ML17221A324

Proposed Changes to Tech Spec 3.4.10 Re RCS - Structural Integrity ASME Code Class 1,2 & 3 Components & Section 4.0 Re Surveillance Requirements

ML17221A324
Person / Time
Site:	Saint Lucie
Issue date:	08/17/1987
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17221A325	List: ML17221A324 ML17308A425
References
NUDOCS 8708240048
Download: ML17221A324 (58)

Text

ATTACHMENT I Marked-up TechnicaI Specification Pages 3/4 0-2 B3/4 0-2 3/4 4-26 8 27 3/4 4-28 to 36 3/4 4-37 & 38 3/4 4-39 to 52 3/4 4-53 8 54 3/4 4-55 B3/4 4-I2 B3/4 4-l3 8P08240048 8708017>>>

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APPLICABILITY SURVEILLANCE RE UIREMENTS 4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with:

A maximum allowable extension not to exceed 25K of the test interval, and

b. A total maximum combined interval time for any 3 consecutive surveillance intervals not to exceed 3.25 times the specified surveillance interval.

4.0.3 Performance of a Surveillance Requirement within the specified time interval shall constitute compliance with OPERABILITY requirements for a Limiting Condition for Operation and associated ACTION statements unless otherwise required by the specification.

4.0.4 Entry into an OPERATIONAL MOOE or other specified applicability condi-tion 'shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.

The provisions of Specification 4.0.4 are not applicable to the performance of surveillance activities associated with fire protection technical specifica-tions 4.3.3.7.1. 4.3.3.7.2, 4.7.11.1, 4.7.11.2 and 4.7.12 until the completion of the initial surveillance interva? associated with each specification.

R.Q 5 Surveillance Requirements for inservice inspectlonTand testing]of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

ae Inservice inspection of ASME Code Class 1, 2 and 3 componentsPand, inservice testing ASME Code Class 1, 2 and 3 pumps and valvesgshall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection pand testincgactivities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

ST. LUCIE - UNIT 1 ~

3/4 0-2 Amendment No. gl, 40

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APPLICABILITY SURVEILLANCE RE UIREMENTS Continued 4.0e5 (Continued)

ASME Boiler and Pressure Vessel'Code and applicable Required frequencies Addenda terminology for for performing inservice inservice inspectionCand inspection Pand testing5 testin activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Yearly or annually At least once per 366 days

c. The provisions of Specification 4.0s2 are applicable to the above required frequencies for par farming inservice inspection[and testing/

activities.

d. Performance of the above inservice inspection/and testing)activities shall be in addition to other specified Surveillance Requirements.

e. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any Technical Specification.

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APPLI CAB ILITY BASES

.4.0.1 This'specification provides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MOOES or other condition's for which the Limiting Conditions for Operation are applicable. Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL HOOES or other conditions are provided. in the individual Surveillance Requirements. ~Mt 4.0.2 The provisions of this specification provide allowable tolerances for performing s<:rveillance activities beyond those specified in the nominal surveillance interval. These tolerances are necessary to provide operational flexibility because of scheduling and performance considerations.

The tolerance values, taken either individually or consecutively over 3 .test intervals, are sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not signifi-cantly degraded beyond that obtained from the nominal specified interval.

4.0.3 The provisions of this specification set forth the crit ria for determination of compliance with the OPERABILITY requirements of the Limiting Conditions for Operation. Under this criteria, equipment, systems or components are assumed to be OPERABLE if the associated surveillance activities have been satisfactorily performed within the specified time interval. Nothing in this provision is to be cons .rued as defining equipment, systems or components OPERABLE, when such items are found or known to be inoperable although still meeting the Surveil-lance Requirements.

4.0.4 This specification ensures that the surveillance activities associated with a Limiting Condition for Operation have been performed within the specified time interval prior to entry into an OPERATIONAL HOOE or other applicable condition. The intent of this provision is to ensure that surveillance activities have been satisfactorily demonstrated on a current basis as required to meet the OPERABILITY requirement of the Limiting Condition for Operation.

Under the terms of this specification, for example, during initial plant startup or following extended plant outages, the applicable surveillance activities must be performed within the stated surveillance interval prior to pl'acing or returning the system or equipment into OPERABLE status.

4.0.5 (S~e Wa4ad)

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This specification ensures that inservice inspection of ASME Code Class 1,,2'nd;;3.componentsf.and inservice testing of ASME Code Class 1, 2 and 3 pumps and valvesjwill be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a. Relief from any of the above requirements has been provided in writing by the Commission and is not a part of these Technical Specifications.

This specification includes a clarification of the fgequencies for performing the inservice inspection Pand testing activitiesgrequired by Section XI of theASME Boiler and Pressure Vessel Code and applicable Addenda. This clarification is provided to ensure consistency in surveillance intervals thoughout these Technical Specifications and to remove any ambiguities relative to the frequencies for performing the required inservice inspection Pand testing activities.

Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Boiler and Pressure Vessel Code and applicable Addenda.'/For example, the requirements of Specification 4.0.4 to perform surveillance activities prior to entry into an OPERATIONAL MODE or other spe'cified applicability condition takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows pumps to be tested up to one week after return to normal operation. And for example, the Technical Specification definition of OPERABLE does not grant a grace period before a device that is not capable of performing its specified function is declared inoperable and takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

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REACTOR COOLANT SYSTEM 3.4.10 STRUCTURAL INTEGRITY MME ccoK cL RSB 2.,2and 8 QQNPciNKHi5

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LIMITING CONDITION fOR OPERATION ARKcede CL~ i,2.0.od3

~ii 3.4.10.1 tubes)

~noa4s shall The structural integrity of components (except steam generator be maintained ii iiiiiiiiii:iiiii

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Rl.l In GCCOrhaat.g Z ig ACTION:

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Amendment No. 69 ST. LUCIE - UNIT 1 3/4 4-26

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Mith the structural integrity of any ASME Code Class 1 component(s) not conforming to the above requirements, restore the structural

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integrity of the affected component(s) to within its limit or isolate the affected component(s) prior to increasing the Reactor Coolant System temperature more than 50'F above the minimum temperature required by NOT considerations.

b. Mith the structural integrity of any ASMf Code Class 2 component(s) not conforming to the above requirements, restore the structural integrity of the affected component(s) to within its limit or isolate the affected component(s) prior to increasing the Reactor Coolant System temperature above 2004F.

C>> Nth the structural integrity of any ASME Code Class 3 component(s) not conforming to the above requirements, restore the structural integrity of the affected component to within its limit or isolate the affected component from servic'e.

d. The provisions of Specification 3.0.4 are not applicable.

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DE,LF YP TABLE 4.4-6 INSERVICE INSPECTION PROGRAN - SAFETY CLASS 1 COHPONENTS SECTION 1. REACTOR VESSEL AND CLOSURE HEAD Tentative Inspection C

Examination During 10-year Ho. Categoar r~b Examination Area(b) ~Hethad b Inter val Rsna~ks Longitudinal and Cir- Volumetric See Note (a) and Remarks The required examinations will be performed cumferential shell welds at or near the end of the 10-year inspection in core region. interval or when the internals are removed for other reasons. Hechanized Ultrasonic ex-amination will be used.

1.2 Longitudinal a ir- Volumetric See Note (a) and Remarks (1) The required amount of weld lengths will'c cumferential welds examined at or near the end of the shell (other than those 10-year inspection interval or when the of Category A and C). internals are removed for other reasons.

(2) Closure head meridional welds and dome (circumferential) welds which are not E4 accessible inside the head cooling shroud assembly will be excluded from the examination.

A partial examination of the RPV lower head EQ (3) we]ds can be done from the ID with mechanized techniques.

Approximately 25K of meridional welds.

b roximately 75K of circumferential wol wer head to shell).

c) lOOX of dome welds (circumferen-tial).

(4) IDOL manual examination o lower head welds will be performed externa during baseline.

TABLE 4.4-6 {Cont'd)

SECTION 1. REACTOR VESSEL AND CLOSURE HEAO E

Pl Tentative Inspection Examination Ouring 10-year C Ho. ~Cate or (h) Exaotaattoo Area(h) ~kethod h Interval Reaarka lo3 Vessel-to-flange and Volumetric See Note (a) and Remarks Both of these welds are available for ex-head-to-'flange cir- amination during normal refueling operations.

cumferential welds.

1.4 ary nozzle-to-vessel Vol'umetr ic See Note (a) and Remarks The required examinations will be performed welds d nozzle-to-vessel by mechanized techniques as follows:

inside ra sed sections.

Whenever the internals are removed, one (1) outlet and one (1) inlet nozzle during the first two thirds of this interval (not to exceed 2 each). Balance per D>>

remark (2) below.

I (2) In case the internals are not removed, two (2) outlet nozzles for the first two thirds

~ aR IO of the interval and four (4) inlet nozzles near or at the end of the interval.

Vessel penetrations, in- Volumetric See Rema The CRlN tubes and in-core instrumentation cluding control rod drive tubes are welded to the upper head with a penetrations and control partial penetration weld. The assemblies rod housing pressure .corttain an integrally welded thermal sleeve boundary welds. Volumetric examination is not feasible by currently available techniques. These enetrations are included in Category E-2.

llousi ressure boundary welds are in-accessible e to head cooling shroud as so())bly.

(3) 'Heets exclusion crit a of paragraph IS-121(a) ref: FSAR 15..

le6 E-2 Vessel penetrations, in- Visual See Note (a) eluding control rod drive penetrations and control, rod housing pressure

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SECTION 1. REACTOR VESSEL AND CLOSURE HEAD A

(el Tentative Inspection em Examination During 10-year Ho. ~Cate or (b) Examioattoo Area(b) ~metbod b Inter val Remarks

-I 1.7 F Primary nozzles to safe Visual. surface See Remarks There are no welds in this category.

end welds. and volumetric.

1.8 G-1 osure studs and nuts. Visual. surface See Note (a) and Remarks Surface exam1nation does not apply to and volumetric nuts.

1.9 G-1 Ligaments be en Volumetric See Note (a) and Remarks The ligaments w111 be examined whenever ~ e I

threaded stud ho the Reactor Vessel Flange Meld of Itea 1.3 is examined.

1.10 G-1 Closure washers, bushings. Visua See Note (a) There are no bushings.

G-2 Pressure retaining Visual See Remarks There is no bolting less than 2-inches in Rab bolting.' diameter accessible for examination.

1.12 Integrally t(elded Volumetric See R s Nozzle-type pad supports are installed and vessel supports. are examined under Item 1.4, Category D.

1.13 Closure head cladding Visual and See Note (a) and R s At least six (6) patches (each 36 sq. in.)

surface or of the RPV Closure Head will be examined-volumetric sual and surface.

1.14 Vessel cladd1ng. Visual See Note (a) and Remarks At leas x patches (each 36 sq. in.) of the vessel will examined by remote techniques, 1.15 Interior surfaces and Visual See Note (a) and Remarks (1) The examination 11 be done by remote 1nternals and integrally visual techniques.

welded internal supports.

(2) Mhenever refueling occurs an ernals are removed, a remote visual exam ion will be performed'on tl)e vessel inter

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Tentative Inspection Examination Ouring lO-year No. b te or b Examination Area b ~Method h Inter val Reeeeke 2.1 B ongitudinal and Visual and See Note (a)

C r rential Melds Volumetric 2.2 Nozzle-to-Vesse Volumetric See Note (a) and nozzle-to-vessel inside radius section 2e3 E-1 Neater Connections Visual and remarks (1) Hect the exclusion criteria of IS-121 Surface (c) and are examined under category K-2.

2.4 E-2 lleater Connections Visual See Note (a) a 2e5 G-1 Pressure Retaining Visual and See Ranarks Bolting 2-inch in diameter and greater Bolting Volumetric exist.

2e6 G-2 Pressure retaining Visual See Note fa) and Renarks The bolting less t - nches in diameter wi1l Bolting be visually inspected, ei -place under tension or when they are disasse

TABLE 4.4-6 (Cont'd)

I SECTION 2. PRESSURIZER Pl Tentative Inspection Examination During 10-year Ho. ~he\had h Interval Remarks 2.7 Integrally welded Visual and See Note (a) vessel supports. Volumetric 2.8 I-2 Ves cladding. Visual See Note (a) and Remarks At least one (1) patch (36 sp. in.) below the primary manway will be examined.

SECTION 3. STEAN GEHEAATORS 3.1 Longitudinal and c1'r- V s and See Note (a) and Remarks Hechanized examination, no visual, will be Ll cumferential welds, volumet performed on three (3) each staywell circum-Iaa including tube sheet- ferential welds due to limited access and undue to-head welds on the radiat1on exposure to personnel.

primary side.

3.2 Primary nozzle-to- Volume tr ic See Hot a huad wolds and nozzle-to-head inside radi-used sections.

3.3 Primary nozzle-to-safe Visual, surface See Remarks plicable.

end welds. and volumetric.

3.4 G-1 Pressure reta1ning Visual and See Remar ks Hot Applicable.

volumetric bolt1ng.'ressure 3m5 G-2 retaining Visual See Note (a) and Remarks The bolting less that 2-1nches iameter bolting.- will be visually examined in place tension. or whenever the bolting connect is disassembled.

3.6 Integrally welded Visual and See Note (a) vessel supports. volumetric

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SECTION 3. STEAM GEttERATORS Tentative Inspection Examination During 10-year Ho. Cate or b Examination Area(b) ~Method h Interval Remarks 3.7 -2 Vessel cladding Visual See Hote (a) and Remarks Radiation levels permitting, the examinations will be conducted.

SECTION 4. PIPIttG PRESSURE BOUNDARY 4.1 Vessel. . and valve Visual. sur- See Hote (a) and Remarks The pressurizer and pump nozzle-to-safe end Safe ends-t imary pipe face and volumetric welds are. included in this item.

welds and safe e in branch piping welds.

4.2 G-1 Pressure retaining ual and See Remarks There is no bolting 2-inches and larger in the bolting. vol ric piping system.

4.3 G-2 Pressure retaining Visual See Hote (a) and Remat ks All bolting below 2-inches in diameter will be bolting. visually examined, either in-place or whenever the bolted connection is disassembled.

4.4 Circumferential and Visual and See Hote An augmented inspection of the following welds longitudinal pipe welds. volumetric shall be performed:

(1) During first inspection interval-100'S of the longitudinal welds from the reactor vessel to approximately the outboard surfaces of the reactor cavity shall be amined at approximately 3 I/3'year in als in each of the two hot legs of the un (2) During subse nt inspection intervals-provided no defe are found during the first inspection int 1 exceeding the allowable limits provide Section XI of tlute ASttE Code, IDOL of the longitudin-al welds in either one of the two legs shall be examined during each inspect interval following the first.

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SECTION 4. PIPING PRESSURE BOUNOARY I Tenta tfve Inspect f on Examination Ouring 10-year

'-1 or (k) Interval g~ mo. ~tate Examination Area(b) ~teethed b Remarks 4.5 Branch pipe connection Visual and See Note (a) welds, exceeding 4-fn. volumetric nominal p1pe s1ze.

4.6 e J-1 cket Melds. Visual and See Note (a) surface 4.7 Branch pfp nnection Visual and See Hote (a) welds,.4-1n. n al surface pipe size and sma 4.8 J-2 Circumferential and Visual See Note (a)

Da longitudinal pipe welds and branch pipe connection welds.

4.9 Integrally welded Visual and See Notes (a) and (d) supports. volumetr1c 4.10 K-2 Piping supports and Visual See No a) hangers.

SECTION 5. PUMP PRESSURE BOUNDARY AND PUMP EELS 5.1 Pump casing welds. Visual and See Note (a) and Remarks The only feasible method known to date to volumetric . lumetrfcally examine these pump casing welds fs fography. If radfography is possible, or an ernate exam1nation method is developed, the examin on vill be performed at the fre-quency 1ndfca See Note (c).

5.2 L-2 Pump casings. 'isual See Note (a) and Renarks Radiation levels perm 1ng, the exam1natfon will be performed wheneve e puntps are disassembled.

5.3 Hozzle-to-safe end welds; Visual and See Note (a) and Remarks This item fs considered under Section volumetric Iten 4.1.

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SECTION 5. PUHP PRESSURE DOUHOARY AND PUMP FLYMNEELS Tentative Inspection Examination Ouring 10-year No. ~Cate er (b) Exaeteattea Area(b) ~bathed b Interval keearke 5.4 Pressure retain1ng V1sual and .Sec Note (a) and Remarks (1) Bolting 2-inches and larger in diameter bolting. volumetric will be examined either in-place under tension, or when the bolt1ng .is removed or when the bolting connection is disassembled.

(2) There is no feasible method of examining the flange ligaments of the pumps volumetrically at the present t1me. See note (c).

5.5 G-2 Pressure'retaining Vis See Remarks is no bolting

'here below 2-inches in diameter.

bolting.

5.6 Integrally welded Visual and See Note (a) supports. volumetric 5.7 K-2 Supports and hangers. Visual See No a) 5.8 Flywheel Volumetric (1) (2) See Remarks (1) An in-place ultrasonic volumetric ex- .

Surface (2) amination of the areas of higher stress concentration at the bore and key way at approximately 3 year intervals, during the refueling or ma1ntenance shutdown incid1ng with the inservice inspection sch e, 4 (2) A surface nlnation of all exposed sur-faces and comp ultrasonic volumetric examination at app mately 10 year intervals, during the p t shutdown coinciding with the inserv nspection schedule. Removal of the flywhe is not required to perform these examinatio

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SECTION 6. VALVE PRESSURE DOUNOARY Tentative Inspection Examination During 10-year Ho. ~Cate or b feamtoatioo Area(bj ~tietbod b Interval Reearta 6.1 Valve body welds Visual and Remarks Not Applicable.

volumetric 6.2 H-2 Valve bodies Visual See Note (a) and Remarks Examinations will be conducted provided valves can be disassembed without undue radiation exposure to personnel.

6e3 Valve-to fe end Visual and See Remarks Not Applicable.

welds. volumetric 6o4 G-1 Pressure retaining Visual and See Remarks There are no valves with bolting 2-inches and bolting. volwaetrlc larger in diameter.

6e5 G-2 Pressure retaining sual See Note (a) and Remarks All bolting below'2-inches in diameter will be bolting. visually examined, either in-place if the bolting connection is not disassembled during the inspection interval, or whenever the bolting connection is disassembled.

6.6 Integrally welded Visual and e Remarks There are no valves with integrally welded supports volumetric supports.

6.7 K-2 Support and hangers Visual See Note Note a : e extent an frequency of t e examinations will be at least as much as the gui nes'.of Table IS-251 of Section XI 1971 Edition through Minter 1972 Addenda.

(b): The item number, category, examination area and examination method are listed in Table IS- of Section XI of the ASHE Boiler and Pressure Vessel Code.

a (c): Present ultrasonic techniques may not. be aiaenable to examination of pump/valve castings.

(d): Mhere accossibility to welds prohibits their examination, each weld shall be examined on a case by case bas

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ACTQR CQQLANT SYSTEM SURVEI NCE RE UIREMENTS Continued The service Inspection Program shall be reviewed every 5 years assure that the techniques. and procedures being uti-lized a urrent and applicable. The results of these reviews shall be re rted in Special Reports to the Coamission pursuant to Specificat n 6.9.2 within 90 days of completion.

b. Ins ections Foll Re airs or Re lacements The structural ntegr ty o a ety ass components s a be demonstrated after completion of al repairs and/or replacements by veri-fying the repairs and/or placements meet the requirements of Section XI of the ASIDE Boi and Pressure Vessel Code, 1971 Edition. and Addenda through nter 1972. Nhen repairs and/or replacements are made which inv ve new strength welds on com-ponents greater than 2 inch diame , the new welds shall receive a surface and 100 percent v umetric examination and meet applicable code requirements. repairs and/or replace-

. ments are made which involve new strengt Mh

'ds on components 2 inch diameter or smaller, the new welds s 11 receive a surface examination and meet applicable code quirements.

c. S stem Pressure Tests The structural integrity o afety ass components s all be demonstrated by perform system pressure tests per the requirements of Section XI of ASME Boiler and Pressure Vessel Code, 1971 Editioh, and Adden through Minter 1972.

ST. LUCIE - UNIT 1 3/4 4-38

TABLE 4.4-7 INSERVICE INSPECTION PROGRAN - SAFETY CLASS 2 COHPOHEHTS SECTION Cl. PRESSURE VESSELS Tentative Inspection Examination Ourirg 10-year No. or . Examination Area Hethod Interval Remarks Cl.l C-A cumferential Volumetric 'he comoonents in this category are included (1) The areas of examination include she d head in the overall total of required examinations shell and head circumferential welds for ISC-261(a) and ISC-261(b} components. A welds ~hich are gross structural cumulative 25K of the overall total of re- discontinuities (see Subparagraph quired examinations will be completed during. NE-3213.2 of Section Ill-Huclear Power Plant Components the interval. See Note (a).

Code) in vessels exceeding 4-inch nominal pipe size.

(2) See Note (f)

(3) See Note (b).

(4) The steam generator welds will not stakmell dto be examined due their configuration, limited access and radiation exposure to personnel.

Clm2 C-B Hozzle-to-vessel Volumetric The components in this category are included (1 e Note (b).

welds in the overall total of required examinations for ISC-261(a) and ISC-261(b) components. A (2) See Note cumulative 25K of the overall total hf re-quired examinations will be completed during the interval. See Note (a).

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I SECTION Cl. PRESSURE VESSELS d

Tentative Inspection Item Examination During 10-year e or Examination Area Hethod Interval Remarks C1.3 C-C Integrally-welded Surface The components in this category are 1ncluded (l) See Note (b). ~

upports in the overall total of requ1red examinations for ISC-261(a) and ISC-261(b) components. A (2) See Note (f).

cumulative 25K of the overall total of re-quired examinations w1ll be completed during the interval. See Note (a).

Cl.4 C-0 Pressure-retain1ng isual and The components in th1s category are included (1) Bolting exceeding 1-inch in diameter bolting e r surface 1n the overall total of required examinations- will be examined 1n-place in the bolted-or vo etric for ISC-26l(a) and ISC-261(b) components. A up cond1tion or whenever the bolted cumulative 25K of tne overall total of required connection 1s disasseiabled. Flange examinations will Le completed during the ligaments between threaded stud holes terval; See Note '(a). will be included whenever the connection is disasseaible, and feasible methods of examination have been developed.

d (2) A required examieatioo toesists of the Ch following:

(a) Visual examinat1ons will include 100K of the bolts, studs, and nuts in the bolted joint.

(b) Surface examinat1ons w111 be performed on 10K of the bolting 1n each joint, but not less than 2 bolts or studs per joint whenever the connection is disassembled.

(3) See ote (b).

(4) See Note

TABLE 4.4-7 Cont'd I

SECTION Cl. PRESSURE VESSELS I Tentative Inspection Examination Ouring 10-year Ho. Cate or Examination Area Hethod Interval Remarks C1.5 ISC-261(c) Visual Cumulative lOOX of the required (1) Examinations will be conducted in accordance with components examinations (see Note (c)). the procedures of IS-211 for evidence of component leakage or structural distress with the system under pressure as specified in ISC-520(b), when

'the system is undergoing either a periodic system performance test or a system pressure test.

(2) For insulated components, the examinations will be Ral conducted without the removal of the insulation.

4h (3) Components in letdown portion of CVCS system {from pressure control valves to volume control tank, which normally operates at less than 275 psig 200 F) will be visually examined in accordance with ISC-261(c).

C1.6 ISC-261(d) Visual C lative 100$ of the required (1) See Hate (g).

Components eexam ions (see Note.(c)).

SECT I C2. P IP IHG C2.1 C-F Circumferehtial Volumetric The'components in is category (1) The areas of examination include circumferential C2.1 .1 butt welds are included in the o all total butt welds at structural discontinuities in of required examinations r piping exceeding 4-inch nominal pipe size and ISC-261{a) components. circumferential butt welds in piping exceeding A cumulative 25K of the overal 4-inch nominal pipe sjze within 3 pipe-diameters total of required"examinations wi of the centerline of rigid pipe anchors, or

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be completed during the interval. anchors at the penetration of the primary con-See Note (a). ainment, or at rigidly anchored components.

(2) . See e {b).

(3) See Note (h

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er TABLE 4.4-7 Cont'd SECTIOH C2. PIP IHG Tentative Inspection Examination Ouring 10-year Ho. ate or Examination Area Hethod Interval Remarks C2.1 C-G Circumferential Volumetric One-half of the components in this The areas of examination include circumferential C2.1.2 t welds category will be selected and included butt welds at structural discontinuities in in the overall total of required ex- piping exceeding 4-inch nominal pipe size and aminations for ISC-261(b) components. circumferential butt welds in piping exceeding A cumulative 25K of the overall total 4-inch nominal pipe size within 3 pipe-diameters of required examinations will be of the centerline of rigid pipe anchors, or completed during the interval. See anchors at the penetration of the primary con-Hoto (a). tainment, or at rigidly anchored components.

(2) A representative sampling among the total number of welds will be selected for examination.

(3) See Hote (b).

(4) See Hote (i).

C2.2 C-F Longitudinal weld Volumetric The components in this categor e in- (1) The areas of examination include the longitudinal C2.2.1 )oints in fittings eluded in the overall total of requ weld Joints in pipe fittings exceeding 4-inch examinations for ISC-261(a) components. nominal pipe size.

A cumulative 25K of the overall required examinations will be'completed during (2) Se ote (b).

the interval. See Hote (a).

(3) See Hote ( > .

QFLv"- TP TABLE 4.4-7 Cont'd I

n SECTIOH C2. PIP IHG Pl Tentative Inspection Examination Ouring 10-year e or Examination Area Hethod Interval Rsnarks C2.2 C-G itudinal weld Volumetric See Remarks. Hot applicable for Hote (i) systems.

C2.2.2 Joint ittings C0.3 C-F Branch pipe-to-pip lumetric See Remarks. Hot applicable for Xote (h) systems.

C2.3.1 weld joints C2.3.2 C-G Branch pipe-to-pipe Volumetric e-half of the components in this (1) The areas of examination include branch con-weld joints cate will be selected and included nection weld joints exceeding 4-inch nominal in the ove total of required ex- pipe size.

aminations for l(b) components.

A cumulative 25l of the all total (2) A representative sampling among the total number of required examinations wil of welds will be selected for examination.

completed during the interval.

4b I See Note (a). e Hote (b).

Crk (4) See Hote

n SECTION C2- PIP IHG Tentative Inspection Examinat1on During 10-year Ho. Cate or Examination Area Hethod Interval Remarks C2e4 C- Integrally-welded Suface The components in th1s category are in- (1) See Note (b).

support-to-pipe eluded in the overall total of required ds examina'tions for ISC-261(a) and ISC-261(b) (2) See Notes (h) and (1).

components. A cumulat1ve 25K of the over-all total of required examinations will be completed during the interval. See Note (a).

C2.5 C-D Pressure-retaining V 1 and The components 1n this category are 1n- (1) Bolting exceed1ng 1-inch in diameter will be bolt1ng . eithe r- eluded in the overall total of required examined in-place 1n the bolted-up condition face or examinations for ISC-26l(a) and ISC-261(b) or whenever the bolted connection is dis-volumetric omponotns. A cumulative 25K of the over- assembled. Flange ligaments between threaded a otal of required exam1nations will be stud holes will be included whenever the con-comple during the interval. See Note (a). nection is disassembled, and feasible exam tion methods have been developed.

(2) A required examinat1on consists of the following:

(a) Visual examinations will include 100K of the bolts, studs, and nuts in the

. bolted point.

(b) Surface examinations will be performed on of the bolting 1n each ]oint. but not less than 2 bolts or studs per joint whenever I connection is disassembled.

6) See Hote (b .

t4) See Notes (h) and (

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F n SECTION C2. P I PING m

Tentative Inspection Exam4ation Ouring 10-year Ho. or Examination Area Hethod Interval Reearks C2.6 C-E or ts and 'isual The components in this category are included (1) See Note (b).

hange in the overall total of required examinations for ISC-261(a) and ISC-261(b) components. A-cumulative 25K of the overall total of required examinatfons will be comploted during the inter-val. See Notes (a) and (e).

C2.7 -- ISC-261 (c) Visual Cumua 1MX of the required examinations. (1) Examinations will be conducted in accord-System See Note (c . ance with the procedure of IS-211 for evfdence of component leakage or structural distress with the system under pressure as specified in ISC-520(b), when the system is undergoing either a periodic system per-

,formance test or a system pressure test.

(2) insulated components, the examinatio will ducted wfthout the removal of the insulat

QFLl. VF TABLE 4.4-7 Cont'd n

m SECTION C2. PIPING Tentative Inspection Examination Ouring 10-year No. or Examination Area Method Interval Remarks (3) Components in letdown portion of CVCS system (from pressure control valves to volume control tank.

which normally operates at less than 275 psig 200 F) will be visually examined in accordance with ISC-261(c).

C2.8 fSC-261(d) systems Visdal Cumulat X of the required (1) See Hot (g).

examinations se e (c)).

Ral SECTION C3. PUMPS

~ mam a C3 I C-F Pump casing welds Volumetric See Remarks. Hot app for Note ()) pumps.

A'.3.1.1 C.3.1.2 C-G Pump casing welds Volumetric -

See Reamrks. Hot applicable for Note ()) p

TABLE 4.4-7 Cont'd n

C SECTIOH C3. PUMPS Pl Tentative Inspection Examination Ouring 10-year Ho. Cate or Examination Area Method Interval Renarks C3.2 C- Pump Casing Visual -The components in this category are in- (1) See Note (b).

cluded 1n the overall total of required examinations for ISC-261(a) and ISC-261(b) (2) See Note (j).

components. A cumulativo 25K of the over-all total of required exam1nations will be completed during th 'nterval. Sae Note (a).

C3.3 C-9 Pressure-retaining- 1sual and The components in this category are in- (1) Bolting exceeding 1-inch in diameter will be bolting e r surface eluded in tha overall total of required examined in-place in the bolted-up condition or vo atric examinations for ISC-261(a) and ISC-26l(b) or whenever the bolted connection is dis-components. A cumulativa 25K of tha over- , assembled. Flange. ligaments between threaded all total of required examinations will be stud holes will be included whenever the con-i lated during the interval. Sae Hote nect1on is disassembled, and feasible examina-(a). tion methods have been developed.

(2) A required examination consists of the following:

(a) Visual examinations will 1nclude 100K of the bolts, studs. and nuts 1n the bolted joint.

(b) Surface examinations w111 be performed on 10">> of the bolting in each joint, but not less than 2 bolts or studs per joint whenever the connection is disassembled.

('3) See ta (b).

(4) See Note (

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gers eluded 1n tho overall total of required examinat1ons for ISC-261(a) and ISC-261(b) (2) See Note ()).

components. A cumulative 25% of the over-all total of required examinat1ons will be completed during the interval. See Notes (a) and (e).

C3.5 Integrally ~elded Surface See Renarks Hot applicable for Note 0) pumps.

supports C3.6 ISC-261(c) Visual Cumulativ X of the required exam1nations (l) Exam1nations will be conducted in accordance Q ~ components See Note (c). with the procedures of IS-2ll for evidence of component leakage or structural distress with the system under pressure as specified in ISC-520(b). when the system is undergo1ng either a periodic system performance test or a system pressure test.

(2) insulated components, the examinations will be ucted without the retrroval of the insulat o

r hr Qi,L'E YP t TABLE 4.4-7 Cont'd n

SECTION C3. PUMPS C

Tentative Inspection Examination Ouring 10-year No. r Examination Area Method Interval Remarks (3) Components in letdown portion of CVCS system (from pressure control valves to volume control tank, which normally operates at less than 275 psig 200 F) will be visually examined in accordance with ISC-261(c).

1 C3.7 ISC-261(d)'omponents Visu'al Cumulative 50K o equired examinations (1) See Note (g).

(see Note (c)).

4h SECTION C4. VALVES k

~ C4.1 C-F Valve body welds Volumetric See Remarks Hot applicable tes {h) and (i) systems.

C4.1.1 C4.1.2 C-G Valve body welds Volumetric See Reamrks Hot applicable for Hotes (h) and (i) syst~

SECTION C4. VALVES C Tentative Inspection P4 Examination During 10-year No. te o Examination Area Method Interval Remarks C4.2 C-H Valve Bodies Visual The components in this category are included (1) See Hote (b).

in the overall total of required examinations for ISC-261(a) and ISC-261(b) .components. A (2) See Hotes (h) and (i).

cumulative 25% of the overall total of required examinations will be completed during Qe interval. Sec Note (a).

C4.3 C-D Pressure-retain- Vis and The components in this category aro included (1) Bolting exceeding 1-inch in diameter will ing bolting either in the overall total of required examinations be examined in-place in the bolted-up con-face or for ISC-261(a) and ISC-261(b) components. A dition or whenever the bolted connection volumetric c ative 25% of the overall total of re- is disassembled. Flange ligaments between quire aminations will be completed during threaded stud holes will be included when-the interv See Note (a). ever the connection is disassembled. See Hote (d).

(2) A required examination consists of the following:

(a) Visual examinations will include 1004 of the bolts, studs, and nuts in the bolted )oint.

) Surface examinations will be performed n le of the bolting in each )oint, b ot less than 2 bolts or studs per joint ever the connection is disassembl (3) See Note (b).

(4) See Hotes (h) and (i).

M SECTION C4. VALVES Tentative Inspection Examination Ouring 10-year ate or Examination Area Hethod Interval Remarks C-E Supports and - Visual The components in this category are included (1) See Hote (b).

ers in the overall total of required examinations for ISC-261(a) and ISC-261(b) components. A cumulative 251, of the overall total of required examinations will be completed during the interval. See Notes (a) and (e).

Integrally-welded Surface See Remarks Hot applicable for Hotes (h) and (i) systems.

supports ISC-261(c) Visual Cumulativ 'f of the required examinations. (1) Examinations will be conducted in accordance components See Note (c). with the procedures of IS-211 for evidence of component leakage or structural distress with the system under pressure as specified in ISC-520(b), when the system is undergoin either a periodic system performance test or a system pressure test.

For insulated components, the examinations 1 be conducted without the removal of the insu on.

(3) Components in own portion of CVCS system (from pressure contr valves to volume con-trol tank, which normally rates at less than 2?5 psig 200 F) will be lly ex-amined in accordance with ISC-261 c

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TABLE 4.4-7 Cont'd SECTION C4. VALVES Tentative Inspection Examination During 10-year No. ate or Examination Area Hethod Interval Remarks C4.7 -- ISC>>261(d) Visual Cumulative 50K of the required examinations (1) See Note (g).

onents (see note (c)).

ote a : t east part o t e overa to a of required exam ions will be performed by the expiration of 1/3, 2/3, and the end of the 10-year interval.

(b): The total number of required examinations is dependent upon her or not a system consists of multiple streams which perform the same (or redundant) functions as stated in ISC-242(a); the distr on of individual components to be examined will be determined in accordance with ISC-242(b). (c). and (d).

(c): At least 25K of the required examinations will be completed by the expirat of 1/3 of the 10-year inspection interval. with not more than 66-2/3X of the required examinations completed by the expiration of f the 10-'year inspection interval.

d Present ultrasonic techniques and procedures may not be amenable to examination of castings.

e )there accessibility to welds prohibits their examination, each weld will be evaluated on ase by case basis.

f The regenerative, letdown, and shutdown heat exchangers, and the steam generators (secondary e) are to be examined.

9 Components and systems'n which the contained fluid will be verified by periodic sampling and tes h Portions of the shutdown c'ooling systems are to be examined.

Portions of the main steam and feedwater systems are to be examined.

3) Low pressure safety injection pmxps are to be examined.

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ACTOR COOLANT SYSTEM SAFE CLASS. 3 COMPONENTS LIMITING C ITION FOR OPERATION 3.4.10.3 The stru ural integrity of components identified in Section 3.2.2 of the FSAR as afety Class 3 components shall be maintained at a level consistent wit the acceptance criteria in Specification 4.4.10.3.

APPLICABILITY: ALL MODES.

ACTION:

Mith the structural integrity of a of the above components not con-forming to the above requirements. re ore the structural integrity of the component to within its limit or is ate the affected components from service. The provisions of Specific ion 3.0.4 are not applicable.

SURVEILLANCE RE UIREMENTS 4.4.10.3 The following inspection program shall be per rmed:

a. Inservice Ins ections The structural integrity o the Safety ass components s all be demonstrated at least o e per 40 months during periods of normal reactor operation or ring system performance testing by verifying via visual insp tions, as outlined by the inspection program shown in Table 4.'4-that there is no evidence of unanticipated component leakag structural distress. or corrosion.

1 ST. LUCIE - UNIT 1 3/4 4-53 Amendment No. 6g

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b. S stem essure Tests The structural integrity of the Safety ass co onents shall be demonstrated at least once per 10 years by per ing system pressure tests at the following test pressures:

1. For closed syst , at least 110 percent of the design pressure,

2. For open storage tanks, least the nominal hydrostatic pressure developed with the nks filled to design capa--

city. and

3. Open-ended portions of systems may exempted from pres-sure testing.

c~ Pi Han er Ins ections The structural integrit of the Safety C ass 3 components sha 1 be demonstrated at least e per 40 months by verifying via visual inspections that the s orts and hangers for piping and components over 4 inches in ter show no evidence of inadequate support, unintended restrain or structural distress.

ST. LUCIE - UNIT 1 3/4 4-54

' .~ ~ Tr TABLE 4.4-8 INSERVICE INSPECTION PROGRAM - SAFETY CLASS 3 COMPONENTS Class 3 piping greater than 4 inches and components with pipe connections greater than 4 inches w ssure tested and visually examined near or at the end of the 10-year inspection interval. In components will be visually examined during periods of normal operations or during system performanc once during each 1/3 of the year 10-year inspection interval.

2. Open-ended portions of systems will not be pressure

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REACTOR COOLANT SYSTEM BASES for piping, pumps and valves. Below this temperature, the system pressure must be limited to a maximum of 20" of the system's hydrostatic test pressure of 3125 psia.

The number of reactor vessel irradiation surveillance specimens and the frequencies for removing and testing these specimens are provided in Table 4.4-5 to assure compliance with the requirements ef Appendix H to 10 CFR Part 50.

The limitations imposed on the pressurizer heatup and cooldown rates and spray water temperature differential are provided to assure that the pressurizer is operated within the design criteria assumed for the fati-gue analysis performed in accordance with the ASME Code requirements.

3/4.4.10

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inspection program) for the Reactor Coolant System 6-lb'equired componen ensure that the structural integrity of these components will be maintain at an acceptable level throughout the life of the plant.

To the extent licable, the inspection program for the Reactor Coolant System components 's in compliance with Section XI of the ASME Boiler and Pressure Vessel Cod "Inservice Inspection of Nuclear Reactor Coolant Systems", 1971 Edition, nd Addenda through Minter 1972.

All areas scheduled for lumetric examination have been pre-service mapped using equipment, techniq and procedur es anticipated for use during post-operation examinations. To assure that consideration is given to the use of new or improved i ection equipment, techniques and procedures, the Inservice Inspection rogram will be periodically reviewed on a 5 year basis.

The use of conventional nondestructive, dir t visual and remote visual test techniques can be applied to the inspec on of most reactor coolant loop components except the reactor .vessel. Th reactor vessel requires special consideration because of the radiation els and the requirement for remote underwater accessibility.

The techniques anticipated for inservice inspection include inspections, ultrasonic, radiographic, magnetic particle and dye

'al pen trant testing of selected parts.

ST. LUCIE - UNIT 1 B 3/4 4-12

REACTOR COOLANT SYSTEM BASES nondestructive testing for repairs on components greater than 2 inches di eter gives a high degree of confidence in the integrity of the system, d will detect any significant defects in and near the new welds. Repairs components 2 inches in diameter or smaller receive a surface examinatio hich assures a similar standard of integrity. In each case, the leak t t will ensure leak tightness during normal operation.

For normal opening and re sing,'the structural integrity of the Reactor Coolant System is unchang Therefore, satisfactory performance of a system leak test at 2235 psia f owing each opening and subsequent rity. These leak tests will be conducted 'in reclosing is acceptable demonstration o he system's structural inte-the. pressure-temperature limitations for Inservice Leak and Hydrostatic esting and Figure 3.4-2.

The Safety Class 2 and 3 components will be pre ure tested at least once toward the end of each inspection interval years). The Safety Class 2 components having a design temperature abov 400'.F will be pressure tested at not less than 125 percent of the system sign pressure while those components having a design temperature of 4 'F and below will be pt essure tested at 110 percent of design pressure. T Safety Class 3 components will be pressure tested at the levels indica in Specificatinn 4.4.10.3b.

1 I

T. LUCIE - UNIT 1 B 3/4 4-13 Amendment No. 80

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ATTACHMENT2 EVALUATION As required by 10 CFR 50.55a(g), FPL updated the lnservice Inspection (ISI) and Inservice Testing (IST) programs, together with proposed Technical Specification amendments for St. Lucie Unit I, to the requirements of the 1974 Edition through Summer 1975 Addenda of the ASME Boiler and Pressure Code. The ISI program was submitted to the NRC in July and September of 1977. On December 20, 1977, the NRC granted relief, on an interim basis, pending completion of a detailed review of the programs. Final NRC approval is still pending and, since 1977, FPL has had to comply with both the existing Technical Specifications and the proposed ISI and IST programs, whichever, is more restrictive.

The proposed amendments which were submitted in 1977, removed reference to a specific Edition and Addenda of Section XI of the ASME Boiler and Pressure Vessel Code for inservice inspections and, instead, proposed a new Specification 4.0.5 addressing surveillance requirements for inservice inspection and testing.

The subject revised amendment proposes to maintain a similar format as was originally submitted. This format is consistent with both the Combustion Engineering Standard Technical Specifications (CE-STS) and the St. Lucie Unit 2 Technical Specifications.

A change is proposed to add a new specification in Secton 4.0 (Surveillance Requirements) of the Technical Specifications. The change will include Surveillance Requirements for inservice inspection of ASME Code Class I, 2 and 3 components. Specification 4.0.5 has been added to include this requirement. This addition reflects wording provided in the CE-STS and provides consistency between the Unit I and Unit 2 Technical Specifications.

The purpose of the change to Technical Specification 3 4.,10, Structural lntegrity-ASME Code Class I, 2 and 3 Components, is to incorporate three (3) separate Limiting Conditions for Operation (LCO) into one (I) LCO. That is, the change incorporates the Structural Integrity - ASME Code Class I, 2 and 3 Component individual LCOs into one (I) LCO. The format reflects the format/wording contained in both the CE-STS and the St. Lucie Unit 2 Technical Specifications.

The changes are as follows:

Limitin Condition for 0 ration (LCO) - The LCO has been written to encompass ME Code Class I, 2 and 3 Components and is written consistent with the CE-STS and the St. Lucie Unit 2 Technical Specifications.

A licabilit - The applicability has been changed to reflect ALL MODES since ME ode Class I, 2 and 3 Components have been incorporated into one Specification. This is consistent with the CE-STS and St. Lucie Unit 2 Technical Specifications.

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Action - The Action Statement has been changed to reflect three (3) separate statements for Structural Integrity of ASME Code Class I, 2 and 3 Components.

This is consistent with the CE-STS and St. Lucie Unit 2 Technical Specifications.

Surveillance Re uirernents - With the addition of Specification 4.0.5, as discussed above, the Surveillance Requirements have been changed to reflect the ISI requirements as outlined in Specification 4.0.5. Reference to the Surveillance Requirements, as outlined in Section XI of the ASME Boiler and Pressure Vessel Code, l97l Edition and Addenda through Winter 72, have been deleted. Inservice Inspection requirements are already outlined in the appropriate Edition and Addenda of'Section XI, as referenced in the new Specification 4.0.5. Therefore, restatement of these requirements in the Technical Specifications is not necessary. The Inservice Inspection Program Tables for ASME Code Class I, 2 and 3 Components have been deleted since they are maintained in the St. Lucie Unit I ISI Program. These changes to Technical Specification 3.4.IO reflect the format in the CE-STS and the St. Lucie Unit 2 Technical Specifications.

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ATTACHMENT3 NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the Commission's regulations, IO CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (I) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated or (3) involve a significant reduction in a margin of safety. Each standard is discussed as follows:

(I) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The change to Technical Specification Section 4.0, Surveillance Requirements, is a change to achieve consistency between the St. Lucie Unit I Technical Specifications and the St. Lucie Unit 2 Technical Specifications. The intent of the Specifications has not been changed.

The change incorporates the format/wording of the Combustion Engineering Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications.

The change to Technical Specification 3.4.IO - -Structural Integrity-ASME Code Class I, 2 and 3 Components is proposed to achieve consistency between the St. Lucie Unit I Technical Specifications and St. Lucie Unit 2 Technical Specifications. Three (3) separate Limiting Conditions for Operation have been incorporated into one (I) LCO.

Reference to lnservice Inspection Tables and Surveillance Requirements of a specific Edition and Addenda of Section Xl of the ASME Boiler and Pressure Vessel Code have been deleted. Reference to Specification 4.0.5 has been added to provide Surveillance Requirements for lnservice Inspection of ASME Code Class I, 2 and 3 Components in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by IO CFR 50.55a(g). Also, the St. Lucie Unit I ISI Program contains the requirements as provided in the appropriate Edition and Addenda of Section Xl of the Code. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Use of the modified specification would not create the possibility'of a new or different kind of accident from any accident previously evaluated.

The change to Technical Specification Section 4.0, Surveillance Requirements, is a change to achieve consistency between the St. Lucie Unit I Technical Specifications and the St. Lucie Unit 2 Technical Specifications. The intent of the Specifications has not been changed.

The change, incorporates the format/wording of the Combustion Engineering - Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications.

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Reference to Inservice Inspection Tables and Surveillance Requirements of a specific Edition and Addenda of Section XI of the ASME Boiler and Pressure Vessel Code have been deleted. Reference to Specification 4.0.5 has been added to provide Surveillance Requirements for Inservice Inspection of ASME Code Class I, 2 and 3 Components in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by IO CFR 50.55a(g). Also, the St. Lucie Unit I ISI Program contains the requirements as provided in the appropriate Edition and Addenda of Section XI of the Code. Therefore, th'e possibility of a new or different kind of accident from any accident previously evaluated is not created.

(3) Use of the modified specification would not involve a significant reduction in a margin of safety.

The change to Technical Specification Section 4.0, Surveillance Requirements, is a change to achieve consistency between the St. Lucie Unit I Technical Specifications and the St. Lucie Unit 2 Technical Specifications. The intent of the Specifications has not been changed.

The change incorporates the format/wording of the Combustion Engineering - Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications.

The change to Technical Specification 3.4.IO - Structural Integrity-ASME Code Class I, 2 and 3 Components is proposed to achieve consistency between the St. Lucie Unit I Technical Specifications and St. Lucie Unit 2 Technical Specifications. Three (3) separate Limiting Conditions for Operation have been incorporated into one (I) LCO.

Reference to Inservice Inspection Tables and Surveillance Requirements of a specific Edition and Addenda of Section XI of the ASME Boiler and Pressure Vessel Co'de have been deleted. Reference to Specification 4.0.5 has been added to provide Surveillance Requirements for Inservice Inspection of ASME Code Class I, 2 and 3 Components in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by IO CFR 50.55a(g). Also, the St. Lucie Unit I ISI Program contains the requirements as provided in the appropriate Edition and Addenda of Section Xl of the Code. Therefore, use of the modified specification would not involve a significant reduction in the margin of safety.

Based on the above, we have determined that the amendment request does not (I) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore does not involve a significant hazards consideration.

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