Text

Application to Add Limiting Condition for Operation (LCO) 3.0.6 to the Technical Specifications
	ML18151A472
Person / Time
Site:	Saint Lucie, Seabrook, Turkey Point
Issue date:	05/29/2018
From:	Larry Nicholson; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2018-049
	Download: ML18151A472 (211)
	v • d • e

l=PL.. MY 29 2018 L-2018-049 10 CFR 50.90 ATIN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Florida Power & Light Company St. Lucie Units 1 and 2, Docket Nos. 50-335, 50-389 Turkey Point Units 3 and 4, Docket Nos. 50-250, 50-251 N extEra Energy Seabrook, LLC Seabrook Station, Docket No. 50-443

Subject:

Application to Add Limiting Condition for Operation (LCO) 3.0.6 to the Technical Specifications Florida Power & Light Company (FPL), acting on behalf of itself and as agent for NextEra Energy Seabrook, LLC (NextEra) is submitting a request for an amendment to the technical specifications (TS) for St. Lucie Units 1 and 2, Turkey Point Units 3 and 4, and Seabrook Station. The proposed amendments modify the TS to incorporate the provisions of Limiting Condition for Op.e ration (LCO) 3.0.6 in the improved standard TS (ISTS), which provide the actions to be taken when the inoperability of a support system results in the inoperability of related supported systems. In addition, the proposed change adds a new Safety Function Determination Program to the administrative section of the TS to ensure that a loss of safety function is detected and appropriate actions are taken when using the provisions of LCO 3.0.6.

The enclosure to this letter provides FPL's and NextEra's evaluation of the proposed change. to the enclosure provides the existing TS pages marked up to show the proposed changes, and Attachment 2 provides existing TS Bases pages marked up to show the proposed changes. Retyped TS pages incorporating the proposed changes will be provided when requested by the NRC project manager. The changes to the TS Bases are provided for information only and will be incorporated in accordance with the plant's TS Bases Control Program upon implementation of the approved amendment. Attachment 3 provides a table of support system required actions in the ISTS that direct entering the conditions and required actions of supported systems and shows how these required actions are addressed in the proposed change.

This letter contains no new or revised regulatory commitments.

FPL requests approval of the proposed amendments by April 1, 2019. Once approved, the amendments shall be implemented within 90 days.

In accordance with 10 CPR 50.91, a copy of this application, with attachments, is being provided to the designated officials in Florida and New Hampshire.

Florida Power & Light Comp any 700 Universe Boulevard, Juno Beach, FL 33408

i I

I L-2018-049 Page 2 of 2 If you should have any questions regarding this submittal, please contact Steve Catron, Fleet Licensing Manager, at 561-304-6206.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on May '2..E , 2018 Sincerely, Larry N cholson Director, Nuclear Licensing and Regulatory Compliance Florida Power & Light Company Enclosure cc: NRC Project Manager - St. Lucie NRC Project Manger - Turkey Point NRC Project Manager - Seabrook Regional Administrator - NRC Region 1 Regional Administrator - NRC Region 2 NRC Resident Inspector - St. Lucie NRC Resident Inspector - Turkey Point NRC Resident Inspector - Seabrook Ms. Cindy Becker, Florida Department of Health Director Homeland Security and Emergency Management (New Hampshire)

Mr. John Giarrusso, Jr., Nuclear Preparedness Manager (Massachusetts)

L-2018-049 Enclosure Page 1 of 33 E nclosure Evaluation of the Proposed Change

SUBJECT:

Application to Add Limiting Condition for Operation (LCO) 3.0.6 to the Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Current Technical Specifications Requirements 2.2 Reason for the Proposed Change 2.3 Description of the Proposed Change

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration Analysis 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

- Markup of the Technical Specifications - Markup of Proposed Bases Changes - Table of Support System Actions that Direct Entering Actions of Supported Systems

L-2018-049 Enclosure Page 2 of 33 1.0

SUMMARY

DESCRIPTION Florida Power & Light Company (FPL), acting on behalf of itself and as agent for NextEra Energy Seabrook, LLC (NextEra) is submitting a request for an amendment to the technical specifications (TS) for St. Lucie Units 1 and 2, T urkey Point Units 3 and 4, and Seabrook Station. The proposed amendments modify the TS to incorporate the provisions of Limiting Condition for Operation (LCO) 3.0.6 in the improved standard TS (ISTS), which provide the actions to be taken when the inoperability of a support system results in the inoperability of related supp orted systems. In addition, the proposed change adds a new Safety Function Determination Program to the administrative section of the TS to ensure that a loss of safety function is detected and appropriate actions are taken when using the provisions of LCO 3.0.6.

2.0 DETAILED DESCRIPTION 2.1 Current Technical Specifications Requirements The Seabrook and Turkey Point TS, which are based on NUREG-0452, Standard Technical Specifications for Westinghouse Pressurized Water Reactors [Reference 1),

do not include a provision similar to LCO 3.0.6 in NUREG-1431, Standard Technical Specifications Westinghouse Plants [Reference 2]. Similarly, the St. Lucie TS are based on NUREG-0212, Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors [Reference 3], which does not include a provision similar to LCO 3.0.6 in NUREG-1432, Standard Technical Specifications Combustion Engineering Plants [Reference 4] .

2.2 Reason for the Proposed Change This change incorporates the provisions of LCO 3.0.6 in the ISTS, which addresses the issue of cascading when implementing the TS. The proposed change will eliminate the potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' Actions. The Actions necessary to ensure the plant is maintained in a safe condition are included in the support system's Actions, which may include directions to enter th e Actions for the supported system when appropriate.

2.3 Description of the Proposed Change 2.3.1 St. Lucie Units 1 and 2

a. Revise Specification 3.0.2 to include LCO 3.0.6:

3.0.2 Upon discovery of a failure to meet an LCO, the Required ACTION(s) of the assoeiated eonditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6 If the LCO is met or is no longer applicable prior to expiration of the specified time interval(s), completion of the Required ACTION (s) is not required, unless otherwise stated.

L-2018-049 Enclosure Page 3 of 33

b. Add new LCO 3.0.6:

3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the ACTIONS associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered.

This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification [6.8.4.r (Unit 1)] [6.8.4.s (Unit 2)}, "Safety Function Determination Program (SFDP)." Ifa loss ofsafety fiznction is determined to exist by this program, the appropriate ACTIONS ofthe LCO in which the loss ofsafety fiznction exists are required to be entered.

When a support system's ACTION directs a supported system to be declared inoperable or directs entry into the ACTIONS for a supported system, the applicable ACTIONS shall be entered in accordance with LCO 3.0.2

c. Add notes and Actions that direct entering the Actions for supported systems.

1. Add note to LCO 3.4.6.2, "Reactor Coolant System Leakage," Action c:

Enter applicable ACTIONS for systems made inoperable by an inoperable pressure isolation valve.

In addition, delete the following from St. Lucie Unit 1 TS 3.4.6.2, Action c:

(Note, however, that this may lead to ACTION requirements for systems iflvolved.)

2. Add note to Actions in LCO 3.6.1.3, "Containment Air Locks":

Enter the ACTION ofLCO 3.6.1.2, "Containment Leakage," when air lock leakage results in exceeding the overall containment leakage rate.

3. A dd notes to Actions in LCO 3.6.3.1 (Onit 1) LCO 3.6.3 Unit 2, "Containment Isolation Valves":

1. Enter applicable ACTIONS for systems made inoperable by containment isolation valves.

2. Enter the ACTION ofLCO 3.6.1.2, "Containment Leakage,"

when leakage results in exceeding the overall containment leakage rate acceptance criteria.

4. Add note to Action in LCO 3.7.3.1 (Onit 1) LCO 3.7.3 (Onit 2),

Component Cooling Water":

Enter applicable ACTIONS ofLCO 3.4.1.3, Reactor Coolant System -Hot Shutdown," for shutdown cooling loops made inoperable by CCW.

L-2018-049 Enclosure Page 4 of33

5. Add note to Action in LCO 3.7.4.1 (Unit 1) LCO 3.7.4 (Unit 2), "Intake Cooling Water System":

Enter applicable ACTIONS ofLCO 3.4.1.3, "Reactor Coolant System -Hot Shutdown," for shutdown cooling loops made inoperable by ICW.

6. Revise LCO 3.8.1.1, "A.C. Sources - Operating," Action a to include the following:

Within 24hours from discovery ofno offsite power to one train concurrent with inoperability ofredundant required feature(s),

declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

7. Add note to LCO 3.8.1.1, "A.C. Sources - Operating," Action c:

Enter applicable ACTIONS of[LCO 3.8.2.l (Unit 1)j[LC03.8.3.1 (Unit 2)J ."11.C. Distribution - Operating," when ACTION c is entered with no AC power to any train.

8. Revise LCO 3.8.1.1 , "A.C. Sources - Operating," Action d to include the following:

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery oftwo offsite circuits inoperable with inoperability ofredundant required feature(s), declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

9. Add note to Action in LCO 3.8.1.2, "Electrical power Systems -

Shutdown":

Enter the ACTION ofLCO [3.8.2.2, ."11.C. Distribution -

Shutdown," (Unit 1)) [LCO 3.8.3.2, "Onsite Power Distribution -

Shutdown," (Unit 2)} with one required train de-energized as a result ofinoperable offsite circuit.

10. Add note to Action in LCO 3.8.2.1, "A.C. Power Distribution -

Operating" (Unit 1) LCO 3.8.3.1 , Onsite Power Distribution -

Operating" (Unit 2):

Enter applicable ACTIONS of[LCO 3.8.2.3, "D.C. Distribution -

Operating," (Unit 1)} [LCO 3.8.2.1, "D.C. Sources - Operating, "

(Unit 2)} for DC trains made inoperable by inoperable AC distribution system.

d. Add new administrative [fS 6.8.4.r (Unit 1)] [fS 6.8.4.s (Unit 2)], Safety Function D etermination Program (SFDP).

L-2018-049 Enclosure Page 5 of33 2.3.2 Seabrook

a. Revise LCO 3.0.1 and 3.0.2:

3.0.1 Compliance "w'ith the Lln1:i.ting Conditions fer Operation contained in the succccdifl:g specifications is required duriflg the OPERATIONAL MOD ES or other conditions specified thereifl; except that upon failure to meet the Limiting Conditions fer Operation, the associated ACTION requirements shall be met, excep t as provided in Specification 3.0.5. LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements a:re not met within th e specified time inter* als, except as provi.ded in Specification 3.0.5. If th e Limiting Condition for Operation is restored prior to expiration of the specified time iflter

als, completion of th e ACTION requirements is not required. Upon discovery ofa failure to meet an LCO, the ACTIONS shall be met, except as provided in LCO

3. 0.5 and LCO 3. 0. 6. If the LCO is met or is no longer applicable prior to expiration ofthe specified time interval, completion ofthe ACTION(S) is not required unless otherwise stated.

b. Add new LCO 3.0.6:

3. 0. 6 W'hen a supported sy stem LCO is not met solely due to a support system LCO not being met, the ACTIONS associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered.

This is an exception to !,CO 3. 0.2 for the supported sy stem. In this event, an evaluation shall be performed in accordance with Specification 6. 7.6.o, "Safety Function Determination Program (SFDP)." Ifa loss ofsafety fiznction is determined to exist by this program, the appropriate ACTIONS ofthe LCO in which the loss ofsafety fiznction exists are required to be entered.

W'hen a support system's ACTION directs a supported sy stem to be declared inoperable or directs entry into the ACTIONS for a supported system, the applicable ACTIONS shall be entered in accordance with LCO 3.0.2.

c. Add notes and Actions that direct entering th e Actions for supported systems:

1. Add note to LCO 3.4.6.2, "Reactor Coolan t System Leakage," Action c:

Enter applicable ACTIONS for systems made inoperable by an inoperable pressure isolation valve.

L-2018-049 Enclosure Page 6 of 33

2. A dd note to A ctions in LCO 3.6.1.3, "Con tainment Air Locks":

Enter the ACTION ofLC03.6.1.2, "Containment Leakage," when air lock leakage results in exceeding the overall containment leakage rate acceptance criteria .

3. Add notes to A ctions in LCO 3.6.3, "Con tainment Isolation Valves":

1. Enter applicable ACTIONS for systems made inoperable by containment isolation valves.

2. Enter the ACTION ofLCO 3.6.1.2, "Containment Leakage,"

when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria .

4. A dd note to Action in LCO 3.7.3, "Primary Component Cooling Water,":

Enter applicable ACTIONS ofLCO 3.4.1.3, "Reactor Coolant Loops and Coolant Circulation, " for residual heat removal loops made inoperable by PCCW.

5. A dd notes to A ctions in LCO 3.7.4, "Service Water System/Ultimate H eat Sink,":

1. Enter applicable ACTIONS ofLCO 3.8.1.1, "AC Sources -

Operating, " for diesel generator made inoperable by service water.

2. Enter applicable ACTIONS ofLCO 3.4.1.3, "Reactor Coolant Loops and Coolant Circulation, " for residual heat removal loops made inoperable by service water.

6. Revise LCO 3.8.1.1 , 'AC Sources - Operating," Action a to in clude the following:

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery ofno offsite power to one train concurrent with inoperability ofredundant required feature(s),

declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

7. A dd note to LCO 3.8.1.1, 'AC Sources - O p erating," Action c:

Enter applicable ACTIONS ofLCO 3.8.3.1, "Onsite Power Distribution - Operating," when ACTION cis enteredwithnoAC power to any train.

8. Revise LCO 3.8.1.1 , 'AC Sources - Operating," Action e to include the following:

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery oftwo offsite circuits inoperable concurrent with in operability ofredundant required feature(s),

declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

L-201 8-049 Enclosure Page 7 of 33

9. A dd note to Action in LCO 3.8.1.2, "A.C. Sources - Shutdown":

Enter the ACTION ofLCO 3.8.3.2, "Onsite Power Distribution -

Shutdown, " with one required train de-energized as a result of inoperable offsite circuit.

10. A dd n ote to LCO 3.8.3.1, "Onsite Power Distribution - Operating,"

Action a:

Enter applicable ACTIONS ofLCO 3.8.2.1, "DC Sources -

Operating, " for DC trains made inoperable by inoperable power distribution system .

d. A dd new administrative TS 6.7.6.o, Safety Function Determination Program (SFDP).

2.3.3 Turkey Point

a. Revise LCO 3.0.1 and 3.0.2:

3.0.1 Comp!:iaftce with the Llmit+/-flg Coflclit+/-ofls for Operat+/-ofl cofltaiflcd ifl th e succeeding spccificat+/-ofls is rcqoocd duriftg the O PE R.ATION}.tL MODES or other coflclit+/-ofls specified thcreifl, except that upofl failtlt'c to m eet the Llmit+/-flg Coflclit+/-ofls for Opcrat+/-ofl, the associated ACTION rcquircm Cflts shaH be met, except as pro vided ifl Specification 3.0.6. LCOs shall be met during the MODES or other speci.ied conditions in the Applicability, except as provided in LCO 3.0.2 3.0.2 Noflcompliaflce with a sp ecificat+/-ofl shaH exist whcfl the reqoocmeflts of the Llmi.t+/-flg Coflclit+/-ofl for O perat+/-ofl and associated ACTION rcqooemcnts arc flot met wtthifl the specified time ifltel'\i als, except as provided ifl Spccificat+/-oft 3.0.6. If the Llmi.t+/-flg Coftdit+/-ofl for Opcrat+/-ofl is restored prior to expirat+/-oft of the specified time intervals, complet+/-ofl of the ACTION reqooemCflts is ftot required. Upon discovery ofa failure to meet an LCO, the ACTIONS shall be met, ex cept as provided in LCO 3.0.6 and LCO 3.0. 7. If the LCO i s met or is no longer applicable prior to expiration ofthe speci.ied time interval, completion ofthe ACTION(S) is not required unless otherwise stated.

b. A dd new LCO 3.0.7:

3.0. 7 When a supported system LCO is not met solely due to a support system LCO not being met, the ACTIONS associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered.

This is an exception to LCO 3.0.2 for the supported sy stem. In this event, an evaluation shall be performed in accordance with Speci.ication 6.8.4.n, "Safety Function Determination Program (SFDP)." Ifa loss ofsafety function is determined to exist by this program, the appropriate ACTIONS ofthe LCO in which the loss ofsafety function exists are required to be entered.

L-2018-049 Enclosure Page 8 of 33 When a support system's ACTION directs a supported system to be declared inoperable or directs entry into the ACTIONS for a supported system, the applicable ACTIONS shall be entered in accordance with LCO 3.0.2.

c. A dd notes and Actions that direct entering the Actions for supported systems:

1. Add note to LCO 3.4.6.2, "Reactor Coolant System Leakage," Action d:

Enter applicable ACTIONS for systems made inoperable by an inoperable pressure isolation valve.

2. Add note to Actions in LCO 3.6.1.3, "Containment Air Locks":

Enter the ACTION ofLCO 3.6.1.2, "Containment Leakage," when air lock leakage results in exceeding the overall containment leakage rate.

3. Add notes to Actions in LCO 3.6.4, "Containment Isolation Valves":

1. Enter applicable ACTIONS for systems made inoperable by containment isolation valves.

2. Enter the ACTION ofLCO 3.6.1.2, "Containment Leakage,"

when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria .

Delete the footnote:

CAUTION. The inoperable isolation valve(s) may be part of a system(s). Isolating the affeeted penetntion(s) may affeet the use of the system(s) . Consider the teehaieal speeifieation requ:i:rements on the affeeted sy stem(s) and aet aeeord:in.gly .

4. Add note to Actions in LCO 3.7.2, "Component Cooling Water System,":

Enter applicable ACTIONS ofLCO 3.4.1.3, "Reactor Coolant System -Hot Shutdown," for residual heat removal loops made inoperable by CCW.

5. Add note to A ctions in LCO 3.7.3, "Intake Cooling Water System":

Enter applicable ACTIONS ofLCO 3.4.1.3, "Reactor Coolant System -Hot Shutdown," for residual heat removal loops made inoperable by ICW.

6. Revise LCO 3.8.1.1, 'AC Sources - Operating," Action a to include the following:

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery ofno offsite power to one train concurrent with inoperability ofredundant required feature(s),

declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

L-2018-049 Enclosure Page 9 of 33

7. A dd note to LCO 3.8.1.1, 'AC Sources - Operating," Action c:

Enter applicable ACTIONS ofLCO 3. 8.3.1, "On site Power Distribution - Operating," when ACTION c is entered with no AC power to any train.

8. Revise LCO 3.8.1 .1, 'AC Sources - Operating," Action e to include the following:

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery oftwo offsite circuits inoperable concurrent with in operability ofredundant required feature(s),

declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

9. A dd note to Action in LCO 3.8.1.2, "A.C. Sources - Shutdown":

Enter the ACTION ofLCO 3.8.3.2, "Onsite Power Distribution -

Shutdown," with one required train de-energized as a result of inoperable offsite circuit.

10. Add note to LCO 3.8.3.1, "Onsite Power Distribution - Operating,"

A ction a:

Enter applicable ACTIONS ofLCO 3.8.2.1, "DC Sources -

Operating," for DC trains made inoperable by inoperable power distribution system.

d. A dd new administrative TS 6.8.4.n, Safety Function D etermination Program (SFDP) .

2.3.4 Safety Function Determination Program (SFDP)

The proposed change adds a new Safety Function Determination Program to the administrative section of the St. Lucie, Seabrook, and Turkey Point TS:

Safety Function Determination Program (SFDP)

This program ensures loss ofsafety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6 [3.0. 7 for Turkey Point], an evaluation shall be made to determine ifloss of safety function exists. Additionally, other appropriate actions may be taken as a result ofthe support system in operability and corresponding exception to entering supported system ACTIONS.

This program implements the requirements ofSpecification

[3. 0. 6.J[3. 0. 7]. The SFDP shall contain the following:

a. Provisions for cross train checks to ensure a loss ofthe capability to perform the safety mnction assumed in the accident analysis does not go undetected,

b. Provisions for ensuring the plant is maintained in a safe condition ifa loss offunction condition exists,

L-201 8-049 Enclosure Page 10 of 33

c. Provisions to ensure that an inoperable supported system's allowed outage time is not inappropriately extended as a result ofmultiple support system inoperabilities, and

d. Other appropriate limitations and remedial or compensatory actions.

A loss ofsafety function exists when, assuming no concurrent single failure, no concurrent loss ofoffsite power, or no concurrent loss of onsite dieselgenerator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose ofthis program, a loss ofsafety function may exist when a support system is inoperable, and:

a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable, or

b. A required system redundant to the system(s) in turn supported by the inoperable supported sy stem is also inoperable, or

c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identi.ies where a loss ofsafety function exists. Ifa loss of safety function is determined to exist by this program, the appropriate ACTIONS ofthe LCO in which the loss ofsafety function exists are required to be entered. When a loss ofsafety function is caused by the in operability ofa single Technical Speci.ication support sy stem, the appropriate ACTIONS to enter are those ofthe support sy stem .

3.0 TECHNICAL EVALUATION

3.1 Change to LCO 3.0.1 and LCO 3.0.2 (Seabrook and Turkey Point)

LCO 3.0.1 in the current TS for Seabrook and Turkey Point requires (1) compliance with the LCOs when in the Applicability of the TS, and (2) meeting th e Action requirements upon a failure to meet the LCO. LCO 3.0.2 discusses that when the requiremen ts of an LCO and the associated Action requirements are not met within the specified time intervals, noncompliance with the TS exists; and completion of Actions is no t required if an LCO is met prior to expiration of th e sp ecified time interval. Incorporating ISTS LCO 3.0.6 into the current TS would be an excep tion to LCO 3.0. 1 and 3.0.2. However, in the ISTS, LCO 3.0.6 is only an exception to LCO 3.0.2. This dissimilarity is the result of differences between LCO 3.0.1 and 3.0.2 in the ISTS and the Seabrook and T urkey Point TS.

NextEra and FPL propose to revise LCO 3.0.1 and 3.0.2 for Seabrook and Turkey P oint to be consistent with the ISTS. The revision to LCO 3.0.1 incorporates the first premise in current LCO 3.0.1 that compliance with the LCOs is required when in the Applicability of the TS. The change to LCO 3.0.2 incorporates the second

L-2018-049 Enclosure Page 11 of33 provision of current LCO 3.0.1 regarding the requirement to meet Actions and retains the current provision that completion of Actions is not required if compliance with the LCO is restored. In addition, the proposed change to LCO 3.0.2 includes the exceptions provided by LCO 3.0.5 and LCO 3.0.6 for Seabrook, and LCO 3.0.6 and 3.0.7 for Turkey Point.

Proposed LCO 3.0.6 to the Seabrook TS and proposed LCO 3.0.7 to the Turkey Point TS are exceptions to LCO 3.0.2, which must be modified to reflect the new LCO as exceptions. The change to LCO 3.0.2 is necessary to allow applying the exceptions provided by LCO 3.0.6 and 3.0.7. The change to revise the wording of LCO 3.0.1 and 3.0.2 to align with the wording in the ISTS is administrative in nature and does not by itself change any technical requirements or alter the TS rules of usage.

3.2 Change to LCO 3.0.2 (St. Lucie)

Proposed new LCO 3.0.6 is an exception to LCO 3.0.2; therefore, LCO 3.0.2 is modified to reference LCO 3.0.6 as an exception. The change to LCO 3.0.2 is necessary in order to apply the exception allowed by LCO 3.0.6. In addition, an editorial change to LCO 3.0.2 removes references to " Required" ACTIONS and "associated conditions." The standard TS (NUREG-1432) use the terms "Condition" and "Required Actions." However, the St. Lucie TS, which are not based on NUREG-1432, do not use these terms and only refer to the term "Action."

This editorial revision does not change the technical requirements of LCO 3.0.2.

3.3 Addition ofLCO 3.0.6 (St. Lucie and Seabrook) and LCO 3.0.7 (Turkey Point)

The proposed change incorporates ISTS LCO 3.0.6 into the St. Lucie and Seabrook TS as new LCO 3.0.6 and into the Turkey Point TS as new LCO 3.0.7.

LCO 3.0.6 and 3.0.7 establish an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the TS. The exception to LCO 3.0.2 is provided because LCO 3.0.2 would require that the Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system LCO's Actions. These Actions may include entering the supported system's Actions or may specify other Actions to be entered. The exception to LCO 3.0.2 is provided because otherwise, applying LCO 3.0.6 and LCO 3.0.7 would result in noncompliance with LCO 3.0.2.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Actions unless directed to do so by the support system's Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems LCOs'

L-2018-049 Enclosw:e Page 12 of 33 Actions are eliminated by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Actions.

However, there are instances where a support system's Action may either direct a supported system to be declared inoperable or direct en try into Actions for the supported system. This may occur immediately or after some specified delay to perform some other Action. Regardless of whether it is immediate or after some delay, when a support system's Action directs a supported system to be declared inoperable or directs entry into Actions for a supported system, the applicable Actions are entered in accordance with LCO 3.0.2.

The proposed new administrative TS, "Safety Function Determination Program (SFDP)," ensures that a loss of safety function is detected and that appropriate actions are taken. Upon entry into LCO 3.0.6 or 3.0.7, an evaluation is performed to determine if a loss of safety function exists. Additionally, other appropriate actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Actions. The SFDP implements the requirements of LCO 3.0.6 and 3.0.7 as discussed below.

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s),

a safety function assumed in the accident analysis cannot be performed. If an evaluation determines that a loss of safety function exists, the appropriate Actions of the LCO in which the loss of safety function exists are required to be entered.

When a loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Actions of the LCO in which the loss of safety function exists, consideration is given to the specific type of function affected. Where a loss of function is solely due to a single TS support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level),

the appropriate LCO is the LCO for the support system. The Actions for a support system LCO adequately address the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.

The proposed addition of LCO 3.0.6 to the St. Lucie and Seabrook TS and LCO 3.0.7 to the Turkey Point TS would eliminate potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO conditions and required actions by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's required actions. The proposed change is consistent with LCO 3.0.6 in the ISTS. Based on these considerations, FPL and NextEra conclude that the proposed change is acceptable.

3.4 New Notes that Direct Entering Actions of Supported Systems Proposed LCO 3.0.6 and 3.0.7 require entering the Actions of the LCOs for supported systems when directed by a support systems' Actions, and the ISTS Bases for LCO 3.0.6 discuss that there are instances where a support system's Action may

L-2018-049 Enclosure Page 13 of33 either direct a supported system to be declared inoperable or direct entry into the Actions for the supported system. As a result, this proposed change adds notes that modify various support system Actions to direct entering the Actions of supported systems or other TS systems affected by the inoperable support system or component. The proposed notes are consistent with those included in the ISTS that are applicable to St. Lucie, Seabrook, and Turkey Point. Attachment 3 provides tables that identify the notes in the ISTS that direct entering the Actions of supported or affected systems and shows how the applicable notes are addressed in this proposed change.

The proposed notes and their bases are discussed below.

a. A note modifies LCO 3.4.6.2, "Reactor Coolant System Leakage," to direct entering the applicable Actions for systems made inoperable by an inoperable pressure isolation valve (PIV). This note requires an evaluation of affected systems if a PIV is inoperable. The leakage may have affected system operability, or isolation of a leaking flow path with an alternate valve may have degraded the ability of the interconnected system to perform its safety function.

For St. Lucie Unit 1, the parenthetical information in TS 3.4.6.2 Action c "Note, however, that this may lead to ACTION requirements for systems involved" is deleted. The new note replaces this informational note with specific direction to enter the applicable Actions for affected systems.

b. A note modifies LCO 3.6.1.3, "Containment Air Locks," to direct entering the Action of LCO 3.6.1.2, "Containment Leakage," when air lock leakage results in exceeding the overall containment leakage rate acceptance criteria.

c. The Actions in LCO 3.6.3 (3 .6.3.1 for St. Lucie Unit 1, 3.6.4 for Turkey Point),

"Containment Isolation Valves," are modified by two notes. The first note requires entering the Actions for systems made inoperable as a result of inoperable containment isolation valves to ensure that appropriate remedial actions are taken. The second note directs entering the Action of LCO 3.6.1.2, "Containment Leakage," when isolation leakage results in exceeding the overall containment leakage rate acceptance criteria. For Turkey Point, the first note replaces the footnote in TS 3.6.4, which is deleted.

d. For St. Lucie, the Action in LCO 3.7.3.1 (Unit 1) LCO 3.7.3 (Unit 2),"

Component Cooling Water," is modified by a note that directs entering the applicable Actions of LCO 3.4.1.3, "Reactor Coolant System - Hot Shutdown,"

for shutdown cooling loops made inoperable by CCW. This is an exception to LCO 3.0.6 that ensures the proper actions are taken for this condition.

e. For Seabrook, the Action in LCO 3.7.3, "Primary Component Cooling Water," is modified by a note that directs entering the Action of LCO 3.4.1.3, "Reactor Coolant Loops and Coolant Circulation," for residual heat removal loops made inoperable by primary component cooling water. This is an exception to LCO 3.0.6 that ensures the proper actions are taken for this condition.

f. For Turkey Point, the Action in LCO 3.7.2, "Component Cooling Water System," is modified by a note that directs entering the Action of LCO 3.4.1.3,

L-2018-049 Enclosure Page 14 of 33 "Reactor Coolant System - Hot Shutdown," for residual heat removal loops made inoperable by CCW. This is an exception to LCO 3.0.7 that ensures the proper actions are taken for this condition.

g. For St. Lucie, the Action in LCO 3.7.4.1 (Unit 1) LCO 3.7.4 (Unit 2), "Intake Cooling Water System," is modified by a note that directs entering the applicable Actions ofLCO 3.4.1.3, "Reactor Coolant System -Hot Shutdown," for shutdown cooling loops made inoperable by ICW. This is an exception to LCO 3.0.6 that ensures the proper actions are taken for this condition.

h. For Seabrook, two notes modify the Actions in LCO 3.7.4, "Service Water/Ultimate Heat Sink." The first requires entering the applicable Action of LCO 3.8.1.1, "AC Sources - Operating," for a diesel generator (DG) made inoperable by service water. The second note directs entering the Action of LCO 3.4.1.3, "Reactor Coolant Loops and Coolant Circulation," for a residual heat removal loop made inoperable by service water. These notes are an exception to LCO 3.0.6 and ensure that the appropriate actions are taken for the supported systems rendered inoperable by service water.

1. For Turkey Point, the Action in LCO 3.7.3, "Intake Cooling Water System," is modified by a note that directs entering the applicable Actions of LCO 3.4.1. 3, "Reactor Coolant System - Hot Shutdown," for shutdown residual heat removal loops made inoperable by ICW. This is an exception to LCO 3.0.7 that ensures the proper actions are taken for this condition.

J* A note modifies Action c in LCO 3.8.1.1, "AC Sources - Operating," to require entering the applicable Actions of the LCO for ["Onsite Power Distribution -

Operating" (Seabrook and Turkey Point)] ["A.C. Distribution-Operating" (St.

Lucie)] when Action c (one offsite circuit and one DG inoperable) is entered with no AC power to any train. Pursuant to LCO 3.0.6 and 3.0.7, the Actions of LCO 3.8.3.1 would not be entered even if all AC sources to the distribution system were inoperable, resulting in de-energization. Therefore, Action c is modified by a Note to indicate that when the Action is entered with no AC source to any train, the Actions for LCO 3.8.3.1, Onsite Power Distribution -

Operating," must be entered. This allows Action c to provide requirements for the loss of one offsite circuit and one DG without regard to whether a train is de-energized while LCO 3.8.3.1 provides the appropriate restrictions for a de-energized train.

k. For St. Lucie, a note modifies the Action in LCO 3.8.1.2, "Electrical Power Systems - Shutdown," that directs entering the Action of LCO 3.8.2.2, "A.C.

Distribution - Shutdown" (Unit 1) LCO 3.8.2.2, "Onsite Power Distribution -

Shutdown" (Unit 2), with one required train de-energized as a result of an inoperable offsite circuit. Pursuant to LCO 3.0.6, the Action of LCO 3.8.2.2 is not entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Action of LCO 3.8.1.2 is modified by a note to indicate that when this Action is entered with no AC power to any required engineered safety features (ESF) bus, the Action for LCO 3.8.2.2 must be entered. This note allows the Action in LCO 3.8.1.2 to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.2.2

L-2018-049 Enclosure Page 15 of 33 provides the appropriate restrictions for the situation involving a de-energized train.

1. For Seabrook and Turkey Point, a note modifies the Action in LCO 3.8.1.2, "A.C. Sources - Shutdown," that directs entering the Action of LCO 3.8.3.2, "Onsite Power Distribution - Shutdown," with one required train de-energized as a result of an inoperable offsite circuit. Pursuant to proposed LCO 3.0.6 and 3.0.7, the Action ofLCO 3.8.3.2 would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Action of LCO 3.8.1.2 is modified by a note to indicate that when the Action is entered with no AC power to any required ESF bus, the Action of LCO 3.8.3.2 must be entered.

This note allows LCO 3.8.1.2 to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.3.2 would provide the appropriate restrictions for the situation involving a de-energized train.

m. For St. Lucie, a note modifies the Action in LCO 3.8.2.1, "A.C. Power Distribution - Operating" (Unit 1) LCO 3.8.3.1, "Onsite Power Distribution -

Operating," (Unit 2) that directs entering the applicable Actions of LCO 3.8.2.3, "D.C. Distribution - Operating" (Unit 1) LCO 3.8.2.1, "D.C. Sources -

Operating," for DC trains made inoperable by inoperable AC distribution system. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

n. For Seabrook and Turkey Point, a note modifies Action a in LCO 3.8.3.1, "Onsite Power Distribution - Operating," to direct entering the applicable Actions of LCO 3.8.2.1, "DC Sources - Operating," for DC trains made inoperable by inoperable AC power distribution system. This is an exception to LCO 3.0.6 and 3.0.7 and ensures the proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to batteries and eventual loss of DC power. This note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution systems.

3.5 Changes to Actions in LCO 3.8.1.1, "AC Sources - Operating" Supported systems are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source because, based on the TS definition, operability requires either normal or emergency electrical power. Proposed LCO 3.0.6 and 3.0.7 rely on the Actions for inoperable AC sources and inoperable DGs to provide the necessary restriction for cross-train inoperabilities. Required Actions A.2, B.2, and C.1 in ISTS LCO 3.8.1, "AC Sources - Operating," address cross-train inoperabilities for the conditions that an offsite circuit is inoperable, a DG is inoperable, or both offsite circuits are inoperable, respectively. The current TS address cross-train inoperability only for the condition that a DG is inoperable.

Consequently, this change revises TS 3.8.1.1 Actions a and d for inoperable offsite circuits to address cross train inoperability consistent with the ISTS.

L-2018-049 Enclosure Page 16 of33 3.5.1 Changes to LCO 3.8.1.1 - St. Lucie Units 1 and 2

a. Below is current LCO 3.8.1.1, Action a:

With one offsite circuit of 3.8.1.1.a inoperable, except as provided in Action f. below, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

FPL proposes to revise Action a to the following:

1. Demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery ofno offsite power to one train concurrent with inoperability of redundant required feature(s)

3. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

4. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

This Action addresses the condition that one of the two required offsite circuits is inoperable. The proposed change reformats the Action and adds a requirement in item 2 to declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). The proposed Action applies when one train has no offsite power supplying its loads, and a required feature on the other train is inoperable. The completion time for this Action starts upon discovery that a train has no offsite power supplying its loads and a redundant required feature subsequently becomes inoperable.

Ac tion a.2 provides assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features. These features are powered from the redundant AC electrical power train. The 24-hour completion time is intended to allow the operator time to evaluate and repair any discovered inoperabilities and considers the capacity and capability of the remaining AC sources and the low probability of a design basis accident occurring during this period.

L-2018-049 Enclosuxe Page 17 of33 The St. Lucie auxiliary feedwater (AFW) system consists of one steam driven pump with greater than full flow capacity and two full flow capacity motor driven auxiliary feedwater pumps. Each motor-driven pump supplies feedwater to one steam generator, and the turbine-driven pump supplies feedwater to both steam generators. The turbine driven AFW pump is considered a redundant required feature because the design is such that the remaining operable motor driven AFW pumps are not by themselves capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

b. Below is current LCO 3.8.1.1 Action b:

With one diesel generator of 3.8.1.1.b inoperable, demonstrate the OPERABILITY of the A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable EDG does not exist on the remaining EDG*; restore the diesel generator to OPERABLE status within 14 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN. Additionally, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from the discovery of concurrent inoperability of required redundant feature(s) (including the steam driven auxiliary feed pump in MODE 1, 2, and 3), declare required feature(s) supported by the inoperable EDG inoperable if its redundant required feature(s) is inoperable.

FPL proposes to revise Action b as shown below:

1. Demonstrate the OPERABILITY of the A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. Additionally, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from the discovery of concurrent inoperability of required redundant feature(s) (including the steam driven auxiliary feed pump in MODE 1, 2, and 3), declare required feature(s) supported by the inoperable EDG inoperable if its redundant required feature(s) is inoperable.

L-2018-049 Enclosure Page 18 of 33

3. If the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable EDG does not exist on the remaining EDG*.

4. Restore the diesel generator to OPERABLE status within 14 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

5. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

c. Below is current LCO 3.8.1.1 Action c:

With one offsite A.C. circuit and one diesel generator inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.l.l.l.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable EDG does not exist on the remaining EDG*. Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN. Restore the other A.C. power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the provisions of Section 3.8.1.1 ACTION Statement a orb, as appropriate, with the time requirement of that ACTION Statement based on the time of the initial loss of the remaining inoperable A.C. power source. Additionally, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from the discovery of concurrent inoperability of required redundant feature(s)

(including the steam driven auxiliary feed pump in MODE 1, 2, and 3),

declare required feature(s) supported by the inoperable EDG inoperable if its redundant required feature(s) is inoperable.

L-2018-049 Enclosure Page 19 of33 FPL proposes to revise Action c as shown below:

]\[OTE-------------------------------------

[Enterapplicable ACTIO]\[s oELCOJ.8.2~ AC. Distribution

- Opera ting, 11 when ACTIQ]\[ c is entered with no AC power to any train.] (Unit 1)

[EnterapplicableACTIO]\[s oELCOJ.8.3.1, A.C. Distribution -

Operating, 11 when ACTIQ]\[ c is entered with no AC power to any train.] (Unit 2)

c. With one offsite A.C. circuit and one diesel generator inoperable:

1. Demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. Additionally, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from the discovery of concurrent inoperability of required redundant feature(s) (including the steam driven auxiliary feed pump in MODE 1, 2, and 3),

declare required feature(s) supported by the inoperable EDG inoperable if its redundant required feature(s) is inoperable.

3. If the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months unless it can be confirmed that the cause of the inoperable EDG does not exist on the remaining EDG*.

4. Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

5. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

6. Restore the other A.C. power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the provisions of Section 3.8.1.1 ACTION Statement a orb, as appropriate, with the time requirement of that ACTION Statement based on the time of the initial loss of the remaining inoperable A.C.

power source.

L-2018-049 Enclosure Page 20 of33 T he proposed change adds a note that modifies Action c to require entering the applicable Actions of the LCO for "A.C. Distribution -

Operating," when Action c is entered with no AC power to any train.

This allows Action c to provide requirements for the loss of one offsite circuit and one DG without regard to whether a train is de-energized.

The Actions in LCO 3.8.2.1 (Unit 1) and 3.8.3.1 (Unit 2), "A.C.

Distribution - Operating," provide the restrictions for a de-energized train.

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

d. Below is current LCO Action d:

With two of the required offsite A.C. circuits inoperable, restore one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Following restoration of one offsite source, follow ACTION Statement a. with the time requirement of that ACTION Statement based on the time of the initial loss of the remaining inoperable offsite A.C. circuit.

FPL proposes to revise Action d as shown below:

d. With two of the required offsite A.C. circuits inoperable:

1. Declare required frature(s) inoperable when its redundant required fra ture(s) is inopera hie within 12hours from discovery oftwo o.isite circuits inoperable concurrent with inoperability ofredundant required frature(s) .

2. Restore one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

3. Following restoration of one offsite source, follow ACTION Statement a. with the time requirement of that ACTION Statement based on the time of the initial loss of the remaining inoperable offsite A.C. circuit.

This Action applies when both of the required offsite circuits are inoperable. The proposed change reformats the Action and adds a requirement in item 1 to declare required feature(s) inoperable when its redundant required feature(s) is inoperable within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery two offsite circuits inoperable concurrent with inoperability of redundant required feature(s). Action d.1 is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. T hese features are powered from redundant AC safety trains. This includes motor driven

L-2018-049 Enclosure Page 21 of 33 auxiliary feedwater pumps. Single train features, such as turbine driven auxiliary pumps, are not included. The completion time for Action d.1 would start upon discovery that both offsite circuits are inoperable and a required feature is discovered inoperable.

With two offsite circuits inoperable, the completion time for inoperable redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power. The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 allows a completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are operable. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. The completion time is intended to allow the operator time to evaluate and repair any discovered inoperabilities.

3.5.2 Changes to LCO 3.8.1.1 - Seabrook

a. Below is current LCO 3.8.1.1 Action a:

With an offsite circuit of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. source by performing Specification 4.8.1.1.la. within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

NextEra proposes to revise Action a as shown below:

a. With an offsite circuit of the above required A.C. electrical power sources inoperable:

1. Perform Surveillance Requirement 4.8.1.1.la for the OPERABLE offsite circuit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter;

2. Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable within 24hours from discovery ofno offsite power to one train concurrent with in operability ofredundant required feature(s); and

3. Restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

This Action addresses the condition that one of the two required offsite circuits is inoperable. The proposed change reformats the Action and adds a requirement to declare required feature(s) with no offsite power

L-2018-049 Enclosure Page 22 of33 available inoperable when its redundant required feature(s) is inoperable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). Proposed Action a.2 applies when one train has no offsite power supplying its loads, and a required feature on the other train is inoperable. The completion time for this Action a.2 would start upon discovery that a train has no offsite power supplying its loads and a redundant required feature subsequently becomes inoperable.

Action a.2 provides assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features. These features are powered from the redundant AC electrical power train. Since the emergency feedwater (EFW) system incudes only one motor-driven pump, the turbine-driven EFW pump is considered a required redundant feature. The 24-hour completion time is intended to allow the operator time to evaluate and repair any discovered inoperabilities and considers the capacity and capability of the remaining AC sources and the low probability of a design basis accident occurring during this period.

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

b. Below is current LCO 3.8.1.1 Action e:

e. With two of the above required offsite A .C. circuits inoperable; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With only one offsite source restored, restore at least two offsite circuits to OPERABLE status within 72 h ours from time of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

NextEra proposes to revise Action e as shown below:

e. With two of the above required offsite A.C. circuits inoperable

1. Declare required feature(s) inoperable when its redundant required feature(s) is inoperable within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery oftwo offsite circuits inoperable concunent with inoperability ofredundant required feature(s);

2. Restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

L-2018-049 Enclosure Page 23 of33

3. With only one offsite source restored, restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from time of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

This Action applies when both of the required offsite circuits are inoperable. The proposed change reformats the Action and adds a requirement to declare required feature(s) inoperable when its redundant required feature(s) is inoperable within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery two offsite circuits inoperable concurrent with inoperability of redundant required feature(s). These features are powered from redundant AC safety trains. Single train features, such as turbine driven auxiliary pumps, are not included in the list.. The completion time for this Action would start at any time that both offsite circuits are inoperable and a required feature is discovered inoperable.

With two offsite circuits inoperable, the completion time for inoperable redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power. The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 allows a completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are operable. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. The completion time is intended to allow the operator time to evaluate and repair any discovered inoperabilities.

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

3.5.3 Changes to LCO 3.8.1.1 -Turkey Point

a. Below is current LCO 3.8.1.1 Action a:

a. With one of two startup transformers or an associated circuit inoperable, demonstrate the OPERABILITY of the other startup transformer and its associated circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. If the inoperable startup transformer is the associated startup transformer and became inoperable while the unit is in MODE 1, reduce THERMAL POWER to <30% RATED THERMAL POWER within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or restore the inoperable startup transformer and associated circuits to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT STA DBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If THERMAL POWER is reduced to <30% RATED THERMAL POWER within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or if the inoperable startup

L-2018-049 Enclosure Page 24 of33 transformer is associated with the opposite unit restore the startup transformer and its associated circuits to OPERABLE status within 30 days of the loss of OPERABILITY, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If the inoperable startup transformer is the associated startup transformer and became inoperable while the unit was in MODE 2, 3, or 4 restore the startup transformer and its associated circuits to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . This ACTION applies to both units simultaneously.

FPL proposes to revise Action a as shown below:

a. With one of two startup transformers or an associated circuit inoperable:

1. Demonstrate the OPERABILITY of the other startup transformer and its associated circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. Declare required feature(s) with no of/site power available inoperable when its redundant required feature(s) is inoperable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery ofno of/site power to one train concurrent with inoperability of redundant required feature(s).

3. If the inoperable startup transformer is the associated startup transformer and became inoperable while the unit is in MODE 1:

a) Reduce THERMAL POWER to ~30% RATED THERMAL POWER within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or b) Restore the inoperable startup transformer and associated circuits to OPERABLE status within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

4. If THERMAL POWER is reduced to <30% RATED THERMAL POWER within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or if the inoperable startup transformer is associated with the opposite unit, restore the startup transformer and its associated circuits to OPERABLE status within 30 days of the loss of OPERABILITY, or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

5. If the inoperable startup transformer is the associated startup transformer and became inoperable while the unit was in MODE 2, 3, or 4 restore the startup transformer and its associated

L-2018-049 Enclosure Page 25 of 33 circuits to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . This ACTION applies to both units simultaneously.

This Action addresses the condition that one of the two required offsite circuits is inoperable. The proposed change reformats the Action and adds a requirement to declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). Proposed Action a.2 applies when one train has no offsite power supplying its loads, and a required feature on the other train is inoperable. The completion time for this Action a.2 would start upon discovery that a train has no offsite power supplying its loads and a redundant required feature subsequently becomes inoperable.

Action a.2 provides assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features. These features are powered from the redundant AC electrical power train. The 24-hour completion time is intended to allow the operator time to evaluate and repair any discovered inoperabilities and considers the capacity and capability of the remaining AC sources and the low probability of a design basis accident occurring during this period.

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

b . Below is current LCO 3.8.1.1 Action b:

b. With one of the required diesel generators inoperable, demonstrate the OPERABILITY of the above required startup transformers and their associated circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining required diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unless the absence of any potential common mode failure for the remaining diesel generators is determined. If testing of remaining required diesel generators is required, this testing must be performed regardless of when the inoperable diesel generator is restored to OPERABILITY. Restore the inoperable diesel generator to OPERABLE status within 14 days** or be in at least HOT

L-2018-049 Enclosure Page 26 of 33 STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

FPL proposes to revise Action b as shown below:

b. With one of the required diesel generators inoperable:

1. Demonstrate the OPERABILITY of the above required startup transformers and their associated circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining required diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unless the absence of any potential common mode failure for the remaining diesel generators is determined. If testing of remaining required diesel generators is required, this testing must be performed regardless of when the inoperable diesel generator is restored to OPERABILITY.

3. Restore the inoperable diesel generator to OPERABLE status within 14 days** or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

c. Below is current LCO 3.8.1.1 Action c:

c. With one startup transformer and one of the required diesel generators inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a on the remaining startup transformer and associated circuits within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and if the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing, demonstrate the OPERABILITY of the remaining required diesel generators by performing Surveillance Requirement 4.8.1.1.2a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable diesel generator does not exist on the remaining required diesel generators, unless the diesel generators are already operating; restore one of the inoperable sources to OPERABLE status in accordance with Action

L-2018-049 Enclosure Page 27 of 33 Statements a and b, as appropriate. If testing of remaining required diesel generators is required, this testing must be performed regardless of when the inoperable diesel generator is restored to OPERABILITY. Notify the NRC within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of declaring both a start-up transformer and diesel generator inoperable. Restore the other A.C. power source (startup transformer or diesel generator) to OPERABLE status in accordance with the provisions of Section 3.8.1.1 Action Statement a orb, as appropriate, with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable A.C. power source.

FPL proposes to revise Action c as shown below:

1'!0TE--------------------------------------

Enter applicable ACTI01'!S ofLCO 3.8.3.1, "Onsite Power Distribution - Operating," when ACTI01'! c is entere_d with no AC power source to any train.

c. With one startup transformer and one of the required diesel generators inoperable:

1. Notify the N RC within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of declaring both a start-up transformer and diesel generator inoperable.

2. If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventive maintenance or testing, demonstrate the OPERABILITY of the remaining required diesel generators by p erforming Surveillance Requirement 4.8.1.1.2a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable diesel generator does not exist on the remaining required diesel generators, unless the diesel generators are already operating. If testing of remaining required diesel generators is required, this testing must be performed regardless of when the inoperable diesel generator is restored to OPERABILITY.

3. Restore one of the inoperable sources to OPERABLE status in accordance with Action Statements a and b, as appropriate.

4. Restore the other A.C. power source (startup transformer or diesel generator) to OPERABLE status in accordance with the provisions of Section 3.8.1.1 Action Statement a or b, as appropriate, with the time requirement of that Action Statement based on the time of initial loss of the remaining inoperable A.C. power source.

L-2018-049 Enclosure Page 28 of 33 The proposed change adds a note that modifies Action c to require entering the applicable Actions of the 3.8.3.1, "Onsite Power Distribution - Operating," when ACTION c is entered with no AC power source to any train. This allows Action c to provide requirements for the loss of one offsite circuit and one DG without regard to whether a train is de-energized. The Actions in LCO 3.8.3.1 "Onsite Power Distribution - Operating," provide the restrictions for a de-energized train.

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

d. Below is current LCO 3.8.1.1 Action e:

With two of the above required startup transformers or their associated circuits inoperable notify the NRC within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; restore at least one of the inoperable startup transformers to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s* and in COLD With only one startup transformer and associated circuits restored, perform Surveillance Requirement 4.8.1.1.la on the OPERABLE Startup transformer at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and restore the other startup transformer and its associated circuits to OPERABLE status or shutdown in accordance with the provisions of Action Statement 3.8.1.l a with time requirements of that Action Statement based on the time of initial loss of a startup transformer. This ACTION applies to both units simultaneously.

FPL proposes to revise Action c as shown below:

e. With two of the above required startup transformers or their associated circuits inoperable:

1. Notify the NRC within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

2. Declare required feature(s) inoperable when its redundant required feature(s) is inoperable within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery oftwo offsite circuits inoperable concurrent with inoperability ofredundant required feature(s)

3. Restore at least on e of the inoperable startup transformers to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s* and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . This ACTION applies to both units simultaneously.

L-2018-049 Enclosure Page 29 of 33

4. With only one startup transformer and associated circuits restored, perform Surveillance Requirement 4.8.1.1.1 a on the OPERABLE Startup transformer at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and restore the other startup transformer and its associated circuits to OPERABLE status or shutdown in accordance with the provisions of Action Statement 3.8.1.1a with time requirements of that Action Statement based on the time of initial loss of a startup transformer. This ACTION applies to both units simultaneously.

This Action applies when both of the required startup transformers or their associated circuits are inoperable. The proposed change reformats the Action and adds a requirement to declare required feature(s) inoperable when its redundant required feature(s) is inoperable within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery two offsite circuits inoperable concurrent with inoperability of redundant required feature(s). These features are powered from redundant AC safety trains. The completion time for this Action would start at any time that both offsite circuits are inoperable and a required feature is discovered inoperable.

With two offsite circuits inoperable, the completion time for inoperable redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power. The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 allows a completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are operable. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. The completion time is intended to allow the operator time to evaluate and repair any discovered inoperabilities.

The change to reformat the Action from a narrative paragraph to a list of discrete steps is administrative in nature and does not alter the technical requirements of the Action. This change enhances the presentation and clarity of the Action for the benefit of the TS user.

3.6 Safety Function Determination Program While LCO 3.0.6 (3.0.7 for Turkey Point) allows not entering the Actions for supported systems that are inoperable solely due to a support system LCO not being met, it also requires an evaluation in accordance with the Safety Function Determination Program (SFDP) to determine if a loss of safety function exists.

Accordingly, this change proposes to add a SFDP to the administrative section of the TS.

This program ensures that a loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6 or 3.0.7, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate actions may be taken as a result of the support system inoperability and

L-2018-049 Enclosure Page 30 of33 corresponding exception to entering supported system ACTIONs. This program implements the requirements of Specification 3.0.6 and 3.0.7 and contains the following:

a. Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected,

b. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists,

c. Provisions to ensure that an inoperable supported system's completion time is not inappropriately extended as a result of multiple support system inoperabilities, and

d. Other appropriate limitations and remedial or compensatory actions.

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable, or

b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable, or

c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single TS support system, the appropriate ACTIONs to enter are those of the support system.

The proposed SFDP is consistent with the SFDP in ISTS Specification 5.15, "Safety Function Determination Program (SFDP)," with a variation due to the differences between the content of the ISTS and the non-ISTS. The proposed SFDP uses the term ACTIONS rather than Conditions and Required Actions. This variation does not make any technical changes to the SFDP.

L-2018-049 Enclosure Page 31 of 33

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria

NUREG-0800, Standard Review Plan - discusses in section 16, Technical Specifications, that plants with TS based on the previous standard TS and plants with custom TS may partially adopt ISTS provisions without adopting the ISTS format. TS change requests for facilities with TS based on previous standard TS should comply with comparable provisions in the ISTS to the extent possible or justify deviations from the ISTS.

10 CFR 50.36 Technical Specifications - establishes the requirements for information that must be included in the TS.

The proposed change is consistent with the above requirements.

4.2 Precedent

The proposed changes are consistent with NUREG-1431, Standard Technical Specifications Westinghouse Plants, and NUREG-1432, Standard Technical Specifications Combustion Engineering Plants.

In September 2015, Limerick Generating Station received Amendments 219 and 181 [Reference 5], which among other changes, added LCO 3.0.6 and the SFDP to the TS. The NRC approved the addition of LCO 3.0.6 to the TS (non-ISTS) on the basis that it would eliminate potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO conditions and required actions by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's required actions.

4.3 No Significant Hazards Consideration The proposed amendments modify the Technical Specifications (TS) for St. Lucie, Seabrook, and Turkey Point to incorporate the provisions of Limiting Condition for Operation (LCO) 3.0.6 in the ISTS, which provide the actions to be taken when the inoperability of a support system results in the inoperability of related supported systems. In addition, the proposed change adds a new Safety Function Determination Program to the administrative section of the TS to ensure that a loss of safety function is detected and appropriate actions are taken when using the provisions of LCO 3.0.6.

FPL and NextEra evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

L-2018-049 Enclosure Page 32 of 33 This change is associated with the administrative requirements for implementing the TS, which are not initiators of any accidents previously evaluated, so the probability of accidents previously evaluated is unaffected by the proposed change. The proposed change does not alter the design, function, or operation of any plant structure, system, or component (SSC). The capability of any operable TS-required SSC to perform its specified safety function is not impacted by the proposed change. As a result, the outcomes of accidents previously evaluated are unaffected. Therefore, the proposed change does not result in a significant increase in the probability or consequences of an accident previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not challenge the integrity or performance of any safety-related systems. No plant equipment is installed or removed, and the changes do not alter the design, physical configuration, or method of operation of any plant SSC. No physical changes are made to the plant, so no new causal mechanisms are introduced. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The ability of any operable SSC to perform its designated safety function is unaffected by the proposed changes. The proposed change does not alter any safety analyses assumptions, safety limits, limiting safety system settings, or method of operating the plant. The change does not adversely affect plant operating margins or the reliability of equipment credited in the safety analyses.

The proposed change allows not entering the Actions for supported systems that are inoperable solely due to a support system LCO not being met. However, the change also requires implementing a Safety Function Determination Program (SFDP) to determine if a loss of safety function exists. If the SFDP determines that a loss of safety function exists, the appropriate actions of the LCO in which the loss of safety function exists are required to be entered.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, FPL and N extEra conclude that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

L-2018-049 Enclosure Page 33 of33 4.4 Conclusion In conclusion, based on the considerations above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed m anner, (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 safe ty of the general public.

5.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 REFERENCES

l. NUREG-0452, Standard Technical Specifications for Westinghouse Pressurized Water Reactors, Revision 3, Fall 1981.

2. NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 4.0, April 2012.

3. NUREG-0212, Standard Technical Specifications for Combustion E ngineering Pressurized Water Reactors, Revision 2, Fall 1980.

4. UREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 4.0, April 2012.

5. NRC letter "Limerick Generating Station, Units 1 and 2 - Issuance of Amendment Re:

Proposed Change to Add New Limiting Conditions for Operation 3.0.5 and 3.0.6 (TAC Nos. MF5133 and MF5134)," September 15, 2015 (ML15218A501).

ATTACHMENT 1 Proposed Technical Specification Changes (Mark-Up)

St. Lucie Unit 1 Proposed Technical Specification Changes (Mark-Up) 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY and LCO 3.0.6 3.0.1 Limiting Conditions for Operation (LCO) shall be met durin the MODES or other specified conditions in the Applicability , except as provide in LCO 3.0.2 .

3.0.2 Upon discovery of a failure to meet an LCO , the CTION (s) of tt:ie assooiated ooAditions shall be met, except as provided in LCO 3.0.5. If the LCO is met or is no longer applicable prior to expiration of the specified time interval(s), completion of the Re(luired ACTION(s) is not required , unless otherwise stated .

3.0.3 When a Limiting Condition for Operation (LCO) is not met, except as provided in the associated ACTION requ irements , within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action shall be initiated to place the unit in a MODE in which specification does not apply by placing it, as applicable in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION requirements , the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the LCO . Exceptions to these requirements are stated in the individual specifications .

This specification is not applicable in MODES 5 or 6.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made :

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time ;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results , determination of the acceptability of entering the MODE or other specified condition in the Applicability , and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications) ; or

c. When an allowance is stated in the individual value , parameter, or other Specification .

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

3.0.5 Equipment removed from service or declared inoperable to comply with ACTION(s) may be returned to service under administrative control solely to perform testing required to INSERT LCO demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an 3.0.6 exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

ST. LUCIE - UNIT 1 3/4 0-1 A mendment No . 4G, 00, ~ .

~. ~

J

INSE RT LCO 3.0.6 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the ACTIONS associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.8.4.r, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONS of the LCO in which the loss of safety function exists are required to be entered.

When a support system's ACTION directs a supported system to be declared inoperable or directs entry into ACTIONS for a supported system, the applicable ACTIONS shall be entered in accordance with LCO 3.0.2.

REACTOR COOLANT SYSTEM REACTOR COOLANT SYSTEM LEAKAGE LIMITING CONDITION FOR OPERATION 3.4.6.2 Reactor Coolant System operational leakage shall be limited to :

a. No PRESSURE BOUNDARY LEAKAGE ,

b. 1 GPM UNIDENTIFIED LEAKAGE ,

c. 150 gallons per day primary-to-secondary leakage through any one steam generator (SG) ,

d. 10 GPM IDENTIFIED LEAKAGE from the Reactor Coolant System , and

e. Leakage as specified in Table 3.4 .6-1 for each Reactor Coolant System Pressure Isolation ' """'.................."""'"*'~d....u.....:.c.ab..l........::.;t...A..~L - - - - - - - - - - - - - ~

........................................... NOTE .. ... .. .. ... .... ... ... ........... .

APPLICABILITY: MODES 1, 2, 3 and 4. Enter applicable ACTIONS for systems made inoperable by an inoperable pressure isolation valve.

ACTION:

a. With any PRESSURE BOUNDAR LEAKAGE , or with primary-to-secondary leakage not within limit, be in at lea t HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the foll ing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With any Reactor Coolant System perational leakage greater than any one of the above limits, excluding primary to-secondary leakage, PRESSURE BOUNDARY LEAKAGE , and Rea or Coolant System Pressure Isolation Valve leakage, reduce the leakage rate t within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months an in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With any Reactor Coolant System Pressure Isolation Valve leakage greater than the limit in 3.4.6.2.e above reactor operation may continue provided that at least two valves , including check valves , in each high pressure line having a non-functional valve are in and remain in the mode corresponding to the isolated con-dition . Motor operated valves shall be placed in the closed posi-tion , and power supplies deenergized . (r:-.l ote , l=lowe 11er, tl=lat tl=lis may lead to ACTION requiremeAts for systems iAvo lved .) Otherwise,

reduce the leakage rate to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.4 .6.2 Reactor Coolant System operational leakages shall be demonstrated to be within each of the above limits by:

a. Monitoring the containment atmosphere gaseous and particulate radioactivity in accordance with the Surveillance Frequency Control Program . +-

ST. LUCIE - UNIT 1 3/4 4-14 Or=eer aatea 4t2G/81 Amendment No. ~ . ~ . ~

............. ......... ... .. .... .......... .. NOTE ...... ....... .... .... ... .... ... ..... .. .... .. .

Enter the ACTION of LCO 3.6.1.2, "Containment Leakage,"

CONTAINMENT SYSTEMS when air lock leakage results in exceeding overall containment leakage rate acceptance criteria.

CONTAINMENT AIR LOCKS 3.6.1.3 Each containment air lock shall be OPERABLE th :

a. Both doors closed except when the air lock s being used for normal transit entry and exit through the containment, the at least one air lock door shall be closed , and

b. An overall air lock leakage rate in accordan e with the Containment Leakage Rate Testing Program .

APPLICABILITY: MODES 1, 2, 3 and 4 .

ACTION:

a. With one containment air lock door inoperable*:

1. Maintain at least the OPERABLE air lock door closed and either restore the inoperable air lock door to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or lock the OPERABLE air lock door closed .

2. Operation may then continue until performance of the next required overall air lock leakage test provided that the OPERABLE air lock door is verified to be closed at least once per 31 days.

3. Otherwise , be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4 .a is not applicable when entering HOT SHUTDOWN .

b. With the containment air lock inoperable, except as the result of an inoperable air lock door, maintain at least one air lock door closed ; restore the inoperable air lock to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4 .a is not applicable when entering HOT SHUTDOWN .

t SURVEILLANCE REQUIREMENTS 4.6 .1.3 Each containment air lock shall be demonstrated OPERABLE:

If the inner air lock door is inoperable, passage through the OPERABLE outer air lock door is permitted to effect repairs to the inoperable inner air lock door. No more than one airlock door shall be open at any time .

ST. LUCIE - UNIT 1 3/4 6-10 Amendment No. 88, 4,4g, ~ .

~

CONTAINMENT SYSTEMS 3/4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.6.3.1 The containment isolation valves shall be OPERABLE:

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

r-7 With one or more of the isolation valve(s) inoperable, either:

a. Restore the inoperable valve(s) to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or

b. Isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least one deactivated automatic valve secured in the isolation position , or

c. Isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least one closed d.

manual valve or blind flange; or Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4 .a is not applicable when entering HOT SHUTDOWN.

t SURVEILLANCE REQUIREMENTS 4.6.3.1 .1 The isolation valves shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of the cycling test, and verification of isolation time .

...... ................ .... .... .... ........ .. .. ... ... .......... .. .... .. .NOTES ... .. ... ........ ......... ... ... ... ....... ......... .... .. ........... ..

1. Enter applicable ACTIONS for systems made inoperable by containment isolation valves .

2. Enter the ACTION of LCO 3.6.1 .2, "Containment Leakage," when leakage results in exceeding the overall containment leakage rate acceptance criteria.

ST. LUCIE - UNIT 1 3/4 6-18 Amendment No. W , 449, ~

PLANT SYSTEMS 3/4.7.3 COMPONENT COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3.1 At least two independent component cooling water loops shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

. . ~-..

ACTION:

/

With only one component cooling water loop OPERABLE, restore at least two loops to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

SURVEILLANCE REQUIREMENTS 4.7.3.1 At least two component cooling water loops shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic) servicing safety related equipment that is not locked, sealed or otherwise secured in position, is in its correct position .

b. In accordance with the Surveillance Frequency Control Program during shutdown by verifying that each automatic valve servicing safety related equipment actuates to its correct position on a Safety Injection Actuation Signal.

.. ......................... ... ... .. ... .... ..... ... ... ... .. .... ... ........... .NOTE ... ............. ....... ....... ... .. ....... ... ... .. .... .... ... ..... .

Enter applicable ACTIONS of LCO 3.4.1 .3, "Reactor Coolant System - Hot Shutdown ," for shutdown cooling loops made inoperable by CCW.

ST. LUCIE - UNIT 1 3/4 7-14 Amendment No. W , ~ . -r*

PLANT SYSTEMS 3/4.7.4 INTAKE COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.4 .1 At least two independent intake cooling water loops shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

/

With only one intake cooling water loop OPERABLE, restore at least two loops to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN .

SURVEILLANCE REQUIREMENTS 4.7.4 .1 At least two intake cooling water loops shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual , power operated or automatic) servicing safety related equipment that is not locked , sealed , or otherwise secured in position ,

is in its correct position.

b. In accordance with the Surveillance Frequency Control Program during shutdown by verifying that each automatic valve servicing safety related equipment actuates to its correct position on a Safety Injection Actuation signal.

.. .. .... ... .... .. .. .... ... .... .......... ... ..... ......... ........ ............ NOTE ....... ....... ....... ........ ... .. ..... .. ... .... ..... ... .. .... .... .

Enter applicable ACTIONS of LCO 3.4 .1.3, "Reactor Coolant System - Hot Shutdown," for shutdown cooling loops made inoperable by ICW.

ST. LUCIE - UNIT 1 3/4 7-16 Amendment No. W , ~ . i!

3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1 .1 As a minimum , the following AC . electrical power sources shall be OPERABLE :

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system , and

b. Two separate and independent diesel generator sets each with :

1. Engine-mounted fuel tanks containing a minimum of 152 gallons of fuel ,

2. A separate fuel storage system conta ining a minimum of 19,000 gallons of fuel , and

3. A separate fuel transfer pump .

APPLICABILITY: MODES 1, 2 , 3 and 4 .

ACTION:

&.- WitR ORO offsite eirG1:1it of a.8.1.1.a iAoperable, exeept as provided iA 1\etioA f.

IINSERT ACTION a V below, demoAstrate tRO OPERABILITY of tRO remaiAiAg A .G. SOUFGOS by peFformiAg SurveillaAee RequiremeAt 4.8.1.1.1.a 1nitRiA 1 ROUF aAd at least oAee per 8 ROUFS tRereafter. Restore tRe offsite eirnuit to OPERABLE status e

witRiA 72 ROUFS OF be iA at least HOT STANDBY witRiA tRO Ae><t ROUFS aAd MOT SMUTDOVVN witRiA tRO followiAg e ROUFS. LGO a.0.4 .a is Rot applieable WROA OAtOFiAg MOT SMUTDOW~J.

a-:- WitR ORO diesel geAeFatoF of d.8.1.1.b iAoporablo , d0A10Astrato tRe 1 JI OPERABILITY of tRe A .G. sournos by poFformiAg SurvoillaAoe RequiromoAt

!INSERT ACTION b V' 4 .8.1.1.1.a witRiA 1 ROUF aAd at least ORSO per 8 ROUFS tROFOaftor; aAd if tRO EDG boeamo iAoperable duo to aAy eauso otRor tRaA aA iAoperablo support system, OR iAdopoAdeAtly testable eompoAeAt, OF preplaAAed pre*,eAtafr,o maiAtOAOAGe OF testiAg, dOA10AStrate tRO OPERAB ILITY of tRe remaiAiAg OPERABLE EDG by peFformiAg SurvoillaAee RoquiremeAt 4 .8.1.1.2.a.4 witRiA 8 Rours , uA less it eaA be eoAfirmed tRat tRe ea use of tRe iAoperable EDG does Rot exist OR tRe remaiAiAg EDG*; restore tRe diesel geAerator to OPERABLE status witRiA 14 days OF be iA at least MOT STANDBY witRiA tRe Ae><t e ROUFS aAd iA MOT SHUTDOWN witRiA tRO followiAg e ROUFS. LGO a.0.4 .a is Rot applicable WReA eAteriAg HOT SHUTDOW~J. AdditioAally, witRiA 4 ROUFS from tRe diseo'lory of eoAeurreAt iAoperability of required reduAdaAt fcature(s)

(iAeludiAg tRe steam driveA auxiliary feed pump iA MODE 1, 2 , aAd a) , deelare required fcature(s) supported by tRe iAoperable EDG iAoperable if its reduAdaAt required feature(s) is iAoperable.

If the absence of any common -cause failure cannot be confirmed, this test shall be completed regardless of when the inoperable EOG is restored to OPERABILITY.

ST. LUCIE - UNIT 1 3/4 8-1 Amendment No. 400, ~ . ~. ~ .

48G. ~ .~

ELECTRICAL POWER SYSTEMS ACTION (continued)

WitR oAe offsite A.G . oirsuit aml oAe eliesel §OAerator iAoperal:lle , elemoAstrate tRe OPERAB ILITY of tRe remaiAiA§ A .G. souroes l:ly performiAg SurveillaAoe RequiremeAt 4 .8.1.1.1.a witRiA ORO ROUF aAel at least OAOO per 8 ROUFS tRereafter; aAel if tRe EDG l:leoame iAoperal:lle elue to aAy oause otRer tRaA aA iAoperal:lle support system , aA iAelepeAeleAtly testal:l le oompoAeAt, or INSERT ACTION c preplaAAeel preveAtative maiAteAaAoe or testiAg , elemoAstrate tRe OPERABILITY of tRe remaiAiA§ OPERABLE EDG l:ly performiA§ SurveillaAoe RequiremeAt 4 .8.1.1.2 .a.4 witRiA 8 Rours uAless it oaA l:lo ooAfirmeel tRat tRe oause of tRe iAoperal:lle EDG eloes Rot exist OR tRe remaiAiA§ EDG*. Restore at least ORO of tRe iAoperal:lle sou roes to OPERABLE status w itRiA 12 Rours or l:le iA at least I-IOT STA~mBY witRiA tRe Aext 6 Rours aAel iA I-IOT SI-IUTDOWN v.*itRiA tRe follm.\'iA§ 6 ROUFS . LGO d.0.4 .a is Rot applioal:lle WReA eAteriAg ~OT S~UTDOWN . Restore tRo otRor A.G . power souroe (offsite oirouit or eliesel geAerator) to OPERABLE status iA aooorelaAoe witR tRe provisioAs of SeotioA d.8.1.1 AGTIO~, StatemoAt a or l:l , as appropriate , witR tRe time requiremeAt of tRat ACTIO~, StatemeAt l:laseel OR tRe time of tRe iAitial loss of tRe remaiAiAg iAoperal:lle /\.G. power souroe. ,t\elelitioAally, witRiA 4 Rours from tRe elisoo 1t'ory of ooAourroAt iAoperal:lility of requireel reeluAelaAt foature(s) (iAolueliA§ tRe steam elrivoA auxiliary fooel p1:1mp iA MODE 1, 2 , aAel d) , eleolare req1:1iroel foat1:1Fe(s) s1:1pporteel l:ly tRe iAoperal:lle EDG iAoperal:llo if its roduAdaAt requireel feature(s) is iAoporal:llo .

d. WitR two of tRe requireel offsite A.G . oiro1:1its iAoperal:lle , restore ORO of tRe i'NSERT ACTION 6 iAoperal:lle offsite souroes to OPERABLE status witRiA 24 Ro1:1rs or l:le iA at least ~OT STA~lDBY witRiA tRe Aext 6 Ro1:1rs. FollowiAg rostoratioA of oAe offsite sou roe , follow ACTION StatemeAt a . witR tRe time req1:1iromeAt of tRat ACTION StatemeAt l:lased OR tRe time of tRe iAitial loss of tRe remaiAiAg iAoperal:llo offsito A.G . oirnuit.

If tho absence of any common-cause failure cannot be confirmed , this test shall be completed regardless of when the inoperable EOG is restored to OPERABILITY .

ST. LUCIE - UNIT 1 3/4 8-2 Amendment No. 4W, ~ . 468, 400,

~

INSERT ACTION a

a. With one offsite circuit of 3.8.1.1.a inoperable, except as provided in Action f. below:

1. Demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery ofno offsite power to one train concurrent with inoperability ofredundant required Eea ture(s), declare required Eeature(s) with no offsite power available inoperable when its redundant required Eeature(s) is inoperable.

3. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

4. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

INSERT ACTION b

b. With one diesel generator of 3.8.1.1.b inoperable:

1. Demonstrate the OPERABILITY of the A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. Additionally, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from the discovery of concurren t inoperability of required redundant feature(s) (including the steam driven auxiliary feed pump in MODE 1, 2, and 3), declare required feature(s) supported by the inoperable EDG inoperable if its redundant required feature(s) is inoperable.

3. If the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless it can be confirmed that the cause of the inoperable EDG does not exist on the remaining EDG*.

4. Restore the diesel generator to OPERABLE status within 14 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

5. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

INSERT ACTION c

J\TOT.l:t------------------------------------------------

1:tnter applicable ACTIOJ\Ts ofLCO 3.8.21, A.C. Distribution - Operating," when ACTIOJ\T c is entered with no AC power to any train.

c. With one offsite A.C. circuit and one diesel generator inoperable:

1. Demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. Additionally, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from the discovery of concurrent inoperability of required redundant feature(s) (including the steam driven auxiliary feed pump in MODE 1, 2, and 3), declare required feature(s) supported by the inoperable EDG inoperable if its redundant required feature(s) is inoperable.

3. If the EDG became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months unless it can be confirmed that the cause of the inoperable EDG does not exist on the remaining EDG*.

4. Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

5. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

6. Restore the other A.C. power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the provisions of Section 3.8.1.1 ACTION Statement a orb, as appropriate, with the time requirement of that ACTION Statement based on the time of the initial loss of the remaining inoperable A.C. power source.

INSERT ACTION d

d. With two of the required offsite A.C. circuits inoperable:

1. Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery oftwo offsite circuits inoperable concurrent with in operability ofredundant required feature(s), declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

2. Restore one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

3. Following res toration of one offsite source, follow ACTION Statement a. with the time requirement of that ACTION Statement based on the time of the initial loss of the remaining inoperable offsite A.C. circuit.

ELECTRICAL POWER SYSTEMS SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following AC. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system , and

b. One diesel generator set with :

1. Engine-mounted fuel tanks containing a minimum of 152 gallons of fuel ,

2. A fuel storage system containing a minimum of 19,000 gallons of fuel , and

3. A fuel transfer pump.

APPLICABILITY: MODES 5 and 6.

ACTION:

With less than the above minimum required AC . electrical power sources OPERABLE ,

immediately suspend all operations involving CORE ALTERATIONS , operations involving positive reactivity additions that could result in loss of required SHUTDOWN MARGIN or boron concentration , movement of irradiated fuel , or crane operation with loads over the fuel storage pool. In addition , when in MODE 5 with the reactor coolant loops not filled , or in MODE 6 with the water level less than 23 feet above the top of irradiated fuel assemblies seated within the reactor vessel, immed iately initiate corrective action to restore the required sources to OPERABLE status as soon as possible .

SURVEILLANCE REQUIREMENTS 4.8 .1.2.1 The above required AC . electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1 .2 except for requirement 4.8.1 .1.2a .5 .

..... ... ..... ... ... .. ........... .... ..... ... .. .. ............. ..... ...NOTE ..... .. ... .......... ... ..... .. ... .... ... ... ....... ... .. ... ... .

Enter the ACTION of LCO 3.8.2.2, "A.C. Distribution - Shutdown ," with one required train de-energized as a result of inoperable offsite circu it.

ST. LUCIE - UNIT 1 3/4 8-7 Amendment No . 400, ~ . 4+9, 2 13

ELECTRICAL POWER SYSTEMS 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPERATING LIMITING CONDITION FOR OPERATION 3.8.2 .1 The following AC . electrical busses shall be OPERABLE and energized from sources of power other than the diesel generator sets:

4160 volt Emergency Bus 1A3 4160 volt Emergency Bus 183 480 volt Emergency Bus 1A2 480 volt Emergency Bus 182 480 volt Emergency MCC Susses 1A5, 1A6, 1A7 480 volt Emergency MCC Susses 185, 186, 187 120 volt AC . Instrument Bus 1MA 120 volt AC . Instrument Bus 1MB 120 volt AC . Instrument Bus 1MC 120 volt AC . Instrument Bus 1MD APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

r7 With less than the above complement of AC . busses OPERABLE , restore the inoperable bus to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.8.2.1 The specified AC. busses shall be determined OPERABLE and energized from A .C.

sources other than the diesel generators in accordance with the Surveillance L, Frequency Control Program by verifying indicated power availability. 1

.............................................. ... ........ ........ .... NOTE .. .. ..... .. ..... .... ... ... ... ... .. ..... .. .. ............. ..... .

Enter applicable ACTIONS of LCO 3.8.2.3, "D .C. Distribution - Operating," for DC trains made inoperable by inoperable AC distribution system.

ST. LUCIE - UNIT 1 3/4 8-8 Amendment No. 223

ADMINISTRATIVE CONTROLS (continued}

0. Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies . The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of frequencies of those Surveillance Requirements for which the frequency is controlled by the program .

b. Changes to the frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4 .0.2 and 4.0 .3 are applicable to the frequencies established in the Surveillance Frequency Control Program .

p. Snubber Testing Program This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50 .55a in service inspection (ISi) requirements for supports. The program shall be in accordance with the following :

1. This program shall meet 10 CFR 50 .55a(g) ISi requirements for supports.

2. The program shall meet the requirements for ISi of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50 .55a(b) subject to the conditions listed in 10 CFR 50 .55a(b) and subject to Commission approval.

3. The program shall , as required by 10 CFR 50.55a(b)(3)(v) , meet Subsection ISTA, "General Requirements" and Subsection ISTD , "Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants".

4. The 120-month program updates shall be made in accordance with 10 CFR 50 .55a(g)(4), 10 CFR 50.55a(g)(3)(v) and 10 CFR 50 .55a(b) (including 10 CFR 50 .55a(b)(3)(v)) subject to the conditions listed therein .

q. Component Cyclic or Transient Limit Program The program provides controls to track the FSAR , Section 5.2, cyclic and transient INSERT SFDP occurrences to ensure that components are maintained within the design limits.

ST. LUCIE - UNIT 1 6-15h Amendment No. ~ .~ .~ .

~

INSERT SFDP

r. Safety Function Determination Program (SFDP)

This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists.

Additionally, other appropriate actions may be taken as a result of the support system inoperability and corresponding exception to entering supported system ACTIONs. This program implements the requirements ofLCO 3.0.6. The SFDP shall contain the following: