ML071490483

License Amendment, Revised Steam Generator Surveillance Program to Be Consistent with Technical Specification Task Force Change Traveler TSTF-449, Steam Generator Tube Integrity

ML071490483
Person / Time
Site:	Saint Lucie
Issue date:	05/29/2007
From:	Mozafari B NRC/NRR/ADRO/DORL/LPLII-2
To:	Stall J Florida Power & Light Co
Mozafari B, NRR/ADRO/DORL, 415-2020
References
TAC MD2322
Download: ML071490483 (11)

Text

May 29, 2007Mr. J. A. StallSenior 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, UNIT 2 - ISSUANCE OF AMENDMENT REGARDINGSTEAM GENERATOR TUBE INTEGRITY (TAC NO. MD2322)

Dear Mr. Stall:

The Commission has issued the enclosed Amendment No. 147 to Renewed Facility OperatingLicense No. NPF-16 for the St. Lucie Plant, Unit No. 2. This amendment consists of changes tothe Technical Specifications supplemented by letters dated January 22 and April 16, 2007.This amendment revises the steam generator surveillance program to be consistent withTechnical Specification Task Force change traveler TSTF-449, "Steam Generator Tube Integrity."A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's biweekly Federal Register notice.Sincerely,/RA/Brenda L. Mozafari, Senior Project ManagerPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-389

Enclosures:

1. Amendment No. 147 to NPF-16

2. Safety Evaluationcc w/enclosures: See next page

ML071490483 - Package No. ML0 NRR-058OFFICELPL2-2/PM LPL2-2/LACSGB/BCSPWB/BCLPL2-2/BCNAMEBMozafariBClaytonAHiserby memo datedJNakoskiby e-mail dated TBoyceSBailey forDATE05/29/07 5/25/07 5/24/0711/02/0605/29/07

FLORIDA POWER & LIGHT COMPANYDOCKET NO.50-389ST. LUCIE PLANT, UNIT NO. 2AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 147 Renewed License No. NPF-161.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Florida Power & Light Company (thelicensee), dated May 25, 2006, as supplemented by letters dated January 22 and April 16, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (I) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; and E.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, Renewed Facility Operating License No. NPF-16 is amended by changesto the Technical Specifications as indicated in the attachment to this license amendment, and by amending paragraph 3.B to read as follows:B.Technical SpecificationsThe Technical Specifications contained in Appendices A and B, as revisedthrough Amendment No.147, are hereby incorporated in the license. FPL shall operate the facility in accordance with the Technical Specifications. 3.This license amendment is effective as of its date of issuance and shall be implementedwithin 90 days.FOR THE NUCLEAR REGULATORY COMMISSION

/RA SBailey for

/Thomas H. Boyce, ChiefPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical SpecificationsDate of Issuance: May 29, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 147TO RENEWED FACILITY OPERATING LICENSE NO. NPF-16DOCKET NO. 50-389Replace Page 3a of Renewed Operating License NPF-16 with the attached Page 3a.Replace the following pages of the Appendix "A" Technical Specifications with the attachedpages. The revised pages are identified by amendment number and contain vertical lines indicating the area of change. Remove PagesInsert PagesIndex Page VIIndex Page VIIndex Page XIXIndex Page XIX 1-31-3 1-51-5 3/4 4-113/4 4-11 3/4 4-123/4 4-12 3/4 4-12a3/4 4-12a 3/4 4-133/4 4-13 3/4 4-143/4 4-14 3/4 4-14a3/4 4-14a 3/4 4-153/4 4-15 3/4 4-163/4 4-16 3/4 4-173/4 4-17 3/4 4-18 3/4 4-18 3/4 4-193/4 4-19 3/4 4-203/4 4-20 6-15e6-15e

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6-20f SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 147 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-16FLORIDA POWER AND LIGHT COMPANYST. LUCIE PLANT, UNIT NO. 2DOCKET NO. 50-389

1.0 INTRODUCTION

By application dated May 25, 2006 (Agencywide Documents Access and Management SystemAccession No. ML061510346), as supplemented by letters dated January 22 and April 16, 2007, Florida Power & Light Company (the licensee) requested changes to the Technical Specifications (TS) for Saint Lucie Unit 2 (STL-2). The proposed changes would revise the existing steam generator (SG) tube surveillanceprogram. The changes are modeled after Technical Specification Task Force (TSTF) Traveler, TSTF-449, Revision 4, "Steam Generator Tube Integrity," and the model safety evaluation (SE) prepared by the U.S. Nuclear Regulatory Commission (NRC) and published in the FederalRegister (FR) on March 2, 2005 (70 FR 10298). In this regard, the scope of the applicationincludes changes to the definition of leakage, changes to the primary-to-secondary leakage requirements, changes to the SG tube surveillance program (SG tube integrity), changes to the SG reporting requirements, and associated changes to the TS Bases.The supplemental letters dated January 22, 2007, and April 16, 2007, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination, as published in the FR on July 18, 2006 (71 FR 40747).

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operatinglicenses to include TS as part of the license. The licensee provides TS in order to maintain theoperational capability of structures, systems and components that are required to protect the health and safety of the public. The Commission's regulatory requirements related to the content of the TS are contained in Title 10 of the Code of Federal Regulations (10 CFR),Section 50.36. Pursuant to 10 CFR 50.90, licensees may request changes to its TS. The background, description, and applicability of the proposed changes associated with theSG tube integrity issue and the applicable regulatory requirements were included in the NRC staff's model SE published in the FR on March 2, 2005. The "Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding Steam Generator Tube Integrity Using the Consolidated Line Item ImprovementProcess," was published in the FR on May 6, 2005 (70 FR 24127), and made the model SE available for licensees to reference. This was subsequently modified by a simplified model SE (ML061040351) that was approved on September 8, 2006.

3.0 TECHNICAL EVALUATION

3.1 Overview In its May 25, 2006, application, and its January 22, and April 16, 2007, supplements, thelicensee proposed changes to the TS that are modeled after TSTF-449. There were minor differences between TSTF-449 and the licensee's application. These included differences in the facility licensing basis (than that discussed in TSTF-449), differences in TS format and numbering, and TS and TS Bases changes that went beyond TSTF-449. These differences are discussed below.With respect to the differences in the facility licensing basis, the differences did not invalidatethe technical evaluation on TSTF-449; rather they resulted in the licensee having to slightly deviate from some of the modifications discussed in TSTF-449. For example, TSTF-449 uses MODE 3, MODE 4, and MODE 5 for the modes of operation whereas for STL-2 the "modes of operation" are referred to as HOT STANDBY, HOT SHUTDOWN, and COLD SHUTDOWN. In addition, the licensee proposed in its TS to enter COLD SHUTDOWN "within the following 30 hours1.25 days <br />0.179 weeks <br />0.0411 months <br />" after achieving HOT STANDBY (with HOT STANDBY being entered within 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br />) when tube integrity is not maintained (or not verified within the required time period when a tube is inadvertently not plugged). This proposal is slightly different than TSTF-449 that indicates that COLD SHUTDOWN should be entered within 36 hours1.5 days <br />0.214 weeks <br />0.0493 months <br />. Another example is that the licensee indicated that the dose consequences are within the limits of 10 CFR 50.67 since the licensee's current licensing basis is based on the limits set forth in 10 CFR 50.67. Since thesedifferences in the licensing basis were minor in nature, they were consistent with the plant's licensing basis, or they were consistent with the intent of TSTF-449, the NRC staff determined they were acceptable. With respect to the differences in the numbering of the TS, these differences wereadministrative in nature and did not affect the technical adequacy of the submittal. As a result, the NRC staff determined they were acceptable. With respect to the differences in the format of the TS, requirements were listed in sentence format rather than tabular format and using slightly different terminology. Since these differences were administrative in nature and did not affect the technical adequacy of the submittal, the NRC staff determined they were acceptable.In addition to these minor changes, the licensee proposed to include previously approvedalternate repair criteria and repair methods into its proposed new TS for the original SGs (OSGs). The structure of TSTF-449 allows licensees to incorporate alternate repair criteria and methods into the TSTF-449 format. By incorporating the previously approved repair criteria and repair methods into the TSTF-449 format, there were several additions, deletions and changes to the requirements. These changes (including additions and deletions) were made as a result of the format, content, and performance-based approach of TSTF-449. The NRC staff verified that (a) the inspection criteria associated with these repair criteria and methods were moved, as appropriate, to the inspection section of the proposed SG TS, (b) the repair criteria were moved, as appropriate, to the repair criteria section of the proposed SG TS, © the repair methods were moved to the repair method section of the proposed SG TS, and (d) thereporting requirements were moved to the reporting section of the proposed SG TS.There were some pre-existing reporting requirements associated with these repair criteria thatwere deleted since proposed new requirements eliminated the need for these reporting requirements. In addition, the timing of one of the reports was changed from 120 to 180 days after the initial entry into HOT SHUTDOWN. This change in the timing of the report was considered acceptable since 180 days is consistent with the TSTF-449 reporting timeframe and operating experience indicates that the growth and initiation of the indications discussed in these reports does not warrant a report within 120 days. In summary, the NRC staff determined that the previously approved repair criteria and repair methods were appropriately incorporated into the plant's TS.In addition to the above, the licensee also proposed a few changes that went beyondTSTF-449. For example, the licensee proposed, in part, to limit accident induced leakage to 216 gallons per day (0.15 gallons per minute (gpm)) for all SGs. Since this proposal was more restrictive than that required by TSTF-449 (which limited accident induced leakage, in part, to 1 gpm per SG), the NRC staff found it acceptable. Another example is that the licensee is proposing two SG programs since the OSGs at STL-2 are scheduled to be replaced in the fall of 2007. The OSG SG Program is contained in TS Section 6.8.4.I.2 and the replacement SG(RSG) Program is contained in TS Section 6.8.4.I.1. In addition, TS Section 6.8.4.I.2 includesthe inspection requirements and acceptance criteria for sleeving and alternate repair criteria that are approved only for the OSGs. Steam generator tube inspection report requirements for the OSGs and the RSGs are provided in separate TS Sections. The reporting requirements for the OSGs is located in TS Section 6.9.1.13 and the reporting requirements for the RSGs is located in TS Section 6.9.1.12. Since the proposed TS changes that went beyond TSTF-449 were generally consistent with the standard TS as modified to reflect the plant's licensing basis or were administrative in nature, the NRC staff determined that the proposed changes were acceptable.In addition, the licensee proposed changes to its TS Bases that went beyond TSTF-449. Thesechanges included significantly modifying its Operational Leakage Bases section to be generally consistent with the standard TS as modified to reflect existing requirements and the plant's licensing basis. In addition, the licensee modified the Bases for TS Section 3/4.4.8, "Specific Activity," to more accurately reflect its accident-induced leakage limit. Since these proposed changes were consistent with the plant's licensing basis, the intent of TSTF-449, or the standard TS, the NRC staff determined they were acceptable. The remainder of the application was consistent with, or more limiting than, TSTF-449.In summary, the NRC staff determined that the model SE is applicable to this review and findsthe proposed changes acceptable. Consistent with TSTF-449, the proposed TS changes include: (1) revised definitions of leakage, (2) a revised TS Section 3.4.6.2, "RCS (Reactor Coolant System) Operational Leakage," (3) a revised TS Section 3.4.5, "Steam Generator Tube Integrity," (4) new TS Sections 6.8.4.I.1 (RSGs) and 6.8.4.I.2 (OSGs) , "Steam Generator (SG)Program," (5) new TS Sections 6.9.1.12 (RSGs) and 6.9.1.13 (OSGs), "Steam Generator Tube Inspection Report," and (6) revised Index pages to reflect the proposed changes.

4.0 CONCLUSION

The proposed TS changes establish a programmatic, largely performance-based regulatoryframework for ensuring SG tube integrity is maintained. The NRC staff finds that it addresses key shortcomings of the current framework by ensuring that SG programs are focused on accomplishing the overall objective of maintaining tube integrity. It incorporates performance criteria for evaluating tube integrity that the NRC staff finds consistent with the structural margins and the degree of leak tightness assumed in the current plant licensing basis.

The NRC staff finds that maintaining these performance criteria provides reasonable assurance that the SGs can be operated safely without increase in risk.The revised TS will contain limited specific details concerning how the SG Program is toachieve the required objective of maintaining tube integrity; the intent being that the licensee will have the flexibility to determine the specific strategy for meeting this objective. However, the NRC staff finds that the revised TS include sufficient regulatory constraints on the establishment and implementation of the SG Program such as to provide reasonable assurance that tube integrity will be maintained.Failure to meet the performance criteria will be reportable pursuant to the requirements in10 CFR 50.72 and 50.73. The NRC reactor oversight process provides a process by which the NRC staff can verify that the licensee has identified any SG Program deficiencies that may have contributed to such an occurrence and that appropriate corrective actions have been implemented.In conclusion, the NRC staff finds that the TS changes proposed by the licensee in itsMay 25, 2006, application, and its January 22, and April 16, 2007, supplements conform to the requirements of 10 CFR 50.36 and establish a TS framework that will provide reasonable assurance that SG tube integrity is maintained without undue risk to public health and safety.The licensee included in its application the revised TS Bases to be implemented with the TSchange. The NRC staff finds that the TS Bases Control Program is the appropriate process for updating the affected TS Bases pages and has, therefore, not included the affected Bases pages with this amendment.

5.0 STATE CONSULTATION

Based upon a letter dated May 2, 2003, from Michael N. Stephens of the Florida Department ofHealth, Bureau of Radiation Control, to Brenda L. Mozafari, Senior Project Manager, U.S. Nuclear Regulatory Commission, the State of Florida does not desire notification of issuance of license amendments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed findingthat the amendments involve no significant hazards consideration, and there has been no public comment on such finding (71 FR 40747). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above that (1) there isreasonable 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.Principal Contributors: Trent L. Wertz Leslie MillerDate: May 27, 2007 Mr. J. A. StallST. LUCIE PLANTFlorida Power and Light Company cc:Mr. William E. Webster Vice President, Nuclear Operations Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, Florida 34957 Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Marjan Mashhadi, Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW.

Suite 220 Washington, DC 20004Mr. Douglas Anderson County Administrator St. Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982

Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741Mr. Gordon L. Johnston Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000Mr. Christopher R. CostanzoPlant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957Mr. Terry PattersonLicensing Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957Mark Warner, Vice PresidentNuclear Operations Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420Mr. Rajiv S. KundalkarVice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420Mr. J. KammelRadiological Emergency Planning Administrator Department of Public Safety 6000 Southeast Tower Drive Stuart, Florida 34997Mr. Bill ParksOperations Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000Mr. Seth B. DustonTraining Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000