ML080770265

Request for Additional Information, Control Room Habitability, TSTF-448

ML080770265
Person / Time
Site:	Saint Lucie
Issue date:	04/23/2008
From:	Mozafari B L NRC/NRR/ADRO/DORL/LPLII-2
To:	Stall J A Florida Power & Light Co
Mozafari B L, NRR/ADRO/DORL, 415-2020
References
TAC MD6174, TAC MD6175, TSTF-448
Download: ML080770265 (6)

Text

April 23, 2008 Mr. J. A. Stall Senior Vice president, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 1400 Juno Beach, Florida 33408-0420

SUBJECT:

ST. LUCIE PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTROL ROOM HABITABILITY, TSTF-448 (TAC NOS. MD6174 AND MD6175)

Dear Mr. Stall:

By letter dated July 16, 2007, Florida Power & Light Company (the licensee) submitted a request to amend the Technical Specifications for St. Lucie Units 1 and 2 for implementation of the Technical Specification Task Force Traveler (TSTF) 448, Revision 3, "Control Room Habitability." We have reviewed the submittal and have determined that we need additional information before we can complete our review. Enclosed is our request for additional information.

This request was discussed with Mr. Ken Frehafer of your staff on April 22, 2008, it was agreed that a final response would be provided by May 22, 2008. If you have any questions, please feel free to contact me at 301-415-2020.

Sincerely,

/RA/ Brenda L. Mozafari, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-335 and 50-389

Enclosure:

Request for Additional Information cc: See next page

Enclosure REQUEST FOR ADDITIONAL INFORMATION ST. LUCIE UNITS 1 AND 2 CONTROL ROOM HABITABILITY, TSTF-448 DOCKET NOS. 50-335 AND 50-389

1. For Units 1 and 2, Section 2.2 of Attachment 1 of the license amendment request (LAR) dated July 16, 2007, reads:

And finally, there is no significant production or storage of hazardous chemicals at the plant site of within the plant vicinity (Ref. 9, Sections 2.2.2.1 and 9.4). Therefore, there is not a requirement to provide protection to control room operators in the CRE [control room envelope] from chemical hazards, as provided in the TSTF-448.

Identify Ref. 9 of the preceding excerpt, because the reference is not described elsewhere in the LAR.

Section 2.5 of Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," reads:

Licensees should evaluate the impact of hazardous chemicals on control room operators using the methodology of Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release" (Ref. 7). Regulatory Guide 1.78 encourages licensees to conduct periodic surveys of stationary and mobile sources of hazardous chemicals in the vicinity of their plant sites. The periodicity should be based on the number, size, and type of industrial and transportation activities in the vicinity of the plant and regional and local changes in uses of land. The staff recommends conducting a survey of the location, types, and quantities of the mobile and stationary hazardous chemical sources at least once every 3 years, or more frequently as applicable. The staff also recommends annual performance of an onsite survey of hazardous chemical sources. . . .

What program and/or programs currently exist at St. Lucie Units 1 and 2 that ensure that the licensee revisits the issue of onsite and mobile sources of hazardous chemicals on a periodic basis? 2. For St. Lucie Unit 1, the conclusion to the proposed ACTION statement "c." for MODES 1, 2, 3, and 4 of TS 3/4.7.7 reads:

Otherwise, restore the filter train to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Consistent with TSTF-448, the NRC staff notes that normally an ACTION statement directing a shutdown would typically be the last ACTION for a Limiting Condition for Operation (LCO). Discuss how the proposed order of the ACTIONS maintains the clarity of the ACTION statements and avoids misinterpretation.

3. For St. Lucie Unit 1, Attachment 2, Page 5 of 9, m. Control Room Envelope Habitability Program of the LAR Insert 'A', item "d." reads:

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by the CREVS, operating at the flow rate required by the VFTP, at a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 36 month assessment of the CRE boundary.

The frequency invoked on page 5.5-18 for 5.5.18.d (i.e., Control Room Habitability Program) of the Combustion Engineering Owners Group Standard Technical Specifications (CEOG STS) in Technical Specification Task Force Traveler 448 (TSTF-448), Revision 3, "Control Room Habitability" is 18 months.

The current Surveillance Requirement 4.7.7.1.d.2 for St. Lucie Unit 1 TS 3/4.7.7 reads:

At least once per 18 months by:

2. Verifying that the system maintains the control room at a positive pressure 1/8 inch W.G. relative to the outside atmosphere during system operation with 450 cfm outside air intake.

Provide the basis for deviating from the 18-month test frequency found in TSTF-448, Revision 3, and the 18-month test frequency contained in the similar surveillance requirement for current pressure testing specified for St. Lucie Unit 1. In addition, provide a definition of STAGGERED TEST BASIS for Unit 1.

4. Element d of the Control Room Envelope Habitability Program for St. Lucie Unit 2, shown in Insert 'B,' on page 9 of 9 of Attachment 2, reads:

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREACS, operating at the flow rate required by the VFTP, at a Frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 36 month assessment of the CRE boundary.

The frequency invoked on page 5.5-18 for 5.5.18.d (i.e., Control Room Habitability Program) of the CEOG STS in TSTF-448, Revision 3 is 18 months.

The current Surveillance Requirement 4.7.7.d.2 for St. Lucie Unit 2 TS 3/4.7.7 reads:

At least once per 18 months by:

2. Verifying that the system maintains the control room at a positive pressure of greater than or equal to 1/8 inch Water Gauge relative to the outside atmosphere during system operation with 450 cfm outside air intake.

Provide the basis for deviating from the 18-month test frequency found in TSTF-448, Revision 3, and the 18-month test frequency contained in the similar surveillance requirement for current pressure testing specified for St. Lucie Unit 2. In addition, provide a definition of STAGGERED TEST BASIS for Unit 2.

5. Attachment 5, page 6 of 7, second paragraph, second sentence uses the Unit 1 acronym CREVS instead of the Unit 2 acronym CREACS. Provide the staff with a clarification.

April 23, 2008

Mr. J. A. Stall Senior Vice president, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 1400 Juno Beach, Florida 33408-0420

SUBJECT:

ST. LUCIE PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTROL ROOM HABITABILITY, TSTF-448 (TAC NOS. MD6174 AND MD6175)

Dear Mr. Stall:

By letter dated July 16, 2007, Florida Power & Light Company (the licensee) submitted a request to amend the Technical Specifications for St. Lucie Units 1 and 2 for implementation of the Technical Specification Task Force Traveler (TSTF) 448, Revision 3, "Control Room Habitability." We have reviewed the submittal and have determined that we need additional information before we can complete our review. Enclosed is our request for additional information.

This request was discussed with Mr. Ken Frehafer of your staff on April 22, 2008, it was agreed that a final response would be provided by May 22, 2008. If you have any questions, please feel free to contact me at 301-415-2020.

Sincerely, /RA/

Brenda L. Mozafari, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-335 and 50-389

Enclosure:

Request for Additional Information cc: See next page DISTRIBUTION

PUBLIC RidsOgcRp RidsNrrDorlDpr HWalker LPL2-2 R/F RidsAcrsAcnw&mMailCenter RidsNrrDssScvb RidsNrrPMBMozafari RidsRgn2MailCenter D. Nold RidsNrrLABClayton (Hard Copy) RidsNrrDorlLpl2-2 R. Dennig ADAMS Accession Number: ML080770265 NRR-088 OFFICE LPL2-2/PM LPL2-2/LA DSS/SCVB LPL2-2/BC NAME BMozafari BClayton RDennig By memo dated TBoyce/EBrown for DATE 04/ 22 /08 04/ 22 /08 01/15/07 04 / 23 /08 OFFICIAL RECORD COPY Florida Power and Light Company ST. LUCIE PLANT

cc: ST. LUCIE PLANT Mr. Mano Nazar Senior Vice President and Nuclear Chief Operating Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, Florida 34957 Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW. Suite 220 Washington, DC 20004

Mr. Douglas Anderson County Administrator St. Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741

Mr. Gordon L. Johnston Site Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000 Mr. Christopher R. Costanzo Plant General Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Mr. Terry Patterson Licensing Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957 Don E. Grissette Vice President, Nuclear Training and Performance Improvement Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Technical Services Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Mr. J. Kammel Radiological Emergency Planning Administrator Department of Public Safety 6000 Southeast Tower Drive Stuart, Florida 34997 Mr. Bill Parks Operations Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000 Mr. Seth B. Duston Training Manager St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957-2000