for an Inoperable AFW Pump Steam Supply and an Inoperable Motor-Driven AFW Pump The proposed change creates a newTS ACTION for an inoperable AFW pump steam supply concurrent with an inoperable motor-dri-ven AFW pump. The proposed change establishes a 48 hour Completion Time to restore either the inoperable steam supply or the inoperable motor-dri-ven pump to OPERABLE status or the affected Unit must be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
The newTS ACTION for an inoperable AFW pump steam supply concurrent with an inoperable motor-dri-ven AFW pump is numbered TS 3.7.1.2, ACTION c. Accordingly, the existing TS 3.7.1.2, ACTION c, for three inoperable AFW pumps is renumbered to become TS 3.7.1.2, ACTION e, as described in Section 2.3.3 below. The proposed changes apply to the St. Lucie Unit 1 and the St. Lucie Unit 2 TS.
2.3.3   Renumber Existing TS 3.7.1.2 Required ACTION(s)
The proposed changes renumber the TS 3.7.1.2 required ACTION(s) as follows:

St. Lucie Nuclear Plant                                                                     L-2017-139 Docket Nos. 50-335 and 50-389                                                                 Enclosure Page 5 of25
* Renumber existing TS 3.7.1.2, ACTION a, to become TS 3.7.1.2, ACTION b;
* Renumber existing TS 3.7.1.2, ACTION b, to become TS 3.7.1.2, ACTION d;
* Renumber existing TS 3.7.1.2, ACTION c, to become TS 3.7.1.2, ACTION e;
* Renumber existing TS 3. 7 .1.2, ACTI 0 N d, to become TS 3. 7 .1.2, ACTION f.
* Add newTS 3.7.1.2, ACTION a, for an inoperable AF\V pump steam supply;
* Add newTS 3.7.1.2, ACTION c, for an inoperable AFW pump steam supply concurrent with an inoperable motor-driven AFW pump; The proposed changes apply to the St. Lucie Unit 1 and the St. Lucie Unit 2 TS.

==3.0     TECHNICAL EVALUATION==

The proposed license amendments modify the St. Lucie Unit 1 and St. Lucie Unit 2 TS by establishing newTS required ACTION(s) for an inoperable AFW pump steam supply and for an inoperable AF\V pump steam suppl;r concurrent with an inoperable motor-driven AF\V pump. The proposed license amendments additionally renumber existing TS required ACTION(s) for the AFW system to accommodate the newTS required ACTION(s).
3.1     NewTS 3.7.1.2. ACTION a. for an Inoperable AFW Pump Steam Supply The proposed change creates a newTS 3.7.1.2, ACTION a, for an inoperable AFW pump steam supply and establishes a 7 day completion time to restore the inoperable AFW pump steam supply to OPERABLE status or the affected Unit must be placed in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
TS 3.7.1.2 currendy requires one AFW pump capable of being powered from an OPERABLE steam suppl;r and imposes a 72-hour completion time in the event of an inoperable AFW pump steam supply. Entering a 72-hour TS ACTION for a single inoperable AFW pump steam supply is unreasonable since the redundant OPERABLE steam supply is available to mitigate postulated accidents assuming no concurrent single active failure. Moreover, a 72-hour completion time for an inoperable AFW pump steam supply does not represent an appropriate balance when weighed against the 72-hours currend;r allotted for the more severe condition of an inoperable AFW pump. NUREG-1432, STS 3.7.5, Auxiliary Feedwater S;rstem, ACTION A (Reference 6.1), provides for a 7-day completion time for a single inoperable AFW steam suppl;r. The proposed change serves to align the St.

St. Lucie Nuclear Plant                                                                    L-2017-139 Docket Nos. 50-335 and 50-389                                                               Enclosure Page 6 of25 Lucie Unit 1 and Unit 2 TS with NUREG-1432, STS 3.7.5, ACTION A, thereby providing a commensurate level of safety when judged against the current regulatory standards established in NUREG-1432 (Reference 6.1) for an inoperable AFW pump steam supply. Hence, creating a newTS 3.7.1.2 required ACTION for an inoperable AFW pump steam supply and establishing a 7-day completion time to restore the steam supply to OPERABLE status is reasonable.
In creating a newTS 3.7.1.2, ACTION a, for an inoperable AFW pump steam supply, the existing TS 3.7.1.2, ACTION a, for-one inoperable AFW pump is renumbered to become TS 3.7.1.2, ACTION b, as discussed in Section 3.3 below.
The proposed renumbering is purely editorial as no other changes are involved, and is therefore reasonable.
3.2    NewTS 3.7.1.2~ACTION c~ foraninoperableAFWPump Steam Supply Concurrent with an Inoperable Motor-Driven AF\V Pump The proposed change creates a newTS 3.7.1.2, ACTION c, for an inoperable AF\V pump steam supply concurrent with an inoperable motor-driven AFW pump and establishes a 48-hour completion time to restore either the inoperable steam supply or the inoperable motor-driven pump to OPERABLE status or the affected Unit must be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
A 48-hour completion time for an inoperable AFW pump steam supply concurrent with an inoperable motor-driven AFW pump is reasonable based on the remaining motor-driven AFW pump's capability to provide the requisite AFW flow credited in the respective Feedwater Line Break (FLB) and Main Steam Line Break (MSLB) safety analyses for St. Lucie Unit 1 and St. Lucie Unit without assuming a concurrent single active failure. Hence, the proposed 48-hour completion time to restore either the inoperable steam supply or the inoperable motor-driven pump to OPERABLE status satisfies the condition specified in Technical Specification Task Force (TSTF)
Traveler, TSTF-412, Revision 3, Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable (Reference 6.2), for plants with motor-driven AFW trains fully capable of mitigating postulated accidents in accordance with applicable accident analyses. The proposed 48-hour completion time represents an appropriate balance between the more severe 24-hour completion time allotted for two inoperable AF\V pumps and the less severe 72-hour completion time for a single inoperable AFW pump, as currently specified in NUREG-1432, STS 3.7.5 (Reference 6.1) and the St. Lucie Unit 1 and St. Unit 2 TS.
FPL is not proposing any variations or deviations from the TS changes described in TSTF-412 or the NRC staffs model Safety Evaluation (SE) for TSTF-412 (Reference 6.3), with the exception that TSTF-412 applies to inoperable AFW trains in lieu of inoperable AFW pumps. However in the model SE, the NRC states that a 48-hour completion time is acceptable when the remaining OPERABLE motor-

St. Lucie Nuclear Plant                                                                     L-2017-139 Docket Nos. 50-335 and 50-389                                                                  Enclosure Page 7 of25 driven AFW train is capable of providing sufficient feedwater flow in accordance with accident analysis assumptions and that this would typically apply to plants having AFW motor-driven pumps capable of providing greater than or equal to 100&deg;/o of the required flow. NUREG 1432, Standard Technical Specifications-Combustion Engineering Plants Revision 4.0, Volume 2, Bases (Reference 6.4), similarly states that the 48-hour completion time is applicable to plants that can still meet the safety analysis requirement of 100&deg;/o AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump. Since each of the St. Lucie Unit 1 and St. Lucie Unit 2 motor-driven-AFW pumps are capable of providing 100&deg;/o of the AF\V flow credited in the applicable accident analyses, the proposed 48-hour completion time for an inoperable AFW pump steam supply concurrent with an inoperable motor-driven AFW pump is consistent with the NRC's model SE for TSTF-412 and NUREG-1432, Volume 2, Bases, and is thereby reasonable.
In creating a newTS 3.7.1.2, ACTION c, for an inoperable AFW pump steam supply concurrent with an inoperable motor-driven AFW pump, the existing TS 3.7.1.2, ACTION c, for three inoperable AFW pumps is renumbered to become TS 3.7.1.2, ACTION e, as discussed in Section 3.3 below. The proposed renumbering is purely editorial as no other changes are involved, and is therefore reasonable.
3.3    Renumber Current TS 3.7.1.2 Required ACTION(s)
The proposed changes renumber the TS 3.7.1.2 required ACTION(s) as follows:
* Renumber existing TS 3.7.1.2, ACTION a, to become TS 3.7.1.2, ACTION b;
* Renumber existing TS 3.7.1.2, ACTION b, to become TS 3.7.1.2, ACTION d;
* Renumber existing TS 3.7.1.2, ACTION c, to become TS 3.7.1.2, ACTION e;
* Renumber existing TS 3.7.1.2, ACTION d, to become TS 3.7.1.2, ACTION f.
* Add a newTS 3.7.1.2, ACTION a, for an inoperable AFW pump steam supply;
* Add a newTS 3.7.1.2, ACTION c, for an inoperable AFW pump steam supply concurrent with an inoperable motor-driven AFW pump; The proposed renumbering serves to align the sequence ofTS 3.7.1.2 required ACTION(s) with the sequence of required ACTION(s) established in in NUREG-1432, STS 3.7.5, Auxiliary Feedwater System (Reference 6.1). The proposed changes are purely editorial as no other changes are involved, and are therefore reasonable.

==4.0     REGULATORY EVALUATION==

4.1    Applicable Regulatory Requirements I Criteria

St. Lucie Nuclear Plant                                                                     L-2017-139 Docket Nos. 50-335 and 50-389                                                                 Enclosure Page 8 of25
* 10 CPR 50.36, Technical Specifications, requires the establishment of an LCO for any structure, system or component (SSC) satisf)ring the criteria of 10 CPR 50.36(c) (2)(ii).
* General Design Criteria (GDC) 20 of Appendix A to 10 CPR 50 states that protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sens_e accident conditions and to initiate the operation of systems and components important to safety.
* GDC 21 of Appendix A to 10 CPR 50 states that the protection system shall be designed for high functional reliability and inservice testability commensurate with the safety functions to be performed. Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated.
* GDC 22 of Appendix A to 10 CPR 50 states that the protection system shall be designed to assure that the effects of natural phenomena, and of normal operating, maintenance, testing and postulated accident conditions on redundant channels do not result in loss of the protection function, or shall be demonstrated to be acceptable on some other defined basis. Design techniques, such as functional diversity or diversity in component design and principles of operation, shall be used to the extent practical to prevent loss of the protection function.
* GDC 29 of Appendix A to 10 CPR 50 states that the protection and reactivity control systems shall he designed to assure an extremely high probability of accomplishing their safety functions in the event of anticipated operational occurrences.
* GDC 44 of Appendix A to 10 CPR 50 states that a system to transfer heat from structures, systems and components important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions.
The proposed changes comply with the requirements of 10 50.36(c)(2)(ii) and do not alter the manner in which the St. Lucie Unit 1 and St. Lucie Unit 2 AFW systems are operated and maintained, consistent with GDCs 20, 21, 22, 29 and 44. Therefore, all applicable regulatory requirements will continue to be satisfied as a result of the proposed changes.

St. Lucie Nuclear Plant                                                                       L-2017-139 Docket Nos. 50-335 and 50-389                                                                  Enclosure Page 9 of25 4.2    No Significant Hazards Consideration The proposed license amendments modify the St. Lucie Unit 1 and St. Lucie Unit 2 Technical Specifications (TS) by establishing TS required ACTION(s) for an inoperable turbine-driven Auxiliary F eedwater (AF\\7) pump steam supply and for an inoperable turbine-driven AFW pump steam supply concurrent with an inoperable motor-driven AFW pump. The proposed license amendments additionally renumber existing AF\V system TS required ACTION(s) to accommodate the new TS required ACTION(s).
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 Auxiliary F eedwater (AF\\7) system is not an initiator of any design basis accident or event, and therefore the proposed changes do not increase the probability of any accident previously evaluated. The proposed changes to address the condition of one inoperable AFW pump due to an inoperable steam supply or one inoperable AFW pump due to an inoperable steam supply concurrent with one inoperable motor-driven AFW pump do not change the response of the plant to any accidents. The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not adversely affect the ability of structures, systems, and components (SSCs) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of any accident previously evaluated. Further, the proposed changes do not increase the types and amounts of radioactive effluent that may be released offsite, nor significandy increase individual or cumulative occupational/ public radiation exposures.
Therefore, facility operation in accordance with the proposed license amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.

St. Lucie Nuclear Plant                                                                       L-2017-139
-Docket Nos. 50-335 and 50:..389                                                               Enclosure Page 10 of25 (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 changes do not result in a change in the manner in which the AFW system provides plant protection. The AFW system will continue to supply water to the Steam Generators to remove decay heat and other residual heat by delivering at least the minimum required- flow rate. There are no design changes associated with the proposed changes. The changes to the required actions and completion times do not change any existing accident scenarios, nor create any new or different accident scenarios. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements or eliminate any existing requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
(3)      Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined.
The safety analysis acceptance criteria are not impacted by these changes.
The proposed changes will not result in plant operation in a configuration outside the design basis.
Therefore, operation of the facility in accordance with the proposed amendment will 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.
4.3    Conclusion

Si:. Lucie Nuclear Plant                                                                        L-2017-139 Docket Nos. 50-335 and       50-38~                                                              Enclosure Page 11 of25 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     NUREG-1432, Standard Technical Specifications- Combustion Engineering Plants, Revision 4.0, Volume 1, Specifications (Accession No. ML12102A165) 6.2     Technical Specification Task Force (TSTF) Traveler, TSTF-412, Revision 3, Provide Actions for One Steam Supply to Turbine Dri-ven AFW/EFW Pump Inoperable.
(Accession No. ML070100363) 6.3     Notice of A-vailability of Model Application Concerning Technical Specification Task Force (TSTF) Traveler to Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable Using the Consolidated Line Item Improvement Process, Federal Register, Volume 72 Issue 136, July 17, 2007 (72 FR 39089) 6.4     NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants Revision 4.0, Volume 2, Bases (Accession No. ML12102A169)

St. Lucie Nuclear Plant                                         L-2017-139 Docket 1'-Jos. 50-335 and 50-389                                 Enclosure Page 12 o&#xa3;25 Attachment 1 ST. LUCIE UNIT 1 PROPOSED TECHNICAl:. SPECIFICATIONS PAGE (MARKUP)
(1 page follows)

St. Lucie Nuclear Plant                                                                                         L-2017-139 Docket Nos. 50-335 and 50-389                                                                                    Enclosure Page 13 of25 Attachment 1 PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2     At least three independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:
: a. Two motor driven feedwater pumps, and
: b. One feedwater pump capable of being powered from an OPERABLE steam supply system.
APPLICABILITY: MODES 1, 2 and 3.
ACTION:
                       '       With one auxiliary feedwaterpump inoperable, restore the auxiliary feedwater pump to OPERABLE status within 72 hours or be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
With two auxiliary feedwater pumps inoperable; be in atleast HOT STANDBY within 6hours and in HOT SHUTDOWN within the .following 6 hours.
NOTE LCO 3.0.3 and all other LCO Actions requiring MODE changes are suspended until one AFW pump is restored to OPERABLE status.
With three auxiliary feedwater pumps inoperable., immediately initiate corrective action to restore at least one auxiliary feedwater pump to OPERABLE status.
LCO 3.0.4.b is notapplicable.
SURVEILLANCE REQUIREMENTS 4.7.1.2     Each auxiliary feedwater pump shall be demonstrated OPERABLE:
: a. In accordance with the Surveillance Frequency Control Program by:
: c. With.one auxiliary feedwaterpump steam supply inoperable and one motor-driven auxiliary feedwater pump inoperable, either restore the inoperable auxiliary
           -              feedwater pump steam supply OR restore the inoperable motor-driven auxiliary feedwater pump to OPERABLE status within 48 hours or be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
: a. With one auxiliary feedwaterpump.steam supply inoperable, restore the inoperable auxiliary feedWater pump steam supply to OPERABLE status Within 7 days or be .in at leastHOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
ST. LUCIE- UNIT 1                                3/4 7-4              Amendment No. ~. 00, 499, ~.
223,2&#xa3;9-

St. Lucie Nudear Plant                                       L-2017-139 Docket Nos. 50-335 and 50-389                                 Enclosure Page 14 of25 Attachment 2 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGE (MARKUP)
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St. Lucie Nuclear-Plant                                                                                                L-2017-139 Docket Nos. 50-335 and 50-389                                                                                           Enclosure Page 15 of25 Attachment 2 PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2     At least three independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:
: a. Two feedwater pumps, each capable ofbeing powered from separate OPERABLE emergency busses, and
: b. One feedwaler pump capable of being powered from an OPERABLE steam supply system.
APPLICABILITY: MODES 1, 2, and 3.
ACTION:
With one auxiliary feedwater pump inoperable, restore the auxiliary feedwater pump to OPERABLE status within 72 hours or be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
With two auxiliary feedwater pumps inoperable, be in at least HOT STANDBY within 6 hours and in HOTSHUTDOWN within the following 6 hours.
NOTE LCO 3.0.3 and all other LCO Actions requiring MODE changes are suspended until one AFW pump is restored to OPERABLE status.
With three auxiliary feedwater pumps inoperable; immediately initiate corrective action to restore at least one auxiliary feedwater pump to OPERABLE status.
LCO 3;0.4.b is not applicable.
SURVEil L ANCE REQUIREMENTS 4.7.1.2     Each auxiliary feedwater pump shall be demonstrated OPERABLE:
: a. In accordancewiththe Surveillance Frequency Control Program by:
: 1. Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.
: c. Wlth one auxiliary .feedwaterpump steam supply inoperable and one motor-driven auxiliary feedwater pump inoperable, either restore the inoperable auxiliary feedwater pump steam supply OR restore the inoperable motor-driven auxiliary feedwater pump to OPERABLE status within 48 hours or be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
: a. Wlth one auxiliary feedwater pump .steam supply inoperab!~. restore the inoperable auxiliary feedwater pump steam supply to OPERABLE status within 7 days or be in atleastHOTSTANDBY within the next 6 hoursand'in HOT SHUTDOWN within the following 6. hours.
ST. LUCIE- UNIT 2                                   3/47-4                 Amendment No. ~. 441, .:t+G,
                                                                                        .!f.+g, 4=t9

St. Lucie Nuclear Plant                                         L-2017-139 Docket Nos. 50-335 and 50-389                                    Enclosure Page 16 o&#xa3;25 Attachment 3 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS PAGE (Clean Copy)
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St. Lucie Nuclear Plant                                                                                          L-2017-139 Docket Nos. 50-335 and 50-3-89                                                                                    Enclosure Page 17 of25 Attachment 3 PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2     At least three independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:
: a. Two motor driven feedwater pumps, and
: b. One feedwater pump capable of being powered from an OPERABLE steam supply system.
APPLICABILITY: MODES 1, 2 and 3.
ACTION:
: a. With one auxiliary feedwaterpump steam supply inoperable, restore the inoperable auxiliary feedwater pump steam supply to OPERABLE status within 7 days or be .in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
: b. With one auxiliary feedwater pump inoperable, restore the auxiliary feedwater pump to OPERABLE status within 72 hours or be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
: c. With one auxiliary feedwater pump steam supply inoperable and one motor driven auxiliary feedwaterpump inoperable, either restore the inoperable auxiliary feedwater pump steam supply OR restore the inoperable motor driven auxiliary feedwater pump to OPERABLE status within 48 hours or be in at leastHOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
: d. With two au>tiliary feedwater pumps inoperable, be in at least HOT STANDBY within 6 hours and in HOT SHUTDOWN within the following 6 hours.
NOTE LCO 3.0.3 and all other LCO Actions requiring MODE changes are suspended until one AFW pump is restored to OPERABLE status.
: e. With three auxiliary feedwater pumps inoperable, immediately initiate corrective action to restore at least one auxiliary feedwater pump to OPERABLE status.
: f. LCO 3.0.4.b is not applicable.
SURVEILLANCE REQUIREMENTS 4.7.1.2     Each auxiliary feedwater pump shall be demonstrated OPERABLE:
: a. In accordance. with the Surveillance Frequency Control Program by:
ST. LUCIE- UNIT 1                                 3/47-4              Amendment No. ga, 00, 499, ~.
                                                                                   ~.~

St. Lucie Nuclear Plant                                             L-2017-139 Docket Nos. 50-335 and 50-389                                        Enclosure Page 18 of25 Attachment 4 ST. LUCIE UNIT 2 PROPOSED    TECHNICAL  SPECIFICATIONS PAGE (Clean Copy)
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St. Lucie Nuclear Plant                                                                                              L-2017-139 Docket Nos. 50-335 and 50-389                                                                                         Enclosure Page 19 o&#xa3;25 Attachment 4 PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2     At least three independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:
: a. Two feedwater pumps, each capable ofbeing powered from separate OPERABLE emergency busses, and
: b. Onefeedwater pump capable of oeing powered from an OPERABLE steam supply system.
APPLICABILITY: MODES 1, 2, and 3.
ACTION:
: a. With one auxiliary feedwater pump steam supply inoperable, restore the inoperable auxiliary feedwater pump steam supply to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
: b. With one auxiliary feedwater pump inoperable, restore the auxiliary feedwater pump to OPERABLE status within 72 hours orbe in at leastHOTSTANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
: c. With one auxiliary feedwater pump steam supply inoperable and one motor driven auxiliary feedwater pump inoperable, either restore the inoperable auxiliary feedwaterpump steam supply OR restore the inoperable motor driven auxiliary feedwater pump to OPERABLE status within 48 hours or be in at least HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours.
: d. With two auxiliary feedwater pumps inoperable, be in at least HOT STANDBY within .6 hours and in HOT SHUTDOWN within the following 6 hours.
NOTE LCO 3.0.3 and all other LCO Actions .requiring MODE changes are suspended until one AFW pump is restored to OPERABLE status.
: e. With three auxiliary feedwater pumps inoperable, immediately initiate corrective action to restore atleast one auxiliary feedwater pump to OPERABLE status.
: f. LCO 3.0.4.b is not applicable.
SURVEILLANCE REQUlREMENTS 4.7.1.2     Each auxiliary feedwater pump shall be demonstrated OPERABLE:
: a. In accordance with the Surveillance Frequency Control Program by:
: 1. Verifying that each valve (manual, power-operated, or automatic) in the flow path thatis not locked, sealed, or otherwise secured in position, is in its correct position.
ST. LUCIE- UNIT 2                                    3/47-4               Amendment No. ~. 4-4@, +1-G, 4-+3, .1-14

St. Lucie Nuclear Plant                                      L-2017-139 Docket Nos. 50-335 and 50-389                                 Enclosure Page 20 o&#xa3;25 Attachment 5 ST. LUCIE UNIT 1 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES (MARKUP)
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St. Lucie Nuclear Plant                                                                                          L-2017-139 Docket Nos. 50-335 and 50-389                                                                                        Enclosure Page 21 o&#xa3;25 Attachment 5 SECTION NO.:                                                                         PAGE:
TITLE:      TECHNICAL SPECIFICATIONS 3/4.7                    BASES ATTACHMENT9 OF ADM-25.04                          4of}6 REVISION NO.:                                 PLANT SYSTEMS ST. LUCIE UNIT 1 3/4.7             PLANT SYSTEMS (continued)                                                    ***.**
BASES .(continued) 3/4.7.1           TURBINE CYCLE {continued) 106.5   =    Power Level-High Trip Setpoint for two loop operation X= Total relieving capacity of all safety Valves per steam line in lbs/hour (6.192 x 106 lbs/hr.)
Y= Maximum relieving capacity ofany one safety valve in lbslhour (7.74 x 105 lbs/hr.)
Surveillance Requirement 4.7.1.1 verifies the OPERABILITY of the MSSVs by the verification ofeach MSSV lift setpoint in accordance with the lnservice Testing Program. The MSSV setpointsare 1000 psia +/-3%
(4 valves each header) and 1040 psia +2/-3% (4 valves each header) for OPERABILITY; however, the valves are reset to 1000 psia +/-1% and 1040 psia +/- 1 %, respectively, during the Surveillance to allow for drift.
The LCO is expressed in units of psig for consistency with implementing procedures.
3/4.7.1.2         AUXILIARY FEEDWATER PUMPS The OPERABILITY of the auxiliary feedwaterpumps ensures that the Reactor Coolant System can be cooled down to less than 325&deg;F from normal operating conditions in the event of a total loss ofoff-site power.
Any two of the three auxiliary feedwater pumps have the required capacity to provide sufficient feedwaterflow to remove reactor decay heat and reduce the RCS temperature to 325&deg;F where the shutdown cooling system may be placed into operation for continued cooldown.
I!NSERTA
                        ........ ~~-&prohibits the application of LCO 3.0.4.b to an inoperable AFW
                        ~~~~_There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFWtrain inoperable and the provisions of LCO 3.0.4.b, which 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, should not be applied in this circumstance.

St. Lucie Nuclear Plant                                                                                      L-2017-139 Docket Nos. 50-335 and 50-389                                                                                 Enclosure Page 22 of25 Attachment 5
                                                   !INSERT A    I In MODES 1, 2, and 3, the AFW System is required to* be OPERABLE and to function in the event thatthe MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace the steam generator secondary inventory lost as the Unit cools to MODE 4 conditions. The following ACTION(s) apply during MODES 1., 2, and 3.
ACTION a establishes a 7-day Completion Time to restore an inoperable turbine driven AFW pump due to an inoperable AFWpump steam supply. The 7-day Completion Time is reasonable since in addition to the two OPERABLE motor-driven AFW pumps, the redundant OPERABLE steam supply line is available for the turbine driven AFW pump to perform its specified function, assuming no single active failure.
ACTION b establishes a 72-hour Completion Time to .restore an.inoperableAFW pump. This condition includes the loss of both steam supplies to the turbine driven AFW pump. The 72-hour Completion Time is reasonable since two OPERABLE AFW pumps remain either of which are capable of satisfying the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure.
ACTION c establishes a 4a-hour Completion Time to restore either an inoperable motor-driven AFW pump or an inoperable turbine driven AFW pump steam supply in the event of an inoperable motor-driven AFW pump concurrent with an inoperable AFW pump steam supply.
The 48-hour Completion Time is reasonable since the redundant OPERABLE motor-driven AFW pump can satisfy the safety analysis requirementof 100% AFW flow to the SG(s) in the event the remaining turbine driven AFW pump steam supply is rendered unavailable during a FLB or MSLB, assuming no single active failure.
ACTION d requires the Unit to be placed in HOT STANDBY within 6 hours and in HOT SHUTDOWN within the following 6 hours in the event of two inoperable AFW pumps. The allowed Completion Times are reasonable., based on operating experience, to reach the required MODE from full power conditions in an orderly manner and without challenging Unit systems.
ACTION e requires the immediate-restoration of an AFW pump to OPERABLE status in the event of three inoperable AFW pumps. A note to ACTION e suspends LCO 3.0.3 and all other LCO actions requiring MODE changes until one AFW pump .is restored to OPERABLE status.
With all three AFW pumps inoperable in MODE 1, 2, or 3, the Unit is in a seriously degraded condition with no safety-related means for conducting a cooldown, and only limited means for conducting a cooldown with non-safety grade equipment In such a condition, the Unit should not be perturbed by any action, including a power change, that might result in a reactor trip.
The seriousness ofthis condition requires that corrective action be started immediately to restore one AFW pump to OPERABLE status.

St. Lucie Nuclear Plant                                     L-2017-139 Docket Nos. 50-335 and 50-389                                Enclosure Page 23 of25 Attachment 6 ST. LUCIE UNIT 2 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGES (MARKUP)
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St. Lucie Nuclear Plant                                                                                 L-2017-139 Docket Nos. 50-335 and 50-389                                                                             Enclosure Page 24 o&#xa3;25 Attachment 6 ECTION NO::
TITLE:     TECHNICAL SPECIFICATIONS 3/4.7                 BASES ATTACHMENT9 OF ADM-25.04 REVISION NO.:                              PLANT SYSTEMS ST. LUCIE UNIT 2 3/4.7         PLANT SYSTEMS (continued)
BASES (continued) 3/4.7.1       TURBINE CYCLE (continued) 3/4.7.1.2     AUXILIARY FEEDWATERSYSTEM (continued)
The steam turbine-driven AFW pup receives steam from either main steam header upstream of the main steam isolation valve. Each of the steam feed lines will supply 100% ofthe requirements of the turbine driven AFW pump.
The turbine driven AFWpump supplies a common header capable of feeding both steam generators, with DC powered control valves actuated to the appropriate steam generator by the Auxiliary Feedwater Actuation System (AFAS).
The AFW System supplies feedwater to the steam generators during normal unit startup, shutdown, and hot standby conditions.
The AFW System rilitigates the consequences of any event with a loss of normal feedwater. The limiting Design Basis Accidents and transients for the AFW System are as follows:
: 1.      Feedwater Line Break, and
: 2.      Loss of normal feedwater.
Action ~its        the application of LCO 3.0.4..b to an inoperable AFWtrain.
There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO notmet after performance ofa risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

St. Lucie Nuclear Plant                                                                                      L-2017-139 Docket Nos. 50-335 and 50-389                                                                                 Enclosure Page 25 o&#xa3;25 Attachment 6 IH'IISERT A I In MODES 1, 2, and 3, the AFW System is required to be OPERABLE and to function in the eventthat the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace the steam generator secondary inventory lost asth~ Unit cools to MODE 4 conditions. The following ACTION(s) apply during MODES 1, 2, and 3.
ACTION a establish~es a ?-day Completion Time to restorE! an inoperableturbine driven AFW pump due to an inoperable AFW pump steam supply. The 7-day Completion Time is re13sonable since in addition to .the two OPERABLE motor-driven AFW pumps, the redundant OPERABLE steam supply line is available for the turbine driven AFW pump to perform its specified function, assuming no single active failure.
ACTION b establishes a 72-hour Completion Time to restore an .inoperable.AFW pump. This condition includes the loss of both steam supplies to the turbine driven AFW pump. The 72-hour Completion Time is reasonable since'two OPERABLE AFW pumps remain either of which are capable of satisfying the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure.
ACTION c establishes a 48-hour Completion Time to restore either an inoperable motor-driven AFW pump or an inoperable turbine driven AFW pump steam supply in the event of an inoperable motor-driven AFW pump concurrent with an inoperable AFW pump steam supply.
The 48-hour Completion Time is reasonable since the redundant OPERABLE motor-driven AFW pump can satisfy the safety analysis requirement of 100% AFW flow to the SG(s) in the eventthe remaining turbine driven AFW pump steam supply is rendered unavailable during a FLB or MSLB, assuming no single active failure.
ACTION d requires the Unit to be placed in HOT STANDBY within 6 hours and in HOT SHUTDOWN within the following 6 hours in the event of two inoperable AFW pumps. The allowed Completion Times are reasonable, based on operating experience, to reach the required MODE from full power conditions in an orderly manner and without challenging Unit systems.
ACTION e requires the immediate restoration of an AFW pump to OPERABLE status in the event of three inoperable AFW pumps. A note to ACTION e suspends LCO 3.0.3 and all other LCO actions requiring MODE changes until one AFW pump is restored to OPERABLE status.
With all three AFW pumps inoperable in MODE 1, 2, or 3, the Unit is in a seriously degraded condition with no saJety~related means for conducting a cooldown, and only limited means for conductinga cooldown with non-safety grade equipment. In such a condition, the Unit should not be perturbed by any action, including a power change, that might result in a reactor trip.
The seriousness of this condition requires that corrective action be started immediately to restore one AFW pump to OPERABLE status.}}