ML17223B116

Proposed Tech Specs Re Seismic Monitoring Instrumentation, Accident Monitoring Instrumentation & Surveillance Requirements for Electrical Power Sys

ML17223B116
Person / Time
Site:	Saint Lucie
Issue date:	02/26/1991
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17223B115	List: ML17223B113 ML17223B116
References
NUDOCS 9103040118
Download: ML17223B116 (59)

Text

ATTACHMENT 1 Marked-up St. Lucie Unit 1 Technical Specification pages:

3/4 3-28 3/4 3-42 3/4 4-4 3/4 8-1 3/4 8-2 3/4 8-3 3/4 8-4 3/4 8-6a 3/4 8-6b 3/4 10-2 6-8 9i03040ii8 9'10226 PDR ADOCK 05000335 P PDR i)

TABLE 3.3-7 SEISMIC MONITORING INSTRUMENTATION MINIMUM

'EASUREMENT CHANNELS INSTRUMENT CHANNEL SENSOR LOCATION RANGE OPEPABLE

1. STRONG MOTION TRIAXIAL ACCELEROGRAPHS

a. SMR-42-1 R.B. Elev. O-l g 1 b.

23.0'.B.

SMR-42-2 Elev. 0-1 g 1

c. SMR-42-3 Elev.

62.0'.A.B.

0-1 g 1

d. SMR-42-4 Elev.

-0.5'.A.B.

0-1 g 1 43.0'.A.B.

Clev. iq. 5 o-L g

2. PEAK RECOROING ACCELEROGRAPHS

a. SMR-42-6 R.B. Piping from S. I.T.lA2-c Elev.

46'0 9/16" 0-2 g

b. SMR-42-7 R.B. Equipment on S. I.T. 1A2 0-2 g

c. SMR-42-8 R.A.B.-Sh. Dn. Ht.

XCHR Supports 0-2 g

3. PEAK SHOCK RECORDERS

a. SMR-42-9 R.B. Elev. 23.0'.B.

b. SMR-42-10 M.S. Pipe Restraints - S.G.lB1

4. EARTHQUAKE FORCE MONITOR

a. SMI-42-11 Control Room 0-0.2 g

5. SEISMIC SWITCH

a. SMS-42-12 R.B. Elev.

23.0'T.

LUCIE - UNIT 1 3/4 3-28

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TABLE 3.3-11 ACCIDENT HONITORING INSTRUHENTATION HINIHUH TOTAL NO. CHANNELS INSTRUHENT OF CHANNELS OPERABLE ACT ION

1. Pressurizer Mater Level

2. Auxiliary Feedwater Flow Rate 1/pump 1/pump

3. RCS Subcooling Hargin Honitor

4. PORV Position Indicator Acoustic Flow Honitor 1/valve 1/valve

5. PORV Block Valve Position.

Indicator 1/valve 1/valve

6. Safety Valv'e Position Indicator 1/valve 1/valve

7. Incore Thermocouples 4/core 2/core quadrant quadrant Containment Sump Mater Level 1* 4, 5 8.

(Narrow Range)

9. Containment Sump Mater Level (Wide Range) 4, 5 24* 1** 4, 5

10. Reactor Vessel Level Honitoring System Containment Pressure

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• non-safety grade contai mient sump water level instrument may be substituted.

The is of eight (8) sensors in a probe. of which Definition of OPERABLE: A channel composed four (4) sensors must be OPERABLE.

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REACTOR COOLANT SYSTEM PRESSURIZER LIMITING CONDITION FOR OPERATION 3.4.4 The pressurizer shall be OPERABLE with a steam bubble, and wi h at least 150 kw of pressurizer heaters capable of being supplied by emergency power.

APPLICABILITY: MODES 1 and 2.

ACTION:

With the pressurizer inoperable, be in at least HOT STANDBY with the reactor trip breakers open within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE RE UIREHENTS 4.4.4 In accordance with 4.8.1.1.Z.

ST LUCIE - UNIT 1 3/4 4-4 Amendment No. 37

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3A.8 ELECTRICAL POWER SYSTEMS 3/4. 8.~ 1 A. C. SOURCES

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OPERATING LIMITING CONDITION FOR OPERATION 3.8. 1. 1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsi te 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 containing a minimum of 16,450 gallons of fuel, and

3. A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3 and 4.

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With one offsite circuit of 3.8.1. l.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 hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. If either EOG has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate its OPERABILITY by performing Surveillance, Requirement 4.8. 1. 1.2.a.4 separately for each such EOG within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLO SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With one d sel generator of 3.8. 1. 1.b inoperable, demonstrate the o erabilit of the A. C. sources by performing Surveillance Requirement 4.8.1.1. l.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> s thereafte~; and QAPZVAI.rZ if the EOG became inoperable due to any cause other than preplanned p~eventative maintenance or testing, demonstrate the OPERABILITY of.

the remaining OPERABLE EOG by performing Surveillance Requirement 4.8. 1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />"; restore the diesel generator to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANOBY within the next 6 hours and in COLO SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Additionally, verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in HOT STANOBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLO SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> that:

"This test is required to be completed regardless of when the inoperable EOG is restored to OPERABILITY.

ST. LUCIE - UNIT 1 3/4 8-1 Amendment No. l Q3

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all required systems, subsystems, trains, components and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and

2. When in MODE 1, 2 or 3, the steam-driven auxiliary feed pump i s OPERABLE.

c. With one offsite A.C. circuit and one diesel generator inoperable, de'monstrate 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 <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and if the EDG became inoperable due to any cause other than 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 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> s~. Restore at least one of the inoperable sour ces to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-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 in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. 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 or b, as appropriate, with the time requirement of tKat ACTION Statement based on the time of the initial loss of the remaining inoperable A.C. power source.

Additionally, verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or ba in 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 following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> that:

1. all required systems, subsystems, trains, components and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and

2. When in MODE 1, 2 or 3, the steam-driven auxiliary feed pump is OPERABLE.

d. With two of the required offsite A.C. circuits inoperable, demonstrate the OPERABILITY of two diesel generators by sequentially performing Surveillance Requirement 4.8.1.1.2.a.4 on both diesels within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />,

. unless the .diesel generator s are already operating; restore one of the inoperable offsite sources 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 />. Following restor ation of one offsite source, follow'CTION 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 test is required to be completed regardless of when the inoperable EDG is restored to OPERABILITY.

ST. LUCIE - UNIT 1 3/4 8-2 Amendment No. lO3

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ELECTRICAL POWER SYSTEHS ACTION Continued With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing Surveillance Requirement 4. 8. l. 1. 1. a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 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 in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Following restoration of one diesel generator unit, follow ACTION Statement b. with the time requirement of that ACTION Statement based on the time of initial loss of the remaining inoperable diesel generator.

With one Unit 1 startup transformer (1A or 1B) inoperable and with a Unit 2 startup transformer (2A or 28) connected to the same A or 8 offsite power circuit and administratively available to both units, then should Unit 2 require the use of the startup transformer admini-strativel available to both units, Unit 1 shall demonstrate the

't of the remaining A.C. sources by performing Surveillance Requirement 4.8. 1. 1. 1,a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. If either EDG has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate its OPERABILITY by performing Surveillance Requirement.4. 8. 1. l. 2. a. 4 separately for each such EDG within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Restore the inoperable startup transformer to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> s and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE RE UIREMENTS 4.8. 1.1. 1 Each of the above required independent circuits between the offsite transmission network and the onsite Class lE distribution system shall be:

a. Determined OPERABLE at least once per 7 days by verifying correct breaker alignments, indicated power availability; and

b. Demonstrated OPERABLE at least once per 18 months by transferring (manually and automatically) unit power supply from the auxiliary transformer to the startup transformer.

4. 8. 1. 1. 2 Each diesel generator shall be demonstrated OPERABLE:

a. In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS by:

1. Verifying fuel level in the engine-mounted fuel tank,

2. Ve~ifying the fuel level in the fuel storage tank,

3. Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine-mounted tank, ST. LUCIE - UNIT 1 3/4 8-3 Amendment No. l03

I op ELECTRICAL POQER SYSTEMS SURVEILLANCE RE UIRBIENTS Continued

4. Verifying the diesel starts from ambient condition and accelerates to approximately 900 rpm in less than or equal

,to 10 seconds"". The generator voltage and frequency shall be 4160 + 420 volts and 60 + 1.2 Hz within 10 seconds after the start signal"". The diesel generator shall be started for this test by using one of the following signals:

gpss, a) Manua/j.yao I b) Simulated loss-of-offsite po~er by itself.

c) Simulated loss-of-offsite power in conjunction with an ESF actuation test signal.

d) An ESF actuation test signal by itself.

'. Verifying the generator is synchronized, loaded to greater than or 'equal to'500 kM in less than or equal to 60 seconds""",

and operates within a load band of 3300 to 3500 kW""" for at least an additional 60 minutes, and

6. Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

b. .By removing 'accumulated water:

1. From the engine-mounted fuel tank at least once per 31 days and after each occasion when the diesel is operated for greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and

2. From the storage tank at least once per 92 days.

""The diesel generator start (10 sec.) from ambient conditions shall be performed at least once per 184 days in these surveillance tests. All other diesel generator starts for the purposes of this surveillance testing may be preceded by an engine prelube period and may also include warmup procedures (e.g., gradual acceleration) as recommended by the manufacturer so that mechanical stress and wear on the diesel generator is minimized.

"""Generator loading in less than or equal to 60 seconds shall be performed at least once every 184 days; timing for this loading test shall start upon the closing the diesel generator breaker. All other loading for the purpose of this surveillance test may be performed according to manufacturer's recommendations. The indicated load band is meant as guidance to avoid routine overloading. Variations in loads in excess of the band due to changing bus loads shall not invalidate this test.

ST. LUCIE - UNIT 1 3/4 8-4 Amendment No. 17,$ 8, 103

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ELECTRICAL POWER SYSTEHS SURVEILLANCE RE UIREHENTS Continued

6. Verify in g the diesel generator oper ates for at least 24 hours"*"". Ouring the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded within a load band of 3800 to 3960 kW" and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel genera/or shall be loaded within a load band of 3300 to 3500 kW , - The generator voltage and frequency shall be 4160 + 420 volts and 60 + 1.2 Hz within 10 seconds after the start signal; the steady state generator voltage and frequency shall be maintained within these limits during this test.

7. Verifying that the auto-connected loads do not exceed the 2000-hour rating of 3730 kW.

8. Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power.

b) Transfer its loads to the offsite power source, and its standby 9.

c) Be res Verifying th u) illto diesel status.

p, e generator operating in a test mode (connected to its bus), a simulated safety injection signal over rides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizes the emergency loads with offsite power.

10. Verifying that the fuel transfer pump transfers fuel from each fuel storage tank to the engine-mounted tanks of each diesel via the installed cross connection lines.

ll. Verifying that the automatic load sequence timers are operable with the interval between each load block within + 1 second of its design interval.

At least once per ten years or after any modification which could affect diesel generator independence by starting"*"" the diesel generators simultaneously, during shutdown, and verifying that the diesel generators accelerate to approximately 900 rpm in less than or equal to 10 seconds.

HThis band is meant as guidance to avoid routine overloading of the engine.

Variations in load in excess of this band due to changing bus loads shall not invalidate this test.

""""This test may be conducted in accordance with the manufacturer's recommendations concerning engine prelube period.

ST. LUCIE - UNIT 1 3/4 8-6a Amendment No. IQ3

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E LECTRICAL POWER SYSTEMS SURVEILLANCE RE UIREHENTS Continued

g. At least once'er ten years by:

1. Draining each fuel storage tank, removing the accummulated sediment and cleaning the tank using an appropriate cleaning compound, and 2 ~ Performing a pressure test of those portions of the diesel fuel oil system designed to USAS B31.7 Class 3 requirements at a test pressure equal to 110X of the system design pressure. cog ftC,+~105 4.8.1.1.3 ~Re orts - All diesel generator failures val'on-valid, shall be reported to the Commission pursuant to ec fication .9.2. Reports of diesel generator fai lures shall include the information recommended in Regulatory Position C.3.b of Regulatory Guide 1. 108, Revision 1, August 1977.

If the number of failures in the last 100 valid tests (on a per nuclear unit basis) is greater than or e ual o 7, the report shall be supplemented to include the additional omratio comended in Regulatory Position C.3.b of Regulatory Guide 1. 108, Revision 1, ugus inFoc~a4n 4,8. l. 1.4 The Class 1E underground cable system shall be demonstrated OPERABLE within 30 days after the movement of any loads in excess of 80X of the ground surface design basis load over the cable ducts by pulling a mandrel with a diameter of at least 80% of the duct's inside diameter through a duct exposed to the maximum loading (duct nearest the ground's surface) and verifying that the duct has not been damaged.

ST. LUCIE - UNIT 1 3/4 8-6b Amendment No. lp3

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SPECIAL TEST EXCEPTIONS GROUP HEIGHT, INSERTICN AND POWER DISTRIBUTION LIMITS LIM'.TING CONDITION FOR OPERATION 3.10.2 The group height, insertion and power distribution limits of Specifications 3. 1. 1.4, 3. 1. 3. 1, 3. 1.3.2, 3. 1.3.5, 3. 1.3. 6, 3.2.2, 3.2.3 and 3.2.4 may be suspended during the per,ormance of PHYSICS TESTS provided:

a. The THERMAL POWER is restricted to the test power plateau which shall not exceed 85K of RATED THERMAL POWER, and

b. The limits of Specification 3.2. 1 are maintained and deter-mined as specified in Specification 4.10.2.2 below.

APPLICABILITY: MODES 1 and 2.

ACTION:

With any of the 11mits of Specification 3.2.1 being exceeded while the requirements of'Specifications 3.1.1.4, 3.1.3.1, 3.1.3.2, 3.1.3.5, 3.1.3.6, 3.2.2, 3.2.3 and 3.2.4,are suspended, either:

a. Reduce THERMAL POWER sufficiently to sa isfy the requirements of Specification 3.2. 1, or

b. Be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE RE UIREMENTS 4.10.2.1 The THERMAL POWER shall be determined at least once per hour during P STS in which the requirements of Specifications 3.1.1.4, 3.1.3. 1 . . . 3. 1.3.5, 3. 1.3.6, 3.2.2, 3.2.3 or 3.2.4 are suspended and s 1 rsfied to be within the test power plateau.

4.10.2.2 The linear heat rate shall be determined to be within the limits of Specification 3. 2. by monitoring it continuously with the 1

Incore Det ctor Monitoring System pursuant to the requirements of L)e,lese Specifications 4.2.1.3 and 3.3.3.2 during PHYSICS TESTS above 5~ of RATED TH R in which the requirements of Specifications 3.1.1.4, 3.1.3.1 . . . , .1.3.5, 3. 1.3.6, 3.2.2, 3.2.3 or 3.2.4 are suspended.

- UNIT.1 7 ST. LUCIE 3/4 10-2 Amendment No.

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ADMINI STRAT I VE CONTROLS I

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Review of the Security Plan and implementing procedures and submittal of recommended changes to the Company Nuclear Review 3oard.

Review of the Emergency Plan and implementing procedures and submittal of recommended changes to the Company Nuclear Review Boards Review of every unplanned on-site release of radioactive material to the environs including the preparation of reports covering I ~

l evaluation, recommendations and disposition of the corrective I ~

action to prevent recurrence and the forwarding of these reports I

I to the Senior Vice President - Nuclear and to the Company Nuclear

~ ~ Review Board.

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Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE 00SE CALCULATION MANUAL and RADMASTE TREATMENT SYSTEMS.

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I I (a m. Review and documentation of judgment concerning prolonged I

operation in bypass, channel trip, and/or repair of defective protection channels of process variables placed in bypass since the last FRG meeting.

AUTHORITY 6.5.1.7 The Facility Review Group shall:

a. Recommend in writing to the Plant Manager, approval or disapproval of items considered under Specifications 6.5.1.6.a through d above.

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b. Render determinationa in writing with regard to whether or not each item considered under Specifications 6.5.1.6 above constitutes an unreviewed safety question. g 4, d, o.nd e C. Provide written notiffcatfon within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Senior Vice President - Nuclear and the Company Nuclear Review Board of disagreement between the FRG and the Plant tfanager; however, the Plant Hanager shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1 above.

RECORDS 6.5.1.8 The Facility Review Group shall maintain written minutes of each FRG meeting that, at a minimum, document the results of all FRG activities performed under the responsibility and authority provisions of these Technical Soecfffcations. Copies shall be provided to the Senior Vice Presfdent - Nuclear and the Chairman of the Company Nuclear Review Board.

ST. LUCIE - UNIT 1 6-8 Amendment No. $ 9 if

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ATTACHMENT 2 Marked-up St. Lucie Unit 2 Technical Specification pages:

XXI XXII XXIV XXV 3/4 6-21 3/4 8-4 3/4 8-18 3/4 8-19 6-9

iNOEX LIST OF FIGURES FiGURE PAGE

2. 1-1 REACTOR CORE THERMAL MARGIN SAF~iY LIMIT Lit<ES FOUR REACTOR COOLANT PUMPS OPERATING. ~ ~ 2v3

2. 2-1 LOCAL POWER DENSITY - HIGH TRIP SETPOINT PART 1 (FRACTION OF RATED THERMAL POWER VERSUS QR2}.......... ~ ~ ~ ~ 0 0 2 7

2. 2-2 LOCAL'OWER DENSITY (QR2 VERSUS Y1 HIGH TRIP SETPOit<T PART 2 2-8 2~2 3 THERiQL MARGIN/LOW PRESSURE TRIP SETPOINT PART 1 (Y1 VERSUS A1)....... 2-9

2. 2-4 THERMAL MARGIN/LOW PRESSURE TRIP SETPOINT PART 2 FRACTION OF RAiED THERMAL WER VER US QR1 2-10 B 2.1-1 AXIAL POWER DISTRIBUTION FOR THERiQL MARGIN SAFETY LIMITS ~ ~ ~ > ~ ~ ~

3.1-1 MINIMUM BORIC ACID STORAGE TANK VOLUM AS A FUNCTION OF STORED BORIC ACID CO I ..........

~ DQ.BTS 3/4 1-15 3.1-la ALLOWABLE TIME TO REALIGiV CEA VS .iNITIAL F... 3/4 1-19a I 3.1-2 CEA INScRTION LItilITS VS THERMAL POWER WI(H FOUR REACTOR COOLANT PUMPS OPERATING.... 3/< 1-28

'/4

3. 2-1 ALLOWABLE PEAK LINEAR HEAT RATE VS BURNUP. 3/4 2-3 3~2 2 AXIAL SHAPE INDEX VS FRACTION OF MAXIMUM ALLOWABLE POWER LEVEL PER SPECIFICATION 4.2.1.3. 3/4

3. 2-3 OW L A F lE. L W AiV F 2-5 E.<STBjO

4. 2-1

3. 2-4 AXiAL SHA NOc 0 RATii'lG L:MI ~ S Wi:"'OUR R AC.vR COOLANT PUMPS OPERATIiVG. /4 2-12 3.4-1 OOSc, EQUIVALcNT I 131 PRI>CRY COOLANT SPECiFIC ACTIV!TY LIMITS VERSUS ?ERC=i'lT OF RAiED iHERMAL PO!AER 'nITH TH" PRitNRY COOLAHi SPcCIFIC AC i i VI ' > 1 Ci/GRAM OOSc, IP 4 /8 EQUI VALEi'lT I-131.

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T LUCIE E - UNIT 2 XXI "renascent: .'lo.8 kp

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INDEX LIST OF FIGURES Continued PAGE

~FIG Rf URE- PE TURE LIMITATIONS 3l

3. 4-3 REA F0 NT SY OOWu ANO ZH $ &C<> << WG>

~ ~ ~ ~ ~

I ~ ~ ~ ~ ~ ~ ~ ~ 3/4 4+

J5 PFP g PI 5 -T P L IMITATIONS 3 REC O 3/4

~ ~ ~ ~ ~ ~ ~

FO RAT< S g5' PPg P+g(P)uiVI U-Ouu+QLG C<OI ER'dW hl 4.7-1 SAMP IN PLA OR SNU BER FUNCTIONAL TE T.............,..... 3/4 7-25 B 3/4.4-1 NIL-OUCTILITY TRANSITION TEMPERATURE INCREASE FUNCTION OF y'E'ssew Wcg>f Igc gATSCIAL4 IRRAPIATION) F'ya PeAcvoa 3/4 G 4 IP 5.1-1 S ITE AREA MAP............................................... 5-2

6. 2-1 0 ELETEO......... . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ .. ............

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 0 ~ <-3

6. 2-2 o ELETED o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

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TABLE 3.6-2 0

CONTAINMENT ISOLATION VALVES Maximum Testable Ouring Isolation Penetration Valve Ta Number Number Function A) Containment Isolation Primary Makeup Water (CIS) Yes I-HCV-15-1 I-HCV-18-2 Station Air Supply Yes I-HCV-18-1 Instrument Air Supply (CIS) No I"FCV-25-5,4 10 Containment Purge Exhaust (CIS) No I-FCV-25-2,3 Containment Purge Makeup (CIS). No V-6741 Nitrogen Supply to Safety Yes Injection Tanks (CIS)

I-HCV-14-7 23 Reactor Coolant Pump Cooling No I-HCV-14-1 Water Supply (SIAS)

I-HCV-14-6 24 Reactor Coolant Pump Cooling No I-HCV-14-2 ' Water Return (SIAS)

Dele4, 2516 26 Letdown Line (CIS) No I V 2522 I-SE-05-1A,1B, 1C,ID,1E 28A Safety Injection Tank Sample Yes I-V-5200- 28B Reactor Coolant System Hot Leg Yes O I-V-5203 Sample (CIS)

Ul I-V-5204 29A Pressurizer Surge Yes I"V-5201 Sample (CIS)

I-V-5205 29B Pressurizer Steam Yes I-V-5202 Sample (CIS)

4

~ p.

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I SURVEILLANCE RE llIRENENTS Continued 1- Verifying the fuel level in the engfne~nted fuel tank,

2. Verifying the fuel level fn the fuel storage tank,

3. VeH~yfng the fuel transfer pump can be st<<rted and transfers fuel from the storage system to the errgfne-amounted t<<nk, 4~ Verffyfng the dfesel starts from aahferrt condftfon and accelerates to approximately 900 rpo fn less than or equal to 10 seconds~. The generator voltage and frequency shall be 4160 + 420 volts and 60 + 1.2 Hz withfn 10 seconds after the start signal~. The diesel generator shall be started for th1s test by usin one of the following signals:

a) Nanua /Local, ~Add b) Simulated loss-of-offsfte power by itself.

c) Sfmulated loss-of-offsfto power in corgunctfon with

~

an ESF <<ctuation test signal.

d) An ESF actuatfon test signal by itself.

5. Verffyfng the generator fs synchronized, loaded~ to greater than or equal to 3685 kM fn less than or equal to 60 seconds, and operates wf thin a load band of 3450 to 3685 N. at least an addf tfonal 60 mf nutes and

6. Verifying the dfesel generator fs alfgned to provfde standby power .to the assocfated emergency busses.

b. By rerrrovfng accumulated water:

From the engine-mounted fuel tank at least once per 31 days and after each occasion when the dfesel fs operated for than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and 'reater

2. From the storage tank at least once per 31 days.

• • The diesel generator start (10 sec) frorrr ambient condit1ons shall be performed at least once per 184 days in these survefllance tests. All other diesel generator starts for purposes of this surveillance testing may be preceded by an engine prelube per1od and may also include waraap procedures (e.g., gradual accelerat1on) as recoaaended by the manufacturer so that mechanical stress <<nd wear on the d1esel generator fs minimized.

4 ~

• ~*Generator loading in less than or equal to 60 seconds shall be performed at least once every 184 days; timing for this loading test shall start upon the closfng of one diesel genera'tor breaker. All other loading for the purpose of this surveillance test may be performed according to manufacturer's recorraendatfons. The indicated load band 1s meant as gufdance to avofd rout1ne overloading. Varfatfons fn loads fn excess of the band due to

. changing bus loads shall not invalfdate this test, ST. LUCIE - UNIT 2 3/4 8-4 Amendment No. 39

0 ll JJ<~<(

TABLE 3.8-1 MOTOR"OPERATED VALVES THERMAL OVERLOAD PROT CTION BYPASS DEVICES VALVE NUMBER FUNCTION BYPASS (YES/NO)

RCS: V-1476 LTOP ISOLATION YES V-1477 LTOP ISOLATION YES CVCS: V-2508 BAMT ISOL. YES V"2509 BAMT ISOL. YES V-2514 BAMP DISCH. YES V-2525 PMW SUPPLY YES V"2553 CHARGING PUMP BYPASS YES V"2554 CHARGING PUMP BYPASS YES V"2555 CHARGING PUMP BYPASS YES V-2501 VCT ISOL. YES V-2504 RWT ISOL. YES SIS: FCV-3301 SHUTDOWN COOLING YES FCV"3306 SHUTDOWN COOLING YES HCV-3512 SHUTDOWN COOLING YES HCV-3657 SHUTDOWN COOLING YES V"3456 SOC ISOL. YES V"3457 SDC ISOL. YES V-3517 SDC ISOL. YES V"3658 SDC ISOL. YES V"3540 HOT LEG INJECTION YES V"3550 HOT LEG INJECTION YES V"3523 " HOT LEG INJECTION YES V"3551 HOT LEG INJECTION YES V-3656,3654 HPSI ISOL. YES V-3659 SI RECIRCULATION YES V-3660 SI RECIRCULATION YES V"3615~ ,25, 3S 't< LPSI INJ. YES V"3616~ . 24,34,94 PSI INJ. YES V-3617~ , 27)37) 'l7 PSI INJ. YES V"3480 SOC ISOL. YES V-3481 SOC ISOL. YES V"3651 SDC ISOL. YES V"3652 la.ce SDC ISOL. YES V"3545 SOC X-TIE YES V"3664 SDC ISOL. YES V"3665 SDC ISOL. YES Y"3536 SOC WARMUP YES V"3539 V-3614-V V"3432

~, 2~,3~,'t<

SOC WARMUP IT ISOL.

RWT ISOL.

YES YES YES V-3444 RWT ISOL. YES ST. LUCIE- UNIT 2 3/4 8"18

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TABLE 3.8-1 (Continued)

MOTOR-OPERATED VALVES THERMAL OVERLOAD PROT CTION BYPASS DEVIC VALVE NUMBER FUNCTION BYPASS YES/NO)

MAIN STEAM:

MV"08"1A,1B MSIV BYPASS YES MV-08-18A, 18B A.D.V. YES MV"08" 19A, 19B A. D.V. YES MV"08-12, 13 AFW TURBINE INLET YES MV-08-3 AFW TURBINE INLET YES MV"08" 14, 15, 16, 17 A.D.V. ISOL. YES MAIN FEEDWATER; MV-09-9, 10, 11, 12 AUX. FEED ISOL. YES MV-09"13, 14 AUX. FEED X-TIE YES lO,Ilgwu'i, ICW: MV-21-2,3 ICW ISOL. YES MV"21-4A,4B ICW ISOL. YES l3,l lg MV-14-17, 18, 19,20 CCW:

MV"14" 9 4&

MV-14-1,2,3,4 FUEL POOL ISOL.

CONT.

CCW PUMP FAN ISOL.

ISOL.

YES YES YES C.S.: MV-07-1A,1B RWT ISOL. YES MV-07-2A,2B SUMP ISOL. YES MV-07-3,4 SYSTEM ISO YES HVAC: FCV-25-14 FCV-25-24,25 f~ CRECS CRECS ISOL.

ISOL.

fe lace YES YES i if II l7 (8 II".

FCV-25-11, 12 SBVS ISOL. YES FCV-25"35 VENT ISOL. YES FCV-25-29,34 H2 CONT. PURGE YES FCV" 25-30, 31 SFP EXHAUST YES FCV"25-32,33 SBVS INLET . YES ST. LUCIE - UNIT 2 3/4 8"19

, e,l t,l I

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AOMINISTRATIVE CONTROLS RESPONSIBILITIES (Conti nued)

k. Review of every unplanned onsite release of radioactive material to the environs including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Senior Vice president - Nuclear and to the Company Nuclear Review Board..

Review of changes to 'the PROCESS CONTROL PROGRAM and the OFFSITE OOSE CALCULATION MANUAL and RAOWASTE TREATMENT SYSTEMS.

Review and documentation of judgment concerning prolonged operation in bypass, channel trip, and/or repair of defective protection channels of process variables placed in bypass since the last FRG meeting.

AUTHOR ITY 6.5.1. 7 The Facility Review Group shall:

a. Recommend in writing to the- Plant Manager approval or disapproval of items considered under Specifications 6.5.1.6a. through d. and m.

above.

b. Render determinations in writing with regard to whether or not each item considered under Specifications 6.5.1.6 ove constitutes an unreviewed:.safety question. a., b, cL, ance e C. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Senior Vice President - Nuclear'nd.the" Company Nuclear. Review Board of disagreement between the'FRG,and;the:-Plant Manager; however.;.,the Plant Manager"shall have-responsibility for resolutipn of such disagreements pursuant to SpeCification 6.1.1 above.

ge lace RECOROS 6.5.1.8 The Facility Review Group. shall maintain written minutes of each FRG meeting that, at a minimum-,. document-the results of all FRG activities-.performed under the responsibility and authorfty provisions of these technical specifica-tions. Copies shall be provided~to the Senior Vice President - Nuclear."and the Chairman of the Company Nuclear. Review Board.

6.5.2 COMPANY NUCLEAR REVIEM BOARD'; CNRB FUNCTION 6.5.2.1 The Company Nuclear Review Board shall function to provide independent review and audit of designated actfvities fn the areas of:

a. nuclear power plant operations

b. nuclear engineering C. chemistry and radiochemistry

d. metallurgy ST. LUC IE - UNIT 2 6-9 Amendment No.M, 29

ek C

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ATTACHMENT 3 SAFETY ANALYSIS INTRODUCTION These amendments are submitted to make administrative changes to the St. Lucie Unit 1 and Unit 2 Technical Specifications and achieve consistency throughout the Technical Specifications by removing outdated material, making minor text changes, and correcting errors.

DISCUSSION W

The proposed amendments represent an administrative update to the St. Lucie Units 1 and 2 Technical Specifications. Each of the proposed changes are discussed below:

St. Lucie Unit 1

1) Item: Page 3/4 3-28 Action:

Add strong motion triaxial accelograph SMR-42-5, at location R.A.B. Elev. 19.5', with a range of 0-1 g, minimum channels operable 1, to Table 3.3-7.

Discussion:

This instrument has always existed and is not the result of a plant change or modification. SMR-42-5 is included in Technical Specification Table 4.3-4. Revision of this table will accurately reflect the current instrumentation in the plant.

2) Item: Page 3/4 3-42 Action:

Replace the total number of RCS Subcooling Margin Monitor channels with two (2), instead of the existing one (1) channel.

Discussion St Lucie Unit 1 License Amendment 79, issued April 10, 1987, added the Reactor Vessel Monitoring System to Table 3.3-11.

The Reactor Vessel Monitoring System is part of the Qualified Safety Parameter Display System (QSPDS). The QSPDS also includes the RCS Subcooling Margin Monitor. There are two channels of QSPDS at St Lucie Unit 1, therefore there are two channels of RCS Subcooling Margin Monitors. When Table 3.3-11 was revised as part of Amendment 79 the RCS Subcooling Margin Monitors were not revised. Revision of this table will accurately reflect the current instrumentation in the plant.

3) Item: Page 3/4 4-4 Action:

Correct Surveillance Requirement 4.4.4 by adding a "2" to the reference. The correct reference is 4.8.1.1.2.

Discussion:

St Lucie Unit 1 License Amendment 103, issued June 12, 1990, revised the "Electrical Power Systems A. C. Sources" section of the Technical Specifications. In this amendment, the diesel generator surveillance requirements and associated numbers were revised. Surveillance Requirement 4.4.4 was not revised during this amendment. This revision will reference the correct surveillance requirement.

4) Item: Pages 3/4 8-1, 8-2, & 8-3 Action:

Capitalize the word "OPERABILITY" on pages 8-1 and 8-3.

Capitalize the "S" in the word "Statement" on page 8-2.

Discussion:

St. Lucie Unit 1 License Amendment 103, issued June 12, 1990, revised the "Electrical Power Systems A. C. Sources" section of, the Technical Specifications. This amendment was issued with the typographical errors mentioned above. This revision will standardize the use of capitalization throughout this section.

~

l 0

5) Item: Page 3/4 8-4 Action:

Add the word "Local" to the diesel generator start option for J

the Diesel Generator surveillance.

Discussion:

St. Lucie Unit 1 License Amendment 103, issued June 12, 1990, revised the "Electrical Power Systems A. C. Sources" section of the Technical Specifications. This revision allowed for warmup and slow acceleration of the diesel generator for certain surveillance requirements.

During the revision of St. Lucie Emergency Operating Procedures, the meaning of the words "manual" and "local" were delineated using the guidance given in CEN 152, Emergency Procedure Guidelines, revision 3. Manual means to operate equipment remote from its physical location, which is normally performed from the Control Room. Local means to operate equipment at its physical location. A warm up and slow acceleration of the diesel generator can, only be accomplished by starting the diesel locally. It is necessary to add the "Local" option to the Technical Specifications to avoid confu sing the operators with inconsistent terminology.

6) Item: Page 3/4 8-6a Action:

Add "with" to the sentence noted on this page.

Discussion:

The additional word <<with" corrects the sentence grammatically.

7) Item: Page 3/4 8-6b Action:

Correct misspellings of "Specification" and "information."

Discussion:

None.

~ $ A.

8) Item: Page 3/4 10-2 Action:

Delete 3.1.3.2 as referenced in Technical Specifications 4.10.2.1 and 4.10.2.2.

Discussion:

St Lucie Unit 1 License Amendment 27, issued May 26, 1978 approved the removal of Part-length control element

,assemblies. TS 3.1.3.2 was deleted at this time.

9) Item: Page 6-8 Action:

Replace "a through e" with "a, b, d, and e."

Discussion:

Technical Specification 6.5.1.7b. in the St. Lucie Unit 1 Technical Specifications require the Facility Review Group to render in writing with regard to whether or not items considered under Specifications 6.5.1.6a through e constitute unreviewed safety questions. Specification 6.5.1.6c is:

c. Review of all proposed changes-to Appendix A Technical Specifications.

In accordance with Title 10 CFR 50.59(a)(2), a proposed change, test, or experiment is deemed to involve an unreviewed safety question:

(i) if the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased; or (ii) if a possibility, for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created; or if (iii) the margin of safety as defined in the basis for any technical specification is reduced.

As a result, an unreviewed safety question is applicable only to changes to the facility, tests, or experiments.

Title 10 CFR 50.59 (a)(1) specifically excludes changes to the Technical Specifications from being considered under Title 10 CFR 50.59. Changes to the Technical Specifications must be proposed by a licensee in accordance with Title 10 CFR 50.90.

These criteria do not include determination relative to unreviewed safety questions.

In light of the above, the requirement that the Facility Review Group render a determination in writing as to whether or not a proposed change to the Appendix A Technical Specifications involves an unreviewed safety question is inconsistent with the definition,of unreviewed safety question as well as the criteria used by the NRC to review proposed changes to the Technical Specifications. As a result, the reference to Specification 6.5.1.6c. should be deleted from Specification 6.5.1.7b.

~ ~ )

0

s~. Lucie Unit 2 Item: Page XXI Action:

For Figure 3.1-1, delete "AND TEMPERATURE" from title.

For Figure 4.2-1, replace title with "DELETED".

For Figure 3.4-2, replace "0 to 2 YEARS OF FULL POWER OPERATION" with "15 EFPY, HEATUP AND CORE CRITICAL" in the title and add "a" to the page reference.

Discussion:

The index was not updated when the figures were amended.

The intent of this change is to correct the index.

Figure .3.1-1 was updated by amendment ¹40 dated 3/13/89.

Figure 4.2-1 was deleted by amendment ¹17 dated 3/5/87.

Figure 3.4-2 was updated by amendment ¹46 dated 8/1/90.

2) Item: Page XXII Action:

For Figure 3.4-3, replace "2 TO 10 YEARS OF FULL POWER OPERATION" with "15 EFPY, COOLDOWN AND INSERVICE TEST" and replace page "32" with "31b".

For Figure 3.4-4, replace "10 TO 40 YEARS OF FULL POWER OPERATION" wi'th "15 EFPYg MAXIMUM ALLOWABLE COOLDOWN RATES" and replace page "33" with "32".

For Figure B 3/4.4-1, add "FOR REACTOR VESSEL BELTLINE MATERIALS" to the title.

Insert Figure "5.6-1 INITIAL ENRICHMENT VS. BURNUP REQUIREMENTS FOR STORAGE OF FUEL ASSEMBLIES IN REGION II.-....

5-4A" to the index.

Discussion:

The index was not updated when the figures were amended.

The intent of this change is to correct the index.

Figure 3.4-3 was updated by amendment ¹46 dated '8/1/90.

Figure 3.4-4 was updated by amendment ¹46 dated 8/1/90.

Figure B 3/4.4-1 was updated by amendment ¹31 dated 6/14/88.

Figure 5.6-1 was added by amendment ¹7 dated 10/16/84.

I 0

3) Item: Page XXIV Action:

For Table 4.4-5, replace page "34" with "33".

Insert Table "3.4-3 LOW TEMPERATURE RCS OVERPRESSURE PROTECTION RANGE ...... 3/4 4-37a".

Insert Table "3.4-4 MINIMUM COLD LEG TEMPERATURE FOR PORV USE FOR LTOP ...... 3/4 4.37a Discussion:

The index was not updated when the tables were amended.

The intent of this change is to correct the index.

Table 4.4-5 was updated by amendment f31 dated 6/14/88.

Table 3.4-3 was added by amendment f31 dated 6/14/88.

Table .3.4-4 was added by amendment f31 dated 6/14/88.

4) Item: Page XXV Action:

For Tables 3.7-3a and 3.7-3b replace "SAFETY RELATED HYDRAULIC SNUBBERS" with "DELETED".

Discussion:

The index was not updated when the tables were deleted.

The intent of this change is to correct the index.

Table 3.7-3a and 3.7-3b were deleted by amendment f22 dated 7/27/87.

5) Item: Page 3/4 6-21 Action:

Delete "HC" from "HCV" on valves 2516 and 2522, leaving the valve tag number as I-V-2516 and I-V-2522.

Discussion:

This change will correct the valve tag numbers for these two valves as they exist in the plant.

K Item: Page 3/4 8-4 Action:

Add the word "Local" to the diesel generator start option for this surveillance.

Discussion:

St. Lucie Unit 2 License Amendment 39, issued February 9, 1989, revised the "Electrical Power Systems A. C. Sources" section of the Technical Specifications. This revision allowed for warmup and slow acceleration of the diesel generator for certain surveillance requirements.

During the revision of St. Lucie Emergency Operating Procedures, the meaning of the words "manual" and "local" were delineated using the guidance given in CEN 152, Emergency Procedure Guidelines, revision 3. Manual means to operate equipment remote from its physical location, which is normally performed from the Control Room. Local means to operate equipment at its physical location. A warm up and slow acceleration of the diesel generator can only be accomplished by starting the diesel locally. It is necessary to add the "Local" option to the Technical Specifications to avoid confusing the operators with inconsistent terminology.

Item: Page 3/4 8-18 Action:

Replace "-3645" with ",25,35,45".

Replace "-3616" with ",26,36,46".

Replace "-3647" with 't~27~37~47tr Replace "-3644" with ",24,34,44".

Discussion:

This change will make the format of listing multiple valves consistent with those in the rest of the table.

Item: Page 3/4 8-19 Action:

Replace TO 16 with g 10 1 1 12 13 14 15 16 g g g g g g ~

Replace "TO 19" with ",15,16,17,18,19".

Discussion:

This change will make the format of listing multiple valves consistent with those in the rest of the table.

Item: Page 6-9 Action:

Replace "a through e" with "a,b,d, and e" Discussion:

Technical Specification 6.5.1.7b. in the St. Lucie Unit 2 Technical Specifications require the Facility Review Group to render in writing with regard to whether or not items considered under Specifications 6.5.1.6a through e constitute unreviewed safety questions. Specification 6.5.1.6c is:

'. Review of all proposed changes to Appendix A Technical Specifications.

In accordance with Title 10 CFR 50.59(a)(2), a proposed change, test, or experiment is deemed to involve an unreviewed safety question:

(i) if the probability of occurrence or the consequence of an accident or malfunction of equipment. important to safety previously evaluated in the safety analysis report may be increased; or (ii) if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created; or (iii) any if the margin of safety as defined in the basis for technical specification is reduced.

As a result, an unreviewed safety question is applicable only to changes to the facility, tests, or experiments. Title 10 CFR 50.59 (a)(1) specifically excludes changes to the Technical Specifications from being considered under Title 10 CFR 50.59. Changes to the Technical Specifications must be proposed by a licensee in accordance with Title 10 CFR 50.90.

These criteria do not include determination relative to unreviewed safety questions.

In light of the above, the requirement that the Facility Review Group render a determination in writing as to whether or not a proposed change to the Appendix A Technical Specifications involves an unreviewed safety question is inconsistent with the definition of unreviewed safety question as well as the criteria used by the NRC to review proposed changes to the Technical Specifications. As a result, the reference to Specification 6.5.1.6c. should be deleted from Specification 6.5.1.7b.

Ct e~~

ATTACHMENT 4 DETERMINATION OF NO SIGNIFICANT HAZARDS The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in 10 CFR 50.92 which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Each standard is discussed as follows:

(1) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The administrative changes do not affect assumptions contained in plant safety analyses, nor do they affect Technical Specifications that preserve safety analysis assumptions. Therefore, the proposed changes do not affect the probability or consequences of accidents previously analyzed.

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

A new or different kind of accident is not created since Technical Specification Limiting Conditions for Operation (LCO) and ACTION statement requirements remain unchanged.

The administrative changes being proposed by FPL will not lead to material procedure changes or to physical modifications to St. Lucie Plant. Therefore, the proposed changes do not create the possibility of a new or different kind of accident.

(3) Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The changes being proposed do not relate to or modify the safety margins defined in and maintained by the Technical Specifications. Therefore, the proposed changes would not involve any reduction in a margin of safety.

Based "'on the above, we have determined that the amendment request does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety; and therefore does not involve a significant hazards consideration.