ML041820242

6/24/04, St. Lucie, Units 1 & 2 - Request for Additional Information Regarding Control Room Ventilation System and Miscellaneous Minor Technical Specification Changes

ML041820242
Person / Time
Site:	Saint Lucie
Issue date:	06/24/2004
From:	Moroney B NRC/NRR/DLPM/LPD2
To:	Stall J Florida Power & Light Co
Moroney B, NRR/DLPM, 415-3974
References
TAC MC0886, TAC MC0887
Download: ML041820242 (4)

Text

June 24, 2004 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

ST. LUCIE PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTROL ROOM VENTILATION SYSTEM AND MISCELLANEOUS MINOR TECHNICAL SPECIFICATION CHANGES (TAC NOS. MC0886 AND MC0887)

Dear Mr. Stall:

By letter dated September 18, 2003, Florida Power and Light Company submitted amendment requests to revise the control room ventilation system technical specifications (TSs) and to make minor miscellaneous TS editorial changes for St. Lucie Units 1 and 2.

The U. S. Nuclear Regulatory Commission staff has reviewed your submittals and finds that a response to the enclosed request for additional information is needed before we can complete the review. This was discussed with members of your staff on June 23, 2004 and Mr. George Madden indicated that a response would be provided by August 15, 2004.

If you have any questions, please feel free to contact me at 301-415-3974.

Sincerely,

/RA/

Brendan T. Moroney, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos.: 50-335 and 50-389

Enclosure:

As stated cc w/encl: See next page

ML041820242 NRR-088 Document Name: G:\DLPM\PDII-2\St. Lucie\MC0886&MC0887RAI.wpd OFFICE PDII-1/PE PDII-2/PM SPSB/SC PDII-2/SC NAME JArroyo BMoroney RDennig WBurton DATE 6/24/2004 6/24/2004 by memo 2/19/04 6/24/2004 REQUEST FOR ADDITIONAL INFORMATION FLORIDA POWER AND LIGHT COMPANY ST. LUCIE NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NUMBERS 50-335 AND 50-389 Unit 1 and Unit 2

1. All current surveillance requirements for ventilation filter testing are not included in the proposed ventilation filter testing program (VFTP). St. Lucie is committed to Regulatory Guide (RG) 1.52, Rev. 2, and as such, the proposed VFTP should be in compliance with the guidance of the RG. Therefore, in order for the proposed VFTP to be acceptable all of the current surveillance requirements should be included.

2. In addition, proposed VFTP items k.1 and k.2 request that inplace testing for emergency safety feature systems show a penetration and bypass of # 1 percent for high efficiency particulate air filters and charcoal adsorbers. This position is not consistent with RG 1.52. In accordance with the staffs position on this issue, as outlined in RG 1.52, systems penetration and bypass for the stated systems and situations should be # 0.05 percent. Therefore the proposed VFTP should be revised and made consistent with the RG, or justification should be provided for the higher limit. Please revise the VFPT or provide justification of why this is not required.

3. Surveillance Requirements (SR) 4.7.7.1.a (Unit 1) and 4.7.7.a (Unit 2) (verification that control room air temperature #120EF) are being deleted.

Licensee is requested to provided a plant-specific technical justification for deletion.

The purpose of a temperature limit is for both equipment operability and human habitability in accordance with General Design Criterion 19. The licensee states, and the staff agrees, that this surveillance does not appear in the Combustion Engineering Standard Technical Specifications. However, since this is currently a requirement in the St. Lucie technical specifications (TSs), please provide a plant-specific rationale for the deletion, and indicate how this parameter will be controlled outside of the TSs.

4. SRs 4.7.7.1.e.3 (Unit 1) and 4.7.7.e.3 (Unit 2) are being revised to allow for conducting control room pressure tests on a staggered test basis.

For this request, the licensee should provide a clearer description of what is requested.

The currently specified test interval (each ventilation system at least once per 18 months) requires testing both trains every 18 months with the interval between the test of each train ranging from one train right after the other, to almost the entire 18 months. Please describe the current practice for scheduling the affected surveillance, so that the increased interval may be accurately characterized. The proposed change, to test one train every 36 months on a staggered test basis, will result in testing each train on a 36 month interval, with each test occurring every 18 months on the alternate train. Please provide a technical basis for increasing the test interval for a Enclosure

train from 18 months to 36 months. Also, state how you will transition to the new test interval.

5. The proposed applicability for the fuel storage pool ventilation system gaseous and particulate monitors is Whenever recently irradiated fuel is in the spent fuel pool. Why is it not, During movement of recently irradiated fuel assemblies in the spent fuel pool?

This is more consistent with the Technical Specification Task Force-51 and the STS for an applicability statement for a limiting condition for operation associated with mitigating or monitoring a fuel handling accident.

Unit 2 Only

6. In Attachment 1, Page 2, the proposed markup for TS Section 3.7.7.1 (Insert 1) associated with the the 2nd and 3rd bullets is not included. The markup designated Insert 1 on Page 8 is associated with Administrative Controls. Please provide corrected version.

Mr. J. A. Stall ST. LUCIE PLANT Florida Power and Light Company cc:

Senior Resident Inspector Mr. G. L. Johnston St. Lucie Plant Plant General Manager U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant P.O. Box 6090 6351 South Ocean Drive Jensen Beach, Florida 34957 Jensen Beach, Florida 34957 Craig Fugate, Director Mr. Terry Patterson Division of Emergency Preparedness Licensing Manager Department of Community Affairs St. Lucie Nuclear Plant 2740 Centerview Drive 6351 South Ocean Drive Tallahassee, Florida 32399-2100 Jensen Beach, Florida 34957 M. S. Ross, Managing Attorney David Moore, Vice President Florida Power & Light Company Nuclear Operations Support P.O. Box 14000 Florida Power and Light Company Juno Beach, FL 33408-0420 P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company Mr. Rajiv S. Kundalkar 801 Pennsylvania Avenue, NW Vice President - Nuclear Engineering Suite 220 Florida Power & Light Company Washington, DC 20004 P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Douglas Anderson County Administrator Mr. J. Kammel St. Lucie County Radiological Emergency 2300 Virginia Avenue Planning Administrator Fort Pierce, Florida 34982 Department of Public Safety 6000 SE. Tower Drive Mr. William A. Passetti, Chief Stuart, Florida 34997 Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. William Jefferson, Jr.

Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000