ML17221A596

Proposed Tech Specs Revising Requirements for Boric Acid Makeup Sys

ML17221A596
Person / Time
Site:	Saint Lucie
Issue date:	01/22/1988
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17221A595	List: ML17221A594 ML17221A596 ML17221A597
References
NUDOCS 8801290198
Download: ML17221A596 (53)

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.ATTACHMENT 1 Marked-up Technical Specification Pages 3/4 1-8 3/4 1-9 3/4 1-10 (with 3/4 1-11 3/4 1-16 (with 3/4 1-17 (with 3/4 1-18 (with 3/4 1-19 3/4 6-16a B 3/4 1-2 (with B 3/4 1-3 insert)insert)insert insert)insert)880229'Oi98 880i22~F'DR A DOCK 05000335 PDR REACTIVITY CONTROL SYSTEMS 3 4.1.2 BORATION SYSTEMS FLOW PATHS-SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.1 As a minimum, one of the following boron injection flow'paths~@-

shall be OPERABLE: a.A flow path from the boric acid makeup tank via either a boric acid pump cr a gravity feed connection and charging pump to the Reactor Coolant System if only the boric acid makeup tank in Specification 3.1.2.7a is OPERABLE, or b.The flow path from the refueling water tank via either a charging pump or a high pressure safety injection pump*to the Reactor Coolant System if only'the refueling wate~tank in.Specification 3.1.2.7b is OPERABLE.APPLICABILITY:

MODES 5 and 6.ACTION: With none of the above flow paths OPERABLE.suspend all operations involving CORE ALTERATIONS or positive reactivity changes until at least one injection path is restored to OPERABLE status.SURVEILLANCE RE UIREMENTS 4.1.2.1 At least one of the above required flow paths shall be demonstrated OPERABLE: a.At least once per 7 days by/Cycling each testable power operated or automatic valve in the flow path required for boron injection through at least one complete cycle of full travel, and 3/4 1-8 Amendment No.p p, 8y*The flow path from the RWT to the RCS via a single HPSI pump shall only be established if: (a)the RCS pressure boundary does not exist, or (b)no charging pumps are operable.In this case.all charging pumps shall be disabled, and heatup and cooldown rates shall be limited in accordance with Fig.3.1-lh.ST.LUCIE-UNIT 1 l

3'e~REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS b.At least once per 31 days by 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.pk/eAs+oPJcc pent gp)blank~le~fLc, P~*i~"~il~p QaC:Idea~A'r~+M>~><<CS 1<$8 fiW<$$F$y ugr~y~f)+nb tie GOi'C.AC c'd PplC4 P I W<k ('c]ruler jjal ZS F (j,~'l1,c P/o~peC Ao)Qe-c Ac,'J Plnl(C~~7edg)5 retu rCd'e~I:i ST.LUCIE-UNIT 1 3/4 1-9

~~A~~1 C REACTIVITY CONTROL SYSTEMS FLOW PATHS-OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.2 ,+serb 4 Ancl.c~APPLICABILITY:

MODES 1, 2, 3 and 4.ACTION: With only one of the above required boron injection f'low paths to the Reactor Coolant System OPERABLE, restore at least two boron injection flow paths to the Reactor Coolant System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or make the reactor subcritical within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and borate to a SHUTDOWN MARGIN equivalent to ht least 2000 pcm at 200 F;restore at least two flow paths to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE RE UIREMENTS 4.1.2.2 At least two of the above required flow paths shall be demonstrated OPERABLE: a.At least once per 7 days by/v Cycling each testable power operated or automatic valve in the flow path through at least one complete cycle of full travel.ST.LUCIE-UNIT 1 3/4 1-10 Amendment No.g g

insert, paqe p)q I-IO mb least 5~o oq Qe, qnb3ouuno@tee.boron In~eonorI ('Aw p<h<s4h3'be.6P<<~~~: (L.Qp~q)g~~04'q0N (he,'boal6.Qih makeup tooth~ke Irenic, rneebnq fpaeIpea'run S.I.R,S panY aI or b)yI'a.a boric aeIb InaYen9 qnmp)nrcuqk a, ebaIqInq pggp>o@<Rcahe(Coo)ak<pshaw, b.One q'IonI 6, qroIn 0 e borIe.oaId eo4uq hanMLs)u3AS%ehn Ineem~q (peeI(<eamon E./.2.S py,'ra'Inrun')

via o.)ra~iQ]eQ palate.Rvouq4 a.obaneII oI enemy>o 4 Rene&he/a4 l)salem.L.Ibe penn p@geom 4e I eyuebnoI usher s)oraqe.kahn'la n.ebnIIglroI ply)$o%%ReaaIoI ho&454Al~Qg 4, lent,%t~c op~iIonI,ng@Ice boron In)enon q'io~poM She)hbt SPAN~~: a..One g)nnI pIIln porn each boric.aaId tnaIIenp 4<~nIAke enmbI'netI baA cohen'ts IaeeIIIn).W~'Peabo>>~~2K L)YI'a,be@bo(ieooIh rn@<<P'lem'rnu~S o.ebai~eq pmlIro%e.Pwekor 4s)ek<gsIIem.(lne qloolash prom eaeb'boric, aeI)rn6eup 4A.e, eombInce 4A, eo hen4 IIIeeSInq J(eeitI'eabon s.n.h e3, via.bo%, araI)>~)eggs>yeg'jhIoIIqh a K'hajj,)umph>o Re Peaekr looIak ps>em,~be$Žo pa@f'rom the.reqoebn~Inn@(sro<arte.ka4, I'rIa O, ebs,~In'omp

>o ke Pgae4r Lohak 5qhem,

REACTIYITY COtG'ROL SYSTEMS SURYEILLANCE REQUIREMENTS (Continued)

II b.At least once per 31 days by 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 At least once per 18 months during shutdown by: l.Cycling each power operated (excluding automatic) valve in.the flow path that is not testable during plant operation, through at least once complete cycle of full travel.2.Yerifying,.that each automatic valve in the flow path actuates to its correct position on a Safety Injection Actuation signal.d.'t te~s&.o~GE, pe,r zp/owns.u4a'Kc.I4~~5r A~x.%~a~Q>>'dling A'~pc<<Ace'ls LaloU 5S+hy ver Py<<J Nt'.sol~4a 0 pc~one.;cF A,~Go~:c-75~lC($)gD 6 6ouC-SS F, ST.LUCIE-UNIT 1 w,3/4 l-ll II II)tl~'4 h h REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES-SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.7 As a minimum, one of the followin borated water sources shall be OPERABLE: yppftd vA+<a.One boric acid makeup ank with a minimum~ad%volume of~gallons of 2.s+&we>ght percent d'or c ac'd (73'Il b.The refueling water Can w t: P~~~~l.A minimum contained volume of 125,000 gallons, 2.A minimum boron concentration of 1720 ppm, and 3.A minimum solution temperature of 40'F.APPLICABILITY:

MODES 5 and 6.ACTION: With no borated water sources OPERABLE, suspend all operations involving positive reactivity changes until at least one borated water source is restored to OPERABLE status.SURVEILLANCE RE UIREMENTS 4.1.2.7 The above required borated water source shall be demonstrated OPERABLE: 1 a.At least once per 7 days by: Verifying the boron concentration of the water, 2.Verifying the water level of the tank, and Amendment No." b.At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the RWT temperature when it is the source of borated water and the site ambient air temperature is<40'F.Dse+nh4cL~ST.LUCIE-UNIT 1 y J-C/I I 4 J I i

<a Ab<9<>o n ce.per-at hound~4ez Ac.g~c*~.Aux/'nny 8<.la(,'y w,'~~pg~~g~,g/wz 4y VEr Vying 5~7 fl,c Boa.'c 3e,'J Aw/ze>p s-S'wLea Mf+or.c.Ac,'J A~kc.g/n~l(k R QPZRwSZE-

!~g J 1 4~H~Wig 8,000 R O D 0 z I hC O O O CC O Cl a 7,000 130 120 110 100 LC W 90 I 6,000 8 10 12 STORED BORIC ACID CONCENTRATION (WT%)Figure.1-1 Minimum Boric Acid Makeup Tank Volume and Temperature as a Function of Stored Boric Acid Concentration ST.LUCIE-UNIT 1~~3/4 1-17 Amendment No.(

'l.

t t F GURE D.I-1 ST.LUCIE 1 MIN BAMT VOLUME VS STORED BAN CONCENTRATION (13 300)AC 0 EP AB PER TIO l 0 t2 tI 0 vn hl'0$C pl-)V m>0 UN CE OP TA IE RAT ON 50)10 250)(9 0 (835)ST.LUCIE-UNIT 1 2A 2.6 2.8 3.0 3.2 3A 3.6 (4196 PPM)(4546 PPM)(4895 PPM)(5245 PPM)(5595 PPM)(5944 PPM)(6294 PPM)38)IH M lmllC (wf 5 lerlr acid)0 1720 PN IN RWT 3/4 1-17 Ammendment No.~

REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES-OPERATING Answer I@~cd,d LIMITING CONDITION FOR OPERATION 4axr 3.1.2.8 At least two of the followin 4hmeCforated water sources sha'll be OPERABLE: The refueling water tank with: l.A minimum contained volume of 401,800 gallons of water, 2.A minimum boron concentration of 1720 ppm, 3.A maximum solution temperature of 100'F, 4.A minimum solution temperature of 55'F when in MODES 1 and 2, and 5.A minimum solution temperature of 40'F when in MODES 3 and 4.APPLICABILITY:

MODES 1;2, 3 and 4.ACTION: With only one borated water source OPERABLE, restore at least two borated water sources to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or make the reactor subcritical within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and borate to a SHUTDOWN MARGIN equivalent to at least 2000 pcm at 200'F;restore at least two borated I water sources to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE RE UIREMENTS 4.1.2.8 At least two borated water sources shall be demonstrated OPERABLE: a.At least once per 7"days by: Verifying the boron concentration in each water source, T.LUCIE-UNIT 1 3/4 1-18 Amendment No.,$$, 86' 1'W 0 o..Sor)c.Acid'tnagcup'4A.

8)n eeeordanee.n)~4 F)~u[e 3.)-1 and&&la rancieof 3.L):o 3'3)am'.pmeen4 boric<<eid L ssRc Io 4)10 ppbo(an).h.Boria kid Nageufgang

)5)'n accordance ncaa fiaiu)e 3,I-I andin%e'1'ange of3e ko R.S Ioai~h1 goree's boric acid (%As>o L))I q)nQw).Bar)a))oid)r)awaup'fangs)A and)e, cuk a)n)nicnun1 eo)nbaed eon)rewed boured u)a)er Wolulp in accordance.

nues Faire.3.)-).

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REACTIVITY CONTROL SYSTEMS SURVEILLANCE RE UIREMENTS Continued 2.Verifying the water level in each watet source~-aad-b.At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the RWT temperature.

, p,~gqlour, 6)uer Py'sj.A,~+5c Gor'c A~'d T k oi 4 de e<<~'~g~~k u4a 6<e d~A x.X~ay 8'l~'-)"'f'~" r5 Ac,/0&8~ST.LUCIE-UNIT 1 3/4 1-19 I~1'l h ll 1 4 l 8~b CONTAINMENT SYSTEMS SPRAY ADDITIVE SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.2 The spray additive system shall be OPERABLE with: 'a 0 b.A spray additive tank containing a volume of between 4010 and ggggg11 51~y Igh 500 and eC'.s o~3',~/, Two spray additive eductors each capable of adding.NaOH solution from the chemical additive tank to a containment spray system pump flow.APPLICABILITY:

MODES 1, 2 and 3.*ACTION: With the spray additive system inoperable, restore the system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />;restore the spray addi.tive system to 0?EPABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE RE UIREMENTS 4.'6.2.2 The spray additive system shall be d monstrated OPERABLE: a.At least once per 31 days by 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 positi'on.

b.At least once per 6 months by: l.Verifying the contained solution volume in the tank, and 2.Verifying the concentration of the NaOH solution by chemical analysis.c.At least once per 18 months, during shutdown, by verifying that each automatic valve in the flow path actuates to its correct position on a CSAS test signal." pp icab e when pressurizer pressure is>17~0 psia.ST.LUG I E-UNIT 1 3/4 6-16a Amendment, No.26 REACTIVITY CONTROL SYSTEMS BASES 3 4.1.1.5 MINIMUM TEMPERATURE FOR CRITICALITY The MTC is expected to be slightly negative at operating conditions.

However, at the beginning of the fuel cycle, the MTC may be slightly positive at operating conditions and since it will become more positive at lower temperatures, this specification is provided to restrict reactor operation when T is significantly below the normal operating temperature.

3/4.1.2 BORATION SYSTEMS The boron injection system ensures that negative reactivity control is available during each mode of facility operation.

The components required to perform this function include 1)borated water sources, 2)hgigpp.)p f1 h.4)bH Idpp , and)an emergency power supply from OPERABLE diesel generators.

With the RCS average temperature above 200'F, a minimum of two separate and redundant boron injection systems are provided to ensure single functional capability in the event an assumed failure renders one of the systems inoperable.

Allowable out-of-service periods ensure that minor component repair or corrective action may be completed without undue risk to overall facility safety from injection system failures during the repair period..The boration capability of either system is sufficient to provide a SHUTOOWN MARGIN from all operating conditions of 2000.pcm after xenon decay and cooldown to 200'F.The maximum boration capability requirement occurs at EOL from full power equilibrium xenon conditions.

jnse~k A~cLcd.The requirements for a minimum contained volume of 401,800 gallons of borated water in the refueling water tank ensures the capability for borating the RCS to the desired level.The specified quantity of borated water is consistent with the ECCS requirements of Specification 3.5.4.Therefore, the larger volume of borated water is specified here too.With the RCS temperature below 200'F, one injection system is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the additional restric-tions prohibiting CORE ALTERATIONS and positive reactivity change in the event the single injection system becomes inoperable.

ST.LUCIE-UNIT 1 B 3/4 1-2 Amendment No.77, gA 4'186

~I I J a r8pui'Izc,n M/-cnw Lc-~@~~or 8 r/4wyL op Lor'4 Ac i'~44<CQM&rjL4

~0/4..GO.~Ac.d rY~/Ceeg 7q</Q~(BAH!c)II I ss (f Qpgc/ay ljs/e>>lsak Cltur).74 z ra ge s'6a s/c/73l7./JA//o s aF 3.S-sacijlg/7 eccev/-C'4ll'7/ss/sss Sac'a~)~~/sar c Aw'd.PY!ar/se.8$+/o t4f ,sl/ooa ya//ossa aP 77zcs Lars/cs/ss sss/crs~~~/2 esl/7lo lg 27(.z gn//a~s ioP 4.Z oucjlp pe oe/-(sl87i/s/sas Sara~'l g<<.c Aa'a'8A QTs A d g oocs gn//o-a esP 77ao/s/As la.-W Ieaak~4~M l2,u7.A~,a,~~~OPqj'O-Oaves//~ae oE/iso p~r7./aseaQ ls r'e ju-iree feaqI:'l R,m.l<sU~4o~k Q<Rcz n/o

• I 1, 0 1 f I.Kg~i,'" isis, j'f l I REACTIVITY CONTROL SYS S BASES gg/0)allo~~OP 2 s'3 E wcipl,k e~oe k(937/k>G II 9 pp~g,oro~).2 BORATION SYSTEMS (Continued fter the plant has been pl ced in MODES boric acid solution from the The boron addition apabili 5 and 6 requires either boric acid tanks or allon g s of 1720 ppm borated water from the refuel-ing water tank to makeup for contraction of the primary coolant that could occur if the temperature is lowered from 200'F to 140'F.The restr$cttons associated with the establishing of the flow path from the RWT to the RCS via a single HPSE pump provide assurance that Appendix G pressure/temperature limtts will not be exceeded in the case of any inadvertent pressure transient due to a mass addition to the RCS.3/4.1.3 MOVABLE CONTROL ASSEMBLIES The specifications of this section ensure that (1)acceptable power distribution limits are maintained, (2)the minimum SHUTDOWN MARGIN is maintained, and (3)the potential effects of a CEA ejection accident are limited to acceptable levels.The ACTION statements which permit limited variations from the basic'equirements are accompanied by additional restrictions which ensure that the original criteria are met.The ACTION statements applicable to an iamovable or untrippable CEA and to a large misalignment

(>15 inches)of two or more CEAs, require a prompt shutdown of the reactor since either of these conditions may be indicative of a possible loss of mechanical functignal capability of the CEAs and in the event of a stuck or untrippable CEA, the loss of SHUTDOWN MARGIN.Overpower margin is provided to protect the core in the event of a large misalignment

(>15 inches)of a CEA.However, this misalignment would cause distortion of the core power distribution.

This distribution may, in turn, have a significant effect on (1)the available SHUTDOWN MARGIN, (2)the time-dependent long-term power distributions relative to those used in generating LCOs and LSSS setpoints, and (3)the ejected CEA worth used{n the safety analysis.Therefore, the ACTION statement associated with the large mis-alignment of the CEA requires a prompt realignment of the misaligned CEA.For small misalignments

(<15 inches)of the CEAs, there is 1)a small degradation in the peaking factor s relative to those assumed in generating LCOs and LSSS setpoints for DNBR and linear heat rate, 2)a small effect on the time dependent long term power distributions relative to those used in generating LCOs and LSSS setpoints for DNBR and linear heat rate, 3)a small effect on the available SHUTDOWN MARGIN, and 4)a small effect on the ejected CEA worth used in the safety analysis.Therefore, the ACTION statement associated with the small misalignment of a CEA permits a one hour time interval during which attempts may be made to restore the CEA to within its alignment requirements prior to initiating a reduction in THERMAL POWER.The one hour time limit is sufficient to (1)identify causes of a misaligned CEA, (2)take appropriate corrective action to realign the CEAs, and (3)minimize the effects of xenon redistribution.

ST.LUCIE-UNIT 1 8 3/4 1-3 Amendment No.g7,7J, 8>

0 C 4 h J I H~4~

ATTACHMENT 2 SAFETY EVALUATION E JW/020.PLA 0 0 0 RIC ACID CONCENTRATION REDUC N 1,0 INTRODUCTION The proposed changes would r evfse the requfrements for the borfc acfd makeup (BANTU)system.These changes would remove the requfrement to heat trace a ma4orfty of the 8AN system, reduce the allowable boron concentr atfon requfrements and fncrease the water volume to meet the shutdown margfn requfrements of Technfcal Specfffcatfons 3.1.1.]and 3.1.1.2.In addftfon, Fpt.has reevaluated the past t.OCA sonp pH to assess the affects of the borfc acfd makeup tank boron concentrat1on reductfon on thfs analysfs.2.0 1 t 5CU 5 SION The proposed changes would modffy the requfrements for the borfc acfd makeup (8NU)system whfch fs used to provfde an adequate volume of borated water fnto the reactor coolant system (RCS)to assure that'he shutdown margfn meets the requfrements of Technfcal Specfffcatfons 3.1.1.1 and 3,1.1,2.The exfstfng plant desfgn requfres the heat tracfng cfrcufts for the SANO system to be operable fn order to Na1ntafn the temperature of flufd fn the 8NU system hfgh enough to prevent the borfc acfd from precfpftatfng at aibfent temperatures and thus assure the BAN system functfons properly.In order to fncrease plant operatfonal flexfbflfty and 1mprove SNU system relfabflfty, ft fs proposed that the requirement to heat trace the SNU system be deleted.The followfng changes are proposed to allow removal of heat trecfng.(1)The boron concentratfon requfrements for the BhNl system w11l be reduced from a~ange of 8.0 to 12.0 wefght percent to 2.5 to 3.S wefght percent borfc acfd.Thfs reductfon fn borfc acfd concentratfon wfll prevent boron precfpftatfon at ambfent temperatures fn the auxf1 fary bulldfng after the heat tracfng fs removed, (2)Increase the upper range of the

required borated water volume for the BANJ system from 8,000 gallons to 13>300 gallons to assure that the existing requirenents for the shutdown margin specified in Technical Specifications 3.1.1.1 and 3.1.1.2 are met with the proposed requirements for lower boron concentration.

In add1tion a topical report, Boric Acid Makeup Tank Concentration Reduction Effort CE-353(F)has been submitted to support the request for the proposed changes.The rev1sed Technical Specifications 3/4.1.2.1, 3/4, 1.2.2, 3/4.1.2.7, 3/4.1.2.8 and the Bases 3/4.1.2 are submitted for rev1ew and approval.3.0 EYALUATION The proposed changes of requirements for the BAN systel, the associated Technical Specif1cation changes and the topical report (CEN-353(F))

are discussed below.3.1 BORATION CAPACITVhe ttlthodology and analytical results to support the request for the Technical Specification changes are documented in the top1cal report (CEN-353(F))

and include two distinct series of calculations for the required and available boron concentrations in the RCS to ma1ntain a safe shutdown margin.Both are employed at each time of inter est in the plant cooldown conditions.

3,1.1 Evaluation of Anal sis for Re uired Boron Concentration The analysis for the required boron concentration is based on the shutdown requirements of Branch Technical Position 5.1 for a class 3 plant.{SRP Section 6.4.7).Specifically, the shutdown marg1n r equfraaents are consistent w1th that specif1ed in Techn1cal Specifications 3.1.1,1 and 3.1.1.2 for Operating Nodes 1 through 4, and 5 through 6, respect1vely.

Conservative core physics parameters were used to calculate the boron concentration required to be present in the RCS for the shutdown margins required by the Technical Specfffcatfons.-In the analysis, the analytical and measurement uncertafntfes were included to ensure that the upper bound boron requfrements were predfcted.

The uncertafntfes fnclude-10K in scram worth,+10%fn moderator temperature feedback,~Sf fn Goppler reactivfty feed back and the time constant of 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> for xenon decay to maximize the xenon poison effect.Evaluation of Anal sfs for Available Boron Concentration The calculated method to determfne the avaflable boron concentratfon fs based on a steady state mass balance for boron fn the entire RCS,.It fs assumed that the borated water added to the RCS fs equal to the fluid volume contract1on due to the cooldown whfle the pressurfzer water level fs mafntafned constant.In the analys1s{CKN-353(F)), various core condftfons were considered to mfnfmfze the avaflable boron reactivity effect.The lfmftfng core condftfons fdent1ffed ah)used fn the analyses were:{1)end-ofwycle condftfons w1th fnftfal RCS concentrations at zero ppm boron, (2)the core wfth the most: reactive control rod fully stuck out, (8)plant power at 100%with 100%equflfbr fum xenon prior to fnftfatfon of plant shutdown, (4)a slow plant cooldown rate of 12.5'F/hr.(S)end-of-cycle moderator cooldown effects and (6)begfnnfng-of-cycle boron reactfvfty worths..These assumptfons are conservatfve wfth respect to mfnfmfzfng the boron reactfvfty affects since assumptfons

())and (2)mfnfmfze the exfstfng boron wfthfn the core and available scram worth, assumptfons (3)and (4)maximize the xenon poison effect and assumptfons (5)and (6)maximize the boratfon requirements due to moderator cooldown effects.The use of a cooldown rate of 12.5'F/hr fs consfstent with the plant test procedures for the boron mfxfng test performed during a naturil-.cfrculatfon test at another Combustfon Kngfneerfng plant.?ncluded fn CKN 3(3(F)fs an analysfs that demonstrates that the boratfon requfrements for the fastest cooldown rate of 100'F/hr., as allowed by Technfcal Specfffcatfons fs bounded by the case when the cooldown rate was lfmfted to 12'F/hro In conclusfon, the topfcal report used a conservatfve method to calculate the requfred boron concentrat1on necessary to Iafntafn the shutdown margfn requfred by Technfcal Specfffcatfons 3.1.1.1 and 3,1,1,2 durfng a safe shutdown scenar'fo.

A conservatfve RCS makeup scenar1o was used to demonstrate that proposed boron concentratfon and volume requfrements for the BAMU t<<nks wfll mafntafn the safe shutdown margfns r equfr'ed by the technfcal specfffcatfons.

TRANSIENT ANO ACCIOENT EVALUAT!ON As stated fn Sectfon 8.6 of CKN-353(F) credft fs not taken for boron addftfon to the reactor coolant system fros the borfc acfd makeup tanks for, the purpose of re<<ctfvfty control fn the accfdents<<n<<lied fn Chapter 15 of the plant's Ffnal Safety Analysfs Report.The response of an operator, ther'efore, to such events<<s steam lfne break, overcoolfng, boron dflutfon, etc., wfll not be affected by a reduct1on fn BAMT concentratfon.

In partfcular, the actfon statements assocfated wfth Technfcal Specfffcatfon 3.1.1,2 requfre that boratfon be coaeenced at greater than 40 gallons per Itfrtute us1ng<<solutfon of<<t least 1120 ppm boron fn the event that shutdown margfn fs lost.Such statements are conservatfvely based upon the refuelfny water tank concentratfon and are therefore fndependent of the amount of boron fn the BANTs.It should be noted that even after reducfng the boron concentratfon fn the BNT, the mfnfNLNr boron concentratfon 1n these tanks fs hfgher than 1720 ppm.Sfm1lar to the Technfcal Specfffcatfon actfon steps fn the event of a loss of shutdown margfn, the operator gufdance fn Combustfon Engfneerfng's Emergency procedure Gufdelfnes (KPGs), CEH-152, Rev.2.are also fndependent of specfffc boron concentratfons w1thfn the horic acid makeup tanks.Specifically, the acceptance criteria developed for the reactivity control section of the Functional Recovery Guidelines of CEN-152 are based upon a boron add1tIon rate from the chemical and volume control system of 40 gallons per minute without reference to a particular boration concentration.

The reduction In boron concentration within the boric acid makeup tanks therefore has no impact on, and does not change, the guidance contained in the EPGs.3.3 E UINENT EVALUATION An evaluation has been performed to identify those colponents 1n the boric acid makeup (BAN)systetl that would be affected by the reduct1on of boric acid concentration.

Boric acid concentration will be reduced from a range of 8 to 12 we1ght percent to a range of 2.5 to 3.5 weight percent.ln addition>the normal operat1ng temperature will be reduced frol a range of 120-160'l:

to a range of 55 to 90'F.The safety related portions of the BAN system that must operate properly to deliver an adequate amount of boric acid during a safe shutdown scenario include, piping>valves, boric acid Iakeup tank(s)and the boric acid makeup pulps.A reduction in the boric acid concentration or telperature will not affect the operation of the pumps, piping or valves.The only equipment potentially affected by this change is the level instruments of the boric ac1d makeup tanks.Since the normal operating tank tewperature will be lowered, the level transiitters may require recalibration to provide accurate level indications.

High and low level setpoints should also be examined.Oeenergizing the BAN system heat tracing will requIre an alternative means to verify that the temperature 1s above the precipitation point of the fluid.Administrative controls must be Instituted to verify that the auriliary bu11ding temperature ts adequately monitored.

Ensuring that the Auxiliary building temperature is greater than 65'F will ensure that the borIc ac14 will not precipitate out of solution.t:PL will address.this findIng presented above.

1'he reductfon fn borfc ac1d concentratfon fn the borfc acfd storage tanks has caused a correspondfng reductfon fn the post-LON mfnfmum sump boron concentrat1on.

A reanalys)s of the suwp pH and spray system pH has been performed.

An a+ustment to the rate or sodfum hydroxfde addftfon has been made to mafntafn the orfgfnal equfpment Envfronmental gualfffcatfon pH band of 8.5 to 11.0.An evaluatfon of the general corrosfon rate of metallfc Naterfals and the affects on non-metallfc materfals has been performed.

It has been determfned that there 1s no adverse affect on fn-contafnwent materfals ff the pH level fs mafntafned fn the orfgfnal pH band.Mhfle the sodfum hydroxfde concentratfon fs varfed a reductfon fn the ffnal boron concentratton fn the contafnment sump wfll not adversely affect the harsh env1ronment qualfffcatfon of the fn-contafnnant equfpNent.

4.0 TECHNICAL SPECIFICATION CHANGES The Techn1cal Spec1f1cat1on changes and the reason for tha1r acceptab111ty are prov1ded below.Techn1cal S ac1f1cat1on 3 4.1.2.1 Borat1on S stems Flow Paths-ShutdawnThe proposed change to the Techn1cal Spac1f1cat1ons el1m1nates the riqu1reaent for heat trac1ng of the bor1c ac1d makeup (BANU)system, The des1gn purpose of heat trac1ng of the BNU system 1s to ma1nta1n the temperature of flu1d 1n the BNU tanks and the borat1on flowpaths h1gh enough to prevent the bor1c ac1d fma prec1p1tat1ng.

The proposed changes to T.S.3/4.1.2.7 and T.S.3/4.1.2.8 reduce the concentrat1on 1n the BANU tanks to a max1im concentrat1on of 3.5 we1ght Percent bor1c ac1d, wh1ch w111 not prec1p1tate at, the borated water temperature h1gher than 55'F.Chee1cal analyses have shown that a 3.5 we1ght percent solut1on of bor1c ac1d w111 rema1n d1ssolvcd (1.e., w111 not prac1p1tate or"plate out")at solut1on temperatures above 50F.The proposed changes also 1nclude a surve1llance requirement to assure that the borated water source 1s operable by ver1fy1ng that the temperature 1n the BANU 1s above 55'F whenever the aux111ary bu11d1ng temperature 1s below 55'F.Cons1stent w1th the new surve111ance requ1rement above, the old surve1llance requ1renent to ver1fy the flow path temperature above the temperature 11N1t 11ne on F1gure 3.1-1 has been deleted.Techn1cal S ec1f1cat1on 3 4.1.2.2 Flow Paths-0 erat1n Currently, the Techn1cal Spec1f1cat1ons require two out of the follow1ng three f1ow paths for boron 1n)ect1on 1nto the RCS: (1)a BNU tank gravity feed path and assoc1atad heat trac1ng, (2)a BANl-tank path v1a a bor1c ac1d makeup pump and assoc1ated heat trac1ng.or (3)flow path from the refuel1ng water tank;

The proposed changes require a flow path from any credfted source of water (refueling water storage tank and/or BANJ tank (or tanks))to bc operable.These changes are consistent with the assumptfons used in the topfcal report, CKH-353(F).

The proposed change to the tcchnfcal speciffcatfon eliminates the requirement for heat tracing of the boric acid makeup (SNU)system.As fn Tcchnical Specfffcatfon 3/4.1.2.1 deletion of the requfriment to heat trace thc BANU system fs consistent with the ability of the borfc acid to remafn fn solutfon at teiperature above 50'F.The proposed change fncludes a surveillance requfrcmcnt to assure that the boratcd water source fs operable by verifying that the temperature fn the BNU fs above 65'F whenever the auxiliary bufldfng temperature fs below 56'F.As fn Technical Specfffcatfon3/l.1.2.1 the old surveillance requirement for temperature verfffcatfon of the flow path fren the boric acid makeup tanks has been deleted.Technical S cfffcatfon 3 4.1.2.7 Sorated Mater Sources Shutdown.The existing Technical Specification requires that one of the two 8NU tanks and its associated heat tracing be operable with the tank containing 8 weight percent boron and a mfnfeuw content of 1660 gallons.The proposed change will delete the heat tracfng operability requirement, lower the boric acfd concentratfon to a range of 2.5 to 3.5 weight percent, change the mfnfmum BAHT content to 3650 gallons and modffy the surveillance requirement to verify that the BA%tank temperature fs above 55'F whenever the auxiliary bufldfng temperature fs below 55'F.As fn Technical Speciffcatfon 3/4.1.2.1 the old surveillance requirement to verify the temperature of the, flow path fren the borfc acid makeup tanks has been deleted.These changes are consistent with the analysis presented fn CKN-353(F), whfch dcionstrates adequate boratfon capability at the lower borfc acid concentratfons and the ability for boric acfd to rcmafn fn solutfon at these concentrations at temperatures above 50'F.<)',8)

Fi ure 3.1-1 for 0 eratin Modes 1 to I The figure spec1fies the minimum required SANU water volume and temperature as a function of stored boric acid concentrat1on for the various plant operating modes.The revised figure spec1fies the m1nimum required water volume (contained fn one or both BAMU tanks)as a ruhctfon of bor1c acid concentration in the BAMU tank.This curve was generated fn the topical report for a minimum refueling water tank boron concentration of 1720 pprn boron.This curve conservatively bounds SAMU tank minima required water volumes for conditions when the refueling water tank boron concentrat1on is gr'eater than 1720 ppm.The range of boron concentration fn the SQQ tank has been reduced from 8.0 to 12.0 weight per'cent boric acid to 2.5 to 3.5 weight percent.The upper range of the requfred borated water volume 1ncreases from 7,900 gallons to 13,300 gallons.The revised Figure 3.1-1 fs consistent wIth the analytfcal results of the topical report (CKN-353(F))

for plant condfifons at Operating Nodes 1 through 4 to mafnta1n the required safe shutdown margin.The temperature versus BNT concentratfon curve has been removed sfnce ft 1s no longer required.Technical S ecfffcatfon 3,1'.2.8 Sorated Mater Sources-0 ratfn The current Technical Specfffcatfon requires that at least one SAMU tank and its associated heat tracing be operable w1th the contents of boric acid 1n the tank to be consistent with the existing Ffgur'e 3o1 1.The exfst1ng Ffgure 3.1-1 specifies, the voluie of boric acid of 7,900 gallons at a minimum concentration of 8.0 weight percent to be maintained fn the BAMU tank.The proposed changes are to provide a new range of boric ac1d concentration of 2.5 to 3.5 weight percent for one or both of the BAMU tanks.The revised volumes of Figure 3.1-1 raises the mfn)mum water volume to 8,350 gallons.Oeletfon of I the requirement to heat trace the BAMU systeat is consistent with the ability to ma1ntain 2.5 to 3.5 weight percent boric acid in solution at temperatures above 554F The revised surveillance requ1rements deletes verifying BAMU tank temperature unless the aux111ary bui]ding temperature is below 55'F.As a conservatisi, this verification of temperature is done more frequently and the old surveillance requirement has been deleted.Bases-3/4.1.2 8oration S stems The Technical Specification define the required components for the boron in)ection system which ensure that negative reactivity 1s available during each mode of operation and define boric acid concentration and volume requ1raments for the SANJ tanks and refueling water tank (RiP).For Mddes 1 through 4 the proposed changes revise the boric acid concentration and volume requirements for the BAMU tank in accordance with the proposed Figure 3.1-1 and the corresponding twinilIN required borated water volumes of between 9,000 and l4,000 gallons w1th boron concentration of 020 ptxi froti the RMT-or 45,000 gallons with boron concentration of l720 ppw froa the RMT'lone.For Modes 5 and d the proposed changes revise the boric acid concentration and volume requirements of the BANJ tanks and the NT to be consistent with the analyses in the topical report CEN-353(f).

5.0 f NVIRONMKNTAL CONSIDERATION This amendment involves changes 1n the insta11at1on or use of components located with1n the restricted area.The proposed amendment involves no significant increase in the amounts of any effluents that may be released offsite and there 1'i no signif1cant increase in indiv1dual or cumulative occupational radiation exposure.As d1scussed above the proposed changes invo1ves no signif1cant hazards considerations.

Accordingly, the amendment meets the eligibility criter1a for categorical exc1usion set forth in 10 CFR 51.22(c)(9).1.0 SODIUM HYDROXIDE CONCENTRATION REDUCTION

1.0 INTRODUCTION

This evaluation is to document the analysis required to.reduce the Chemical Storage Tank NaOH solution from a concentration of 304-324 to 28.5%-30.54 by weight.This change is necessitated by a concurrent reduction of the boric acid concentration in the boric acid makeup tanks from 8.04-12.04 to 2.54-3.5%by weight 2.0 DISCUSSION The affected design bases for the Iodine Removal System are: a)To maintain the containment spray nozzle pH between 8.5 and 11.0 until such time that a Decontamination Factor of 100 is achieved;and b)To achieve a containment sump pH equal to or greater than 8.5 and less than 11.0 after all the spray chemical mixes with the available water inventory including, RWT, safety injection tanks, bo ic acid ma eu tanks, and the reactor coolant system blowdown to assure retention of iodine in the sump solution.Based upon the above design bases, Technical Specification 3.6.2.2 requires the maintenance of an operable Chemical Storage Tank containing a volume of between 4010 and 5000 gallons of 30%to 32%by weight sodium hydroxide solution.3.0 EVALUATION The reference calculation was performed to evaluate the worst case containment sump and containment spray nozzle pH conditions.

following a LOCA.The evaluation verifies that the containment sump and containment spray nozzle pH are maintained between 8.5 and 11.0 at all times during the injection and recirculation phases of containment spray actuation.

For the low sump pH analysis, all borated water sources were considered to be at their highest level and concentration.

The sodium hydroxide tank was assumed to be at its lowest level and concentration.

For the high sump pH analysis, the converse was evaluated (i.e.low level and concentration borated water sources concurrent with a high level and concentration NaOH source).In addition, the 11 analysis e uated the impact of the lowing three cases: 1.Minimum safeguard flow.(i.e.1 CS pump+1 HPS I pump+1 LPSI pump).Loss of o f f site power with one diesel failure.2.Maximum safeguard flow and single failure of one CS PumP.(1 CS PumP+3 HPSI PumPs+2 LPSI pumps).Offsite power available.

3.Maximum safeguard flow (i.e.2 CS pumps+3 HPSI pumps+2 LPSI pumps).Offsite power available.

The results of the evaluation confirm that pH can be maintained within the allowable limits for the containment sump and containment spray nozzle.However, a change to the Chemical Storage Tank concentration will be required.4.0 TECHNICAL SPECIFICATION CHANGES The proposed change to the Technical Specifications is to modify the required Chemical Storage Tank contents from between 4010 and 5000 gallons of 30%-32%by weight NaOH solution to 4010 to 5000 gallons of 28.54-30.54 by weight NaOH solution.These changes are required to offset the projected increase in containment sump and containment spray nozzle pH due to the reduction of boric acid concentration in the boric acid makeup tanks.:12

ATTACHMENT 3 DETERMINATION OF 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, 10 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 (1)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: (1)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.

Credit is not taken for boron addition to the reactor coolant system from the boric acid makeup tanks (BAMTs)for the purpose of reactivity control in the accidents analyzed in Chapter 15 of the St.Lucie Unit 1 Final Safety Analysis Report (FSAR).Response to events such as steam line break, overcooling, boron dilution, etc., will not be affected by a reduction in the BAMT boron concentration.

The ACTION statements from Technical Specification 3.1.1.2 require that boration be commenced at greater than 40 gallons per minute using a solution of at least 1720 ppm boron in the event that shutdown margin is lost.The BAMT boron concentration after the proposed reduction will remain greater than or equal to 1720 ppm.The reduction in boron concentration is accounted for by increasing the volume of boric acid solution that must be contained in the tanks (and by also crediting borated water from the Refueling Water Tank (RWT)).Since the components (or their function)necessary to perform a safe shutdown have not been changed or modified, this change does not significantly increase the probability or consequences of any accident previously evaluated.

In addition, administrative controls on the BAMT temperature and boron concentration ensure that the lack of heat tracing does not result in precipitation of the boron.E JW/020~PLA The proposed change also reduces the concentration of caustic available in the Chemical Storage Tank in order to maintain the containment sump and containment spray nozzle pH within the design limits of 8.5 to 11.0.No change is made to the design bases of the Iodine Removal System or its subsystems, the Chemical Storage Tank and the caustic addition system.The reduction in boric acid concentration in the BMATs has caused a corresponding reduction in the post-LOCA containment sump minimum boron concentration.

A reanalysis of the sump pH and containment spray system pH has been performed.

An adjustment to the rate of sodium hydroxide addition has been made to maintain the original equipment Environmental Qualification pH band of 8.5 to 11.0.An evaluation of the general corrosion rate of metallic materials and the effects on non-metallic materials has been performed.

It has been determined that there is no adverse affect on in-containment materials if the pH level is maintained in the original pH band.With the sodium hydroxide concentration reduction and reduction in the final boron concentration, the harsh environment Equipment Qualification of the in-containment equipment will be unaffected as will the post-LOCA containment sump pH.Therefore, there is no impact on the equipment in the post-LOCA scenerio nor a reduction in the post-LOCA containment iodine removal capability.

(2)Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The ACTION statements from Technical Specification 3.1.1.2 require that boration be commenced at greater than 40 gallons per minute using a solution of at least 1720 ppm boron in the event that shutdown margin is lost.The BAMT boron concentration after the proposed reduction will remain greater than or'qual to 1720 ppm.The reduction in boron concentration is accounted for by increasing the volume of boric acid solution that must be contained in the tanks (and by also crediting borated water from the Refueling Water Tank (RWT)).The reason for requiring a heat tracing circuit was to ensure that the dissolved boric acid remained in solution and available for injection into the RCS to adjust core reactivity throughout core life.By lowering the boron concentration to a maximum of 3.5 weight percent, chemical analyses have shown there is no E JW/020.PLA possibility of the boron precipitating out of solution as long as the temperature of the boric acid remains above 50 F;thus, there is no longer a need for heat tracing.Since the boron will remain in solution when the BAMT flowpaths are credited for reactivity control during a safe shutdown scenario, heat tracing is no longer required to maintain the Boric Acid Makeup (BAMU)system operable.Therefore, this change does not create the possibility of a new or different kind of accident from those previously evaluated.

The reduction in caustic concentration available in the chemical storage tank does not alter the design function of the Iodine Removal System.The Iodine Removal System will operate with slightly reduced NaOH solution in response to reduced boric acid in the BAMTs.(3)Use of the modified specification would not involve a significant reduction in a margin of safety.The intent of the Boration Systems and Borated Water Sources Technical Specifications is to ensure that there are two redundant flowpaths from the borated water sources to the RCS to allow control of core reactivity throughout core life.This requires that sufficient quantities of boron be stored in the BAMTs and that this borated water can be delivered to the RCS in the event of a single active failure of a system component or a seismic event.Reducing the maximum boric acid concentration to less than 3.5 weight percent has been compensated for by increasing the required minimum volumes of borated water.In addition, reducing the maximum boron concentration allows a deletion of the requirement to heat trace the BAMU system since chemical analyses have shown that a 3.5 weight percent solution of boric acid will remain in solution at temperatures above 50 F.Administrative controls on the boric acid makeup tank temperature and boron concentration ensure that a lack of heat tracing does not result in precipitation of the boron.Therefore, the reduction of boric acid concentration and the deletion of heat tracing in the BAMU system does not cause a significant reduction in the margin of safety.EJW/020.PLA Also, the margin of safety as defined by the Technical Specifications has not been significantly reduced due to the reduction in NaOH solution, since the change does not alter the effectiveness of the caustic addition subsystem.

That is, the NaOH reduction change is equally balanced by the reduction of boric acid in the boric acid makeup tanks.Based on the above, we have determined that the amendment request does not (1)involve a significant increase in the probability or consequences of an accident previously evaluated, (2)create the probability 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'oes not involve a significant hazards consideration.

EJW/020.PLA