Text

License Amendment to Allow Risk Informed Completion Times (RICT) for the 120-Volt AC Instrument Bus Requirements
	ML20356A162
Person / Time
Site:	Saint Lucie
Issue date:	12/21/2020
From:	Deboer D; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2020-164
	Download: ML20356A162 (36)
	v • d • e

DEC 2 1 *2020 L-2020-164 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn : Document Control Desk Washington D C 20555-0001 RE: St Lucie Nuclear Plant, Units 1 and 2 Docket Nos. 50-335 and 50-389 Renewed Facility Operating Licenses DPR-67 and NPF-16 License Amendment to Allow Risk Informed Completion Times (RICT) for the 120-Volt AC Instrument Bus Requirements

References:

1. Florida Power & Light Company letter L-2014-242 , Application to Adopt TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times- RITSTF Initiative 4B," December 5, 2014

((ADAMS Accession No. ML14353A016)

2. Florida Power & Light Company letter 2018-058, Fourth Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed Completion Times TSTF-505 , Revision 1, "Provide Risk-Informed Extended Completion Tunes- RITSTF Initiative 4b", March 15, 2018 (ADAMS Accession No. ML18074A116)

3. NRC letter to Florida Power & Light Company, St Lucie Plant, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 247 and 199 Regarding Adoption of Risk-Informed Completion Time in Technical Specifications (CAC Nos. MF5372 and MF5373; EPID L-2014-LLA-0001), July 2, 2019 (ADAMS Accession No. ML19113A099)

Pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests amendments to Renewed Facility Operating License Nos. DPR-67 and NPF-16 for St Lucie Nuclear Plant Units 1 and 2 (St Lucie), respectively . The proposed license amendments revise the St Lucie Operating Licenses (OL) and Technical Specifications (TS) to permit the application of risk-informed completion times (RICT) for the 120-Volt AC Instrument Bus requirements, consistent with TSTF-505 , Revision 2, "Provide Risk-Informed Extended Completion Times RITSTF Initiative 4b". The NRC provided a model safety evaluation for TSTF-505, Revision 2, on November 21 , 2018 (ADAMS Accession No. ML18253A085). The original availability of the TS improvement was recorded in the Federal Register on March 15, 2012 (77 FR 15399).

In Reference 1, as supplemented by FPL letters dated July 8 and July 22, 2016; February 15, 2017; and February 1, March 15, June 7, September 18, November 9, and November 30, 2018, respectively, FPL requested license amendments permitting the use of RICT for select St Lucie TS requirements. In Reference 2, FPL withdrew its request to apply RICT to the Onsite Electrical Distribution System requirements , which include the 120-volt AC Instrument Bus System requirements. In Reference 3, the NRC issued Amendments 247 and 199 authorizing the application of RICT for the remaining requested TS requirements based, in part, on the technical adequacy of the St Lucie probabilistic risk assessment (PRA) and the philosophy of maintaining defense in depth and safety margins in the RICT calculations, consistent with Regulatory Guide 1.177, An Approach for Plant-Specific, Risk-Informed Decision-making - Technical Specifications (ADAMS Accession No. ML100910008). FPL now proposes to apply these same RICT program conditions and limitations to the 120-volt AC Instrument Bus System requirements.

The enclosure to this letter provides FPL's evaluation of the proposed license consistent with the NRC's model application for TSTF-505, Revision 2 and the supplemental information requested in Reference 2. to the enclosure provides the St Lucie Unit 1 TS pages marked up to show the proposed changes. Attachment 2 provides the St Lucie Unit 2 TS pages marked up to show the proposed changes .

St. Lu cie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Pag e 2 of 2 Attachment 3 provides the St. Lucie Unit 1 TS Bases pages marked up to show the proposed changes.

Attachment 4 provides the St. Lucie Unit 2 TS Bases pages marked up to show the proposed changes.

The TS Bases changes are provided for information only and will be incorporated in accordance with the St. Lucie TS Bases Control Program upon implementation of the approved license amendments.

FPL has determined that the proposed license amendment does not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and that there are no significant environmental impacts associated with the proposed changes. The St. Lucie Plant Onsite Review Group (ORG) has reviewed the proposed license amendment. In accordance with 10 CFR 50.91 (b)(1 ), a copy of the license amendment request is being forwarded to the State designee for the State of Florida.

FPL requests that the proposed license amendment is processed as a normal license amendment request ,

with approval within one year of the submittal date. Once approved , the amendment shall be implemented within 90 days.

This letter contains no new regulatory commitments .

Should you have any questions regarding this submittal , please contact Mr. Wyatt Gades, St. Lucie Licensing Manager, at (772) 467-7435.

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

Executed on DEC 2 1 2020 Sincerely,

{)J1Ja~

Daniel D. DeBoer Site Vice President, St. Lucie Nuclear Plant Florida Power & Light Enclosure Attachments cc: USNRC Regional Administrator, Region II USN RC Project Manager, St. Lucie Nuclear Plant, Units 1 and 2 USNRC Senior Resident Inspector, St. Lucie Nuclear Plant, Units 1 and 2 Ms. Cindy Becker, Florida Department of Health

St. Lu cie Nuclear Plant, Units 1 and 2 L-2 02 0-164 Docket Nos . 50-335 and 50-389 Enclosure Pag e 1 of 34 ENCLOSURE Evaluation of the Proposed Changes St. Lucie Nuclear Plant Unit 1 and 2 License Amendment to Allow Risk Informed Completion Times (RICT) for the 120-Volt AC Instrument Bus Requirements

1.0 DESCRIPTION

..... ..... .. .... ........... ..... .... ............ .. ... ..... ..... .. .. .... ....... ........... .. ......... ...... .. ..... ... .. .... ....... 2 2.0 ASSESS MENT .. .. .. .... ... .. .. .. .. ......... ... .. .. ........... ......... .... .. .. ... ........ ........... ....... ....... ... .... .... .. .. ... .. ....... 2 2.1 Current Requirements I Proposed Changes ..... .. .. ... ... ....... .... ...... ... .... ....... ........... ..... .. ...... . 2 2.2 Model Application Elements .. ... .......... .. ... .... ........ ... .... ... .. ..... .... ...... ..... ....... ... ....... ... ....... ..... 3 2.3 TSTF-505 Model Application Enclosure Updates .... .. .. .. ... ... .. .. .. ..... .. ...... ......... ... ... ... ... ........ 6 2.4 Responses to Previous Requests for Additional Information .. ... ... .. .. ... ...... ... ... .... ..... ... ....... 8 2.5 Additional Considerations .. .. .. .. ... ..... ... ... .. .. .. ........... ... ........ ........ ...... ... ........ ....... ..... .... ... .. .. 12

3.0 REGULATORY EVALUATION

.... ...... ... ... .... .. ...... .... ... ..... .. ..... .... ... ... ....... .... ...... ......... ... ...... ... .... .. 14 3.1 Applicable Regulatory Requirements/Criteria ........ ... .... .... ... .. .. ... .. ........ ........ ..... .... ............ 14 3.2 No Significant Hazards Consideration .. ..... ...... .......... ................ .. ... .. .... ..... .. .. ..... .. .... .. ... .... 15 3.3 Conclusion .. .. .. .... ........ ..... ... .... .... ... .. ... ... .... .... ....... ..... .... ... ...... .. .... ...... ... .... .... ....... ... ... ....... 16

4.0 ENVIRONMENTAL CONSIDERATION

.... ... ... .. .. ... .................... ...... .... .... .. .... ... ... .. ... ............... .... . 17

5.0 REFERENCES

.. ..... .... ......... ... ......... ... .. ... ................... ... ........ ........ .. .. .. .... .... .. .. ...... .... .. .. .. ...... ..... ... . 17 - St. Lucie Un it 1 Technical Specification Pages (markup) ... ... ... ... .............. ... . ......... .19 - St. Lucie Unit 2 Technical Specification Pages (markup) ... ... ... .. .. .. ... ... ... .. ... ... .... .... 23 - St. Lucie Unit 1 Technical Specification Bases Pages (markup) .... .. ......... .. .... .. .... ... ... 27 - St. Lucie Unit 2 Technical Specification Bases Pages (markup) ... ... .. .. ..... ... ...... ... ....31

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 2 of 34

1.0 DESCRIPTION

Pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests amendments to Renewed Facility Operating License (RFOLs) Nos. DPR-67 and NPF-16 for St.

Lucie Nuclear Plant Units 1 and 2 (St. Lucie), respectively . The proposed license amendments revise the St. Lucie Operating Licenses (OL) and Technical Specifications (TS) to permit the application of risk-informed completion times (RICT) for the 120-Volt AC Instrument Bus requirements, consistent with TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times RITSTF Initiative 4b" . The NRC provided a model safety evaluation for TSTF-505, Revision 2, on November 21 , 2018 (Reference 5.1). The original availability of the TS improvement was recorded in the Federal Register on March 15, 2012 (77 FR 15399).

In Reference 5.2, as supplemented by FPL letters dated July 8 and July 22, 2016; February 15, 2017; and February 1, March 15, June 7, September 18, November 9, and November 30, 2018 (References 5.3 through 5.11) respectively, FPL requested license amendments which authorize the use of a RICT program for select St. Lucie TS requirements. In Reference 5.7, FPL withdrew its request to apply RICT to the Onsite Electrical Distribution System requirements, which includes the 120-volt AC instrument bus system. In Reference 5.12, the NRC issued Amendments 247 and 199 for St. Lucie Un its 1 and 2, respectively , authorizing RICT for the remaining requested TS requirements. FPL now proposes to apply these same RICT program conditions and limitations to the 120-volt AC instrument bus system requirements. Accordingly, a response to the supplemental information requested in Reference 5.7 is included in this amendment request. The proposed license amendments are consistent with TSTF-505, Revision 2, and the methodology and controls for applying the RICT Program described in NEI 06-09-A, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0, (Reference 5.13). Adherence to NEI 06-09-A is required by the St. Lucie RICT Program and the technical adequacy of the St. Lucie probabilistic risk assessment (PRA) in accordance with Regulatory Guide (RG) 1.200 (Reference 5.14) and the three-tiered approach of RG 1.177 (Reference 5.15) have been established . As such, portions of this amendment request which address elements of the TSTF-505, Revision 2, model application regarding PRA adequacy and risk-based decision-making refer to the NRC safety evaluation accompanying Amendments 247 and 199. In addition, administrative changes are proposed to applicable license conditions of the St. Lucie RFOLs which authorize the use of the RICT Program for the 120-volt AC Instrument Bus System requirements .

2.0 ASS ESSMENT 2.1 Current Requirements I Proposed Changes 2.1.1 Unit 1 License Condition 'J'

License Condition 'J' of St. Lucie Unit 1, RFOL DPR-67, authorizes FPL to implement the RICT program approved in License Amendment No. 247, subject to the two listed conditions. The first listed condition specifies activities to be completed prior to implementing the RICT program. The second listed cond ition specifies methods acceptable to the NRC for implementing the RICT program.

The proposed change adds the amendment resulting from this amendment request to the License Condition 'J' reference of approved license amendments.

The proposed change also deletes the first listed condition of License Condition 'J' specifying activities to be completed prior to implementing the RICT program .

2.1.2 Unit 1. TS 3.8.2.1. ACTION, for 120-Volt AC Instrument Electrical Susses

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 3 of 34

St. Lucie Unit 1, TS 3.8.2.1, ACTION, specifies requirements for less than the required complement of 4160-volt and 480-volt AC emergency electrical busses, and 120-volt AC instrument electrical busses specified in LCO 3.8.2 .1.

The proposed change enumerates the ACTION to become ACTION (a) and adds "emergency" to the description of the AC electrical busses in order to limit the applicability to only the (4160-volt and 480-volt AC) emergency electrical busses.

The proposed change creates new ACTION (b) for the condition of one AC instrument bus either not energized from its associated inverter or with the inverter not connected to its associated DC bus. New ACTION (b) requires reenergization of the affected instrument bus within 2-hours or in accordance with the RICT program, and reenergization of the instrument bus from its associated inverter connected to its DC bus within 24-hours or in accordance with the RICT program, if the bus is connected to its alternate AC power source.

2.1.3 Unit 2 License Condition 'O'

License Condition 'O' of St. Lucie Unit 2, RFOL NPF-16, authorizes FPL to implement the RICT program as approved in License Amendment No. 199, subject to the two listed conditions. The first listed condition specifies activities to be completed prior to implementing the RICT program. The second listed condition specifies methods acceptable to the NRC for implementing the RICT program.

The proposed change adds the amendment resulting from this amendment request to the License Condition 'O' reference of approved license amendments.

The proposed change also deletes the first listed condition of License Condition

'O' specifying activities to be completed prior to implementing the RICT program 2.1.4 Unit 2. TS 3.8.3.1, ACTION b. for 120-Volt AC Instrument Electrical Busses

St. Lucie Unit 2, TS 3.8.3.1, ACTION b, specifies requirements for one AC instrument bus either not energized from its associated inverter or with its inverter not connected to its associated DC bus. ACTION b requires re-energization of the affected instrument bus within 2-hours and re-energization of the instrument bus from its associated inverter connected to its associated DC bus within 24-hours, if the bus is connected to its alternate AC power source.

The proposed change authorizes the use of the RICT program to extend the 2-hour Allowable Outage Time (AOT) for re-energizing the affected instrument bus and the 24-hour AOT for restoring the associated inverter connected to its associated DC bus, respectively.

2.2 Model Application Elements 2.2.1 Applicability of Published Safety Evaluation FPL has reviewed TSTF-505, Revision 2, and the NRC's model safety evaluation dated November 21, 2018 (Reference 5.1). This review included information provided to support TSTF-505, Revision 2, and the safety evaluation for NEI 06-09-A (Reference 5.13) . As described in subsequent sections of this amendment request, FPL concludes that the technical basis presented in TSTF-505 , Revision 2, is applicable to St. Lucie 120-Volt AC instrument bus requirements and supports the incorporation of this amendment in the St. Lucie TS.

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclos ure Page 4 of 34 2.2.2 Verifications and Regulatory Commitments In accordance with Section 4.0, Limitations and Conditions , of the safety evaluation for NEI 06-09-A, FPL provided in Reference 5.2, as supplemented by References 5.3 through 5.11 , the following information to support the St. Lucie RICT Program :

1. Each of the TS Required Actions to which the RICT Program would apply, with a comparison of the TS functions to the functions modeled in the probabilistic risk assessment (PRA) of the structures, systems and components (SSCs) subject to those actions. The comparison is repeated below for the 120-Volt AC Instrument Bus system.

SS Cs Function SS Cs Design PRA TS LCO/ covered Covered modeled Success Success Disposition Condition by LCO/ by LCO/

in PRA Criteria Criteria Condition Condition 3.8.2.1 (Unit 1) 120V AC Yes Sufficient Align to Align to SS Cs 3.8.3.1(Unit2) Instrument power for provide provide modeled Onsite Power Buss es safe power to power to consistent Distribution shutdown busses busses with TS Systems and scope and mitigation can be and directly control of evaluated accident using conditions CRMP.

The success criteria in the PRA are consistent with the design basis criteria.

2. A discussion of the results of peer reviews and self-assessments conducted for the plant-specific PRA models which support the St. Lucie RICT Program, as required by Regulatory Guide (RG) 1.200 Section 4.2.

3. FPL did not provide a description of all PRA models used to support the St.

Lucie RICT Program since each PRA model for the RICT Program was based on an NRC endorsed standard .

4. Appropriate justification for excluding sources of risk not addressed by the PRA models.

5. The plant-specific baseline CDF and LERF to confirm that the potential risk increases allowed under the RICT Program are acceptable.

St. Lucie Nuclea r Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 5 of 34

6. FPL did not provide a plant-specific justification for using at-power PRA models in shutdown since the RICT Program is not applied to the shutdown modes.

7. A discussion of the programs and procedures which assure the PRA models supporting the St. Lucie RICT Program are maintained consistent with the as-built, as-operated plant.

8. A description of how the baseline PRA model, which calculates average annual risk, is evaluated and modified for use in the Configuration Risk Management Program (CRMP) to assess real-time configuration risk, and a description of the CRMP scope and quality controls.

9. A discussion of how the key assumptions and sources of uncertainty in the PRA models were identified, and how their impact on the St. Lucie RICT Program was assessed and dispositioned .

10. A description of the implementing programs and procedures regarding the plant staff responsibilities for the St. Lucie RICT Program implementation ,

including risk management action (RMA) implementation .

11. A description of the implementation and monitoring program as described in NEI 06-09, Section 2.3.2, Step 7 (Reference 5.13) .

12. A description of the process to identify and provide RMAs.

2.2 .3 Optional Changes and Variations The proposed license amendments are consistent with TSTF-505, Revision 2,.

FPL is not proposing any changes, variations, or deviations from the TS changes described in the TSTF-505, Revision 2, or to the applicable parts of the NRC's model application for TSTF-505, Revision 2 (Reference 5.1). Only those required ACTIONs described in Section 2.1 of this amendment request are proposed for change, which does not include all modified ACTIONS in TSTF-505, Revision 2, and which does include some plant-specific TS changes that are not in TSTF-505, Revision 2, but are necessary to facilitate the RICT program for the 120-volt AC instrument bus requirements. This includes administrative changes to the applicable license conditions of RFOLs DPR-67 and NPF-16 for St Lucie Units 1 and 2, respectively. A summary of the changes follows:

As described in Section 2.1 of this amendment request, changes to RFOLs DPR-67 and NPF-16 for St Lucie Unit 1 and Unit 2, respectively, are necessary to implement the RICT program for the 120-volt AC instrument bus system requirements and eliminate one-time license condition requirements relating to RICT program implementation that were completed. The proposed changes are administrative, do not change the RICT program methodologies currently authorized and do not contravene the conclusions in the NRC's model safety evaluation for TSTF-505, Revision 2 (Reference 5.1).

As described in Section 2.1, in order to implement the RICT program for the 120-volt AC instrument bus system requirements at St. Lucie Unit 1, it is necessary to add a new TS ACTION where one does not currently exist for the condition of an inoperable 120-volt AC instrument bus. The proposed change limits the applicability of the existing ACTION to only the 4160-volt and 480-volt AC emergency busses and creates a new ACTION for the condition

St. Lu cie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos . 50-335 and 50-389 Enclosure Page 6 of 34 of one 120-volt AC instrument bus either not energized from its associated inverter or with the inverter not connected to its associated DC bus. The proposed change is conservative since it adds a more restrictive requirement to reenergize the affected AC instrument bus within two hours in lieu of the 8-hours allotted by the current ACTION to restore operability. Likewise, the proposed 24-hours to reenergize the affected 120-volt AC instrument bus from its inverter connected to its DC power supply is not a relaxation of the current ACTION to restore operability within 8-hours since the instrument bus would be reenergized with in two hours using its associated alternative AC power source and fully capable of performing its function thereafter. Applying the RICT program to the proposed 2-hour and 24-hour Completion Times of new ACTION (b) is reasonable since the application is consistent with TS 3.8.7, ACTION A, for an inoperable inverter, and TS 3.8.9, ACTION B, for an inoperable AC vital bus, as provided in TSTF-505, Revision 2, for the Combustion Engineering Standard Technical Specifications (STS).

The St. Lucie TS utilize a different numbering system and a non-tabular format compared to the STS on which TSTF-505, Revision 2, is based. These differences are administrative and do not affect the applicability of TSTF-505, Revision 2, to the St. Lucie TS and do not contravene the conclusions in the NRC's model safety evaluation for TSTF-505, Revision 2 (Reference 5.1).

2.3 TSTF-505 Model Application Enclosure Updates During an August 6, 2020, TSTF/NRC quarterly public meeting, the TSTF and NRC discussed requirements for adding new RICTs to the plant TS for licensees having previously adopted TSTF-505. With regards to the proposed amendments, the following table reflects the model application enclosures recommended for consideration by the NRC and the NEI Risk-Informed Technical Specification Task Force (RITSTF) when proposing new RICTs permitted by TSTS-505, Revision 2.

Enclosure Title Applicability to New RICT 1 List of Revised PRA functionality is not applicable to RICT. Unit 1 TS Required does not currently include specific actions similar to Actions to Unit 2, but per this LAR application, Unit 1 actions is Corresponding intended to be identical to that of Unit 2.

PRA Functions Unit 2 TS 3.8.3.1 .b action subject to this application will read : " With one A.G. Instrument Bus either not energized from its associated inverter, or with the inverter not connected to its associated D.C. Bus: (1) re-energize the A. C. Instrument Bus within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or in accordance with the Risk Informed Completion Time Program, 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 and (2) re-energize the A. C.

Instrument Bus from its associated inverter connected to its associated D. C. Bus within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or in accordance with the Risk Informed Completion Time Program, 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

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 7 of 34 Enclosure Title Applicability to New RICT 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 enterinq HOT SHUTDOWN."

2 Information With the latest PWROG independent certification of Supporting F&O closure (Reference 5.17), the PRA model quality Consistency with is consistent with RG -1.200 Revision 2.

Regulatory Guide 1.200, Revision 2 3 Information This enclosure is not applicable. PRA quality is Supporting developed in accordance with ASME PRA Standard as Technical endorsed by RG-1 .200, Revision 2 (Reference 5.14) .

Adequacy of PRA Models Without PRA Standards Endorsed by Regulatory Guide 1.200, Revision 2 4 Information Sources of risk not addressed by the PRA models have Supporting not changed by the added RICT. Original information Justification of provided in the original TSTF-505 application, as Excluding supplemented, is applicable to the added RICT.

Sources of Risk Not Addressed by the PRA Models 5 Baseline CDF Baseline values used for RICT evaluation :

and LERF Unit 1:

CDF = 5.24E-05 per year LERF= 8.32E-06 per year Unit 2:

CDF = 3.74E-05 per year LERF= 6.48E-06 per year 6 Justification of This enclosure is not applicable. This application does Application of At- not request to use RICTs in shutdown modes.

Power PRA Models to Shutdown Modes.

7 PRA Model The information provided in this enclosure did not Update Process. change since it was approved by the original TSTF-505 application and is not affected by the added RICT.

8 Attributes of the This enclosure is not required . The addition of the new Real-Time RICT does not affect the real-time model.

Model.

St. Lucie Nuclear Plant, Units 1 and 2 L-202 0-164 Docket Nos. 50-335 an d 50-389 Enclos ure Page 8 of 34 Enclosure Title Applicability to New RICT 9 Key The information provided in this enclosure that was Assumptions approved by the original TSTF-505 application was not and Sources of changed or impacted by the added RICT.

Uncertaintv.

10 Program This enclosure is not required. The addition of the new Implementation RICT does not change the program implementation.

11 Monitoring This enclosure is not required . The addition of the new Program RICT does not change the monitoring program.

12 Risk The general RMAs provided as part of the original Management TSTF-505 application that was approved are typically Action Examples applicable to this new RICT. Specific RMAs associated Could have with the specific configuration in which this new RICT some additional is applicable is dependent on the specific equipment RMAs being inoperable or out of service. However, the specific RMAs are centered around protecting and guarding the inverters on the opposite train, stopping work on any other instrument channels, ensuring minimum stay with the aligned configuration, and use of procedural adherence to minimize risk .

2.4 Responses to Previous Requests for Additional Information In Reference 5.7, FPL withdrew its request to apply the RICT program to the Onsite Electrical Distribution System requirements, which includes the 120-volt AC instrument bus system. The decision to withdraw was preceded by a request for additional information (RAI) from the NRC's Electrical Engineering Operating Reactors Branch (EEOB) . To support the proposed license amendments for the 120-volt Instrument Bus System, the EEOB RAls are summarized below followed by FPL's response:

RAl-MF5372/MF5373-EEOB-01 What are Risk Managed Actions (RMAs) for the subject TS?

FPL Response:

The general RMAs provided as part of the original TSTF-505 application that was approved are typically applicable to this new RICT. Specific RMAs associated with the specific configuration in which this new RICT is applicable are dependent on the specific equipment being inoperable or out of service. However, the specific RMAs are centered around protecting and guarding the inverters on the opposite train, stopping work on any other instrument channels, ensuring minimum stay with the aligned configuration, and use of procedural adherence to minimize risk during the RICT.

RAl-MF5372/MF5373-EEOB-02:

Define design success criteria and clarify the minimum set of equipment needed to accomplish the safety function.

FPL Response:

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos . 50-335 an d 50-389 Enclosure Pag e 9 of 34 The success criteria for 120V AC Instrument bus system is having sufficient power for safe shutdown and mitigation and control of accident conditions. This includes having 3 out of 4 channels operable to support at-power operations and three vital AC panels each energized by its own inverter (for each unit) for the time specified by TS . The current TS allows one inverter to be inoperable for a maximum AOT of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months provided power to the affected instrument bus has been restored within 2-hours.

RAl-MF5372/MF5373-EEOB-03:

(This RAI was not relevant to the 120-volt Instrument Bus System . No response is provided.)

RAl -MF5372/MF5373-EEOB-04:

Provide the estimated RICT values in hours.

FPL Response:

TS/LCO Estimated Description Action RICT (Hrs.)

3.8.3.1 .b (1) One 120V AC instrument bus either not energized from 720 its associated inverter or with the inverter not connected to its associated DC bus.

3.8.3.1.b (2) Reenergization of the instrument bus from its associated 720 inverter connected to its DC bus.

RAl -MF5372/MF5373-EEOB-05:

3.8.2. 1 Action Less than the complement of A. C. busses OPERABLE (undesignated) (One or more AC electrical busses inoperable)

I A. For the above TS condition 's lowest estimated RICT (least amount of time available, calculated beyond the front-stop) :

a. Describe a scenario/plant configuration for this condition.

b. Explain how each bus would retain the ability to defend against vulnerabilities during this scenario (e.g., examples of RMAs to assure a reasonable balance of defense-in-depth is maintained for this TS condition) .

FPL Response:

a. The configuration is considered with a baseline alignment and one inverter is considered inoperable or becomes out of service.

The top-10 CDF dominant scenarios for this configuration include the following:

1. Fire initiator in the Main Control Board RTGB 103

2. Seismic plant-level penalty.

3. Fire initiator in the cable Spreading Room .

4. Fire initiator in PC-83

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 10 of 34

5. Fire initiator associated with MCR abandonment scenario impacting fire Areas 36, 37, and 39.

6. Fire initiator in the main hallway at El. -0.5', impacting RCPs cables

7. Fire initiator in CEDM Panel 12 through 18 and failure of AFW MOV MV-09-10 to open .

8. Fire initiator in cable tray C17 and failure of AFW MOV MV-09-10 to open.

9. Fire initiator in Manhole 155 and failure of AFW MOV MV-09-9 to open.

10. Fire initiator in 480V AC MCC 1A5 and failure of AFW MOV MV-09-10 to open.

The top-10 LERF dominant scenarios for this configuration includes the following:

1. Fire initiator in the Main Control Board RTGB 103, Containment fails early -

H2 burn at 50% oxidation, no Pl -SGTR, RCS depressurized .

2. Fire initiator in the cable Spreading Room, Containment fails early - H2 burn at 50% oxidation, no Pl-SGTR, RCS depressurized.

3. Fire initiator in PC-83, Containment fails early - H2 burn at 50% oxidation, no Pl -SGTR, RCS depressurized.

4. Seismic plant-level penalty.

5. Fire initiator in the Main Control Board RTGB 103, Pl -SGTR.

6. Fire initiator in CEDM Panel 12 through 18 and failure of AFW MOV MV-09-10 to open, Containment fails early - H2 burn at 50% oxidation , no Pl -SGTR, RCS depressurized.

7. Fire initiator in cable tray C17 and failure of AFW MOV MV-09-10 to open, Containment fails early - H2 burn at 50% oxidation, no Pl-SGTR, RCS depressurized.

8. Fire initiator in Manhole 155 and failure of AFW MOV MV-09-9 to open, Containment fails early - H2 burn at 50% oxidation, no Pl-SGTR, RCS depressurized .

9. Flooding initiator at 1RAB19-45 due to CCW Spray, Operator fails to trip RCPs due to loss of CCW (seal LOCA scenario)

10. Fire initiator in 480V AC MCC 1A5 and failure of AFW MOV MV-09-10 to open, Containment fails early - H2 burn at 50% oxidation, no Pl-SGTR, RCS depressurized.

The top-10 CDF dominant scenarios for this configuration includes the following :

1. Fire initiator in FA-45 associated with OTC cable separation (201 through 204).

2. Fire initiator in cable tray C2328 concurrent with fire-induced spurious opening of MSIV "A.

3. Loss of 125VDC Bus 2B, 2A Inverter OOS, CCW N-HDR CIS VLVs Fail closed on Loss of DC PWR leading to loss of cooling to RCPs and potential SLOCA, Operator fails to trip RCPs on loss of CCW cooling, operator fails to establish SOC, operator fails to initiate sump recirculation after LOCA and auto switchover fails .

4. Seismic plant-level penalty.

5. Main Control Room Abandonment Scenario (impacting 2_18, 2_19,2_20) concurrent with fire-induced spurious opening of ADVs "A" train .

6. Main Control Room Abandonment Scenario (impacting 2_18, 2_19)

7. Main Control Room Abandonment Scenario (impacting 2_19, 2_20)

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 11 of 34

8. Main Control Room Abandonment Scenario (impacting 2_ 18, 2_20) ,

concurrent with failures of CCW HOR 2A flow FT-14-1A input and CCW HOR 28 flow FT-14-18 input due to fire.

9. Main Control Room Abandonment Scenario (impacting 2_51W).

10. Fire initiator in cable tray C2323 concurrent with operator failure to initiate sump recirculation after RCP seal LOCA & Auto switchover fails due to fire.

The top-10 LERF dominant scenarios for this configuration includes the following:

1. Fire initiator in FA-45 associated with OTC cable separation (201 through 204),

Containment fails early - H2 burn at 50% oxidation, no Pl-SGTR, RCS depressurized.

2. Fire initiator in cable tray C2328 concurrent with fire-induced spurious opening of MSIV "A", Containment fails early- H2 burn at 50% oxidation, no Pl-SGTR, RCS depressurized .

3. Main Control Room Abandonment Scenario (impacting 2_18, 2_19,2_20) concurrent with fire-induced spurious opening of ADVs "A" train, Containment fails early - H2 burn at 50% oxidation, no Pl-SGTR, RCS depressurized.

4. Seismic plant-level penalty.

5. Fire initiator in FA-45 associated with OTC cable separation (201 through 204),

Containment fails early - steam explosion or OCH .

6. Main Control Room Abandonment Scenario (impacting 2_51W), Containment fails early - H2 burn at 50% oxidation, no Pl-SGTR, RCS depressurized.

7. Fire initiator in FA-45 associated with OTC cable separation (201 through 204),

Seals of fuel transfer tube fails.

8. Fire initiator in FA-45 associated with OTC cable separation (201 through 204),

Containment fails early- H2 burn at 50% oxidation, no Pl-SGTR, no Tl-SGTR, no RCS depressurized, het leg failure prior to VB given no Tl-SGTR.

9. Fire initiator in FA-45 associated with OTC cable separation (201 through 204),

Containment isolation check valveV181270 transfers open.

10. Fire initiator in FA-45 associated with OTC cable separation (201 through 204),

Pressure-Induced SGTR (Pl-SGTR).

b. As soon as the inverter is OOS , the operator has a total of 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months as lowest estimated RICT, including 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months front stop, to reconnect the bus to its alternate 480V AC MCC power source. During the outage of the inverter, the 3 remaining 120V AC instrument buses are fully functional with a loss of one tripped channel.

This configuration does not satisfy the 2 out of 4 channel input to RPS, ESFAS, or AFAS systems . The reactor remains operational.

RAl-MF5372/MF5373-EEOB-05, continued:

B. For the above TS condition's highest estimated RICT (most risk significant component(s) that would result in a calculation close to the 30-day back-stop, without Probabilistic Risk Assessment (PRA) functional consideration):

a. Describe a scenario/plant configuration for this condition.

b. Explain how each bus would retain the ability to defend against vulnerabilities during this scenario (e.g., examples of RMAs to assure a reasonable balance of defense-in-depth is maintained for this TS condition) .

FPL Response:

St. Lucie Nuclear Plant, Units 1 an d 2 L-2020-'/64 Docket Nos . 50-335 and 50-389 Enclosure Page 12 of 34 Per the NRC's safety evaluation for Amendments 247 and 199 (Reference 5.12), the application of PRA functionality is not considered in the RICT application due to the safety function being met by the operable train . The RICT is applying the equipment operability definition as stated in the plant TS . Therefore, the configuration described under "A" section of this RA/ is considered with inoperable inverter with no PRA functionality applied. The configuration does not include lowest or highest estimated RICT. The estimated RICT has a back stop of 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months (30 days).

2.5 Additional Considerations During an October 20, 2020 public pre-submittal teleconference (Reference 5.16), the NRC raised additional considerations that should be addressed in this amendment request.

These are summarized below followed by FPL's response :

Provide previous LAR history, including PRA conclusions regarding quality, peer reviews, F&O 's, etc.

FPL Response:

The historical information regarding the issuance of Amendments 247 and 199 for St.

Lucie Units 1 and 2, respectively, including the conclusions about St. Lucie PRA technical adequacy, are discussed in Sections 1.0 and 2.2 of this amendment request.

Further, since the issuance of Amendments 247 and 199 (Reference 5.11 ), the St.

Lucie PRA models were certified by PWROG independent assessment (Reference 5.17) to approve closure of all F&Os generated by previous peer reviews and self-assessments except for the following 4 fire-related F&Os. Table X-1 below provides the currently open F&Os and assessment of their impact on this LAR submittal.

Table X-1 : PSL Open Peer Review F&Os.

Supporting Issue Evaluation Requirement CS-A3-01 4kV power and 125VDC control The SSCs identified by this cables required to support the F&Os and the control cables in operation of the Containment question have no relation with Spray Pump were not the 120V AC instrument buses.

identified. Fire PRA Plant There is no impact on this LAR Response model and other Fire submittal.

PRA support tasks are adversely affected. Perform a comparison of the Components identified on the MSO (multiple spurious operation) list against the Fire PRA components for which new cable selection was performed (i.e., components not previously identified on the Appendix R safe shutdown equipment list) . Verify that the cable selection for the common components supports all credited operations. Fire PRA

St. Lucie Nuclear Plant, Un its 1 and 2 L-2020-164 Docket Nos . 50-335 and 50-389 Enclosure Page 13 of 34 Table X-1: PSL Open Peer Review F&Os.

Supporting Issue Evaluation Requirement Plant Response model and other Fire PRA support tasks are adversely affected.

CS-81 -01 No evaluation was performed to 120V AC instrument buses are verify that the new components not considered new components and cables associated with the to be associated with the fire Fire PRA is bounded by the PRA. There is no impact on this existing overcurrent LAR submittal.

coordination analysis. The evaluation was not completed at this time.

SF-A1 -03 There was no assessment or St. Lucie location is considered review of the potential impact one of the lowest seismicity on a seismic event on the PSL locations in USA. Per NTTF Fire PRA for suppression, Recommendation 2.1, FPL procedure review, and fire submitted St. Lucie hazard brigade training . screening report via FPL letter L-2014-089, dated March 31, 2014. The report documented that St. Lucie performed seismic reevaluation in accordance with EPRI industry guidance and based upon the comparison of the existing Safe Shutdown Earthquake (SSE) response spectrum and the re-evaluated plant-specific Ground Motion Response Spectra (GMRS), St.

Lucie screened out of performing any additional analysis or evaluation.

Notwithstanding , FPL considered addition of plant-level seismic penalty to be applied in all RICT evaluations.

Clarify that the proposed ACTIONs do not result in loss of function.

FPL Response:

Consistent with TSTF-505, Revision 2, the St. Lucie RICT program cannot be applied to plant configurations resulting in a loss of function. St. Lucie RICT procedures explicitly prohibit the application of RICT for activities representing a loss of function or when all trains or subsystems of equipment required by the St. Lucie TS would be inoperable. Moreover, the St. Lucie RICT program requires continuous monitoring for conditions requiring an immediate exit from the extended RICT period as a result of an emergent equipment failure that creates a loss of function .

St. Lu cie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos . 50-335 and 50-389 En closure Page 14 of 34 Regarding the 120-volt AC instrument bus system requirements, the proposed changes do not affect the system's redundant features or system capability to withstand a single failure in the presence of an analyzed accident. The extended durations resulting from RICT program implementation are such that the likelihood of a coincident failure in the redundant train or subsystem is sufficiently low, consistent with the safety evaluation considerations of NEI 06-09-A and TSTF-505, Revision 2.

Determine if battery calculations are necessary to demonstrate safe shutdown capability during extended AOT.

FPL Response:

Safety-related batteries are sized for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for station blackout, i.e.no Emergency Diesel Generator (EOG) backup. For FLEX, with one train of batteries disconnected for extended single train power, the loads are powered for approximately 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The battery chargers, which support the batteries that power the safety-related 120-volt AC instrument busses, can obtain power via isolimiters from safety-related motor control centers (MCCs), which are backed up by the EDGs. If the isolimiters and offsite power are lost, there will be an interruption of power. Should offsite power be lost, the EDGs are available and the battery chargers will maintain the charge to the batteries. Hence, no battery calculations are needed if the batteries are being charged by the battery chargers. If the 120VAC inverters are out of service and offsite power is lost, then the backup power from the MCCs will be lost to the associated instrumentation for approximately 10 seconds until EOG supplied power is available.

Provide design and licensing basis for the new St. Lucie Unit 1 TS ACTION FPL Response:

As discussed in Section 2.2.3 of this amendment request, in order apply the RICT program to the St. Lucie Unit 1 120-volt AC instrument bus system requirements, it is necessary to add a new ACTION where one does not currently exist. The proposed new ACTION (b) for St. Lucie Unit 1 TS 3.8.2.1 specifies requirements for the condition of one120-volt AC instrument bus either not energized from its associated inverter or with the inverter not connected to its associated DC bus. The proposed change is conservative since it adds a more restrictive requirement to reenergize the affected AC instrument bus, thereby restoring the capability to perform its safety function, within two hours in lieu of the current 8-hour requirement to restore operability. No changes are proposed to the design function of the 120-volt AC instrument bus system since the requested amendments do not change plant equipment or the manner in which equipment is maintained and controlled. Changes are proposed to the 120-volt AC instrument bus system licensing basis by imposing more restrictive requirements and applying the RICT program to the proposed 2-hour and 24-hour Completion Times.

Applying the RICT program to the proposed 2-hour and 24-hour Completion Times of new ACTION (b) is reasonable since it is consistent with TS 3.8.7, ACTION A, for an inoperable inverter, and TS 3.8.9, ACTION B, for an inoperable AC vital bus, as provided in TSTF-505, Revision 2, for the Combustion Engineering STS.

3.0 REGULATORY EVALUATION

3.1 Applicable Regulatory Requirements/Criteria

St. Lucie Nuclear Plant, Units 1 and 2 L-2 020-164 Docket Nos . 50-335 and 50-389 Enclosure Pag e 15 of 34

10 CFR 50.36(c)(2)(i) states that when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial Action permitted by the technical specifications until the condition can be met.

General Design Criteria (GDC) 17 of 10 CFR 50, Appendix A, states, in part, that an onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure . Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. (St. Lucie Unit 2 was licensed to GDC 17)

GDC 20of10 CFR 50, Appendix A, states that the protection system shall be designed (1) to initiate automatically the operation of appropriate systems to assure acceptable fuel design limits are not exceeded, sense accident conditions and initiate the operation of systems and components important to safety.

Regulatory Guide 1.174, Revision 1, describes a method acceptable to the NRC for determining whether the quality of the PRA, in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decision-making for light-water reactors .

Regulatory Guide 1.177 describes methods acceptable to the NRC staff for assessing the nature and impact of proposed TS changes by considering engineering issues and applying risk insights.

Regulatory Guide 1.200 describes one acceptable approach for determining whether the technical adequacy of the PRA, in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decision-making for light-water reactors .

The proposed change complies with the applicable regulatory requirements and does not alter the manner in which the facility is operated and maintained, consistent with GDCs 17 and 20 of 10 CFR 50 Appendix A, and RGs 1.174, 1.177 and 1.200, as applicable. All applicable requirements will continue to be satisfied as a result of the proposed license amendments.

3.2 No Significant Hazards Consideration The proposed license amendments revise the St. Lucie Operating Licenses (OL) and Technical Specifications (TS) to permit the application of risk-informed completion times (RICT) for the 120-Volt AC Instrument Bus requirements, consistent with TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times RITSTF Initiative 4b". As required by 10 CFR 50.91 (a), FPL has evaluated the proposed changes using the criteria in 10 CFR 50.92 and determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards' consideration is presented below:

(1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

St. Lucie Nuclear Plant, Un its 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 16 of 34 Response: No The proposed change permits the extension of Completion Times for the 120-Volt AC Instrument Bus requirements provided the associated risk is assessed and managed in accordance with the NRC approved RICT Program. The proposed change does not involve a significant increase in the probability of an accident previously evaluated since the change involves no change to the plant or its modes of operation . The proposed change does not increase the consequences of an accident since the design-basis mitigation function of the affected systems is not changed and the consequences of an accident during the extended Completion Time are no different from those during the existing Completion Time.

Therefore, the proposed license amendments would not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not change the design, configuration, or method of operation of the plant. The proposed change does not involve a physical alteration of the plant since no new or different kind of equipment will be installed.

Therefore, the proposed license amendments would not create the possibility of a new or different kind of accident from any previously evaluated.

(3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change permits the extension of Completion Times for the 120-Volt AC Instrument Bus requirements provided the associated risk is assessed and managed in accordance with the NRC approved RICT Program. The proposed change implements a risk-informed configuration management program to assure margins to safety are maintained. Application of these new specifications and the configuration management program considers the cumulative effects of multiple inoperable systems or components more effectively than the current TS.

Therefore, the proposed license amendment would not involve a significant reduction in the margin of safety.

Based upon the above analysis, FPL concludes that the proposed amendments do not involve a 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.

3.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

St. Lu cie Nuclear Plant, Units 1 and 2 L-2 020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 17 of 34

4.0 ENVIRONMENTAL CONSIDERATION

Florida Power & Light Company (FPL) has reviewed the environmental evaluation included in the model safety evaluation provided on November 21 , 2018 (ADAMS Accession No. ML18253A085).

FPL has concluded that the NRC staff findings presented in that evaluation are applicable to St.

Lucie Unit 1 and Unit 2. The proposed change amendment modifies a regulatory 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 effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed license amendment 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.

5.0 REFERENCES

5.1 NRC Letter to Technical Specifications Task Force, Final Revised Model Safety Evaluation of Traveler TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times -

RITSTF Initiative 48", November 21, 2018 (ADAMS Accession Nos. ML18253A085 and ML18267A259) 5.2 Florida Power & Light Company letter L-2014-242, Application to Adopt TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48,"

December 5, 2014 ((ADAMS Accession No. ML14353A016) 5.3 Florida Power & Light Company letter L-2016-114, Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, 'Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48,' "July 8, 2016 (ADAMS Accession No. ML16193A659) 5.4 Florida Power & Light Company letter L-2016-135, Second Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505,

'Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48,' "July 22, 2016 (ADAMS Accession No. ML16208A061) 5.5 Florida Power & Light Company letter L-2017-006, Third Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times- RITSTF Initiative 4b'," February 1, 2018 (ADAMS Accession No. ML18032A614) 5.6 Florida Power & Light Company letter L-2017 -007 Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times- RITSTF Initiative 4b'," February 25, 2017 (ADAMS Accession No. ML17058A181)

5. 7 Florida Power & Light Company letter L-2018-058, Fourth Response to Request for Additional Information Regarding License Amendment Request to Adopt Risk Informed

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Pag e 18 of 34 Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times- RITSTF Initiative 4b", March 15, 2018 (ADAMS Accession No. ML18074A116) 5.8 Florida Power & Light Company letter L-2018-111, Second Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b", June 7, 2018 (ADAMS Accession No. ML18158A228) 5.9 Florida Power & Light Company letter L-2018-201, Third Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b", September 18, 2018, (ADAMS Accession No. ML18261A354) 5.10 Florida Power & Light Company letter L-2018-201 , Fourth Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b", November 9, 2018, (ADAMS Accession No. ML18316A030) 5.11 Florida Power & Light Company letter L-2018-215, Resubmittal of Fourth Supplement to License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b",

November 30, 2018 (ADAMS Accession No. ML18334A250) 5.12 NRG letter to Florida Power & Light Company, St. Lucie Plant, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 247 and 199 Regarding Adoption of Risk-Informed Completion Time in Technical Specifications (CAC Nos. MF5372 and MF5373; EPID L-2014-LLA-0001),

July 2, 2019 (ADAMS Accession No. ML19113A099) 5.13 NE! 06-09 0-A, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," May 2007 (ADAMS Accession No. ML12286A322) 5.14 Regulatory Guide 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, March 2009 (ADAMS Accession No. ML090410014) 5.15 Regulatory Guide 1.177, Revision 1, An Approach for Plant-Specific, Risk-Informed Decision-making: Technical Specifications, May 2011 (ADAMS Accession No. ML100910008) 5.16 Public Pre-submittal Teleconference with Florida Power & Light Company to Discuss a Proposed License Amendment Request for St. Lucie Plant, Unit Nos. 1 and 2, to Allow Risk-Informed Completion Times for Electrical Systems (ADAMS Accession No.

20282A587) 5.17 Pressurized Water Reactor Owners Group (PWROG) 19013-P, Revision 0, Independent Assessment of Facts & Observations Closure of the Plant St. Lucie Probabilistic Risk Assessment, Risk Management Committee, PA-RMSC-1673, June 2019 [Westinghouse Proprietary Class 2]

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 19 of 34 ATTACHMENT 1 ST. LUCIE UNIT 1 TECHNICAL SPECIFICATION PAGES (MARKUP)

(3 pages follow)

and 2XX J. FPL is authorized to approved in License implem ~e Amen~~n~~Mo.

Risk In armed Completion Time Program as 247 ubject to the following conditions:

1: ;11 FPL will complete _ti 1e follo.,ing prior to implementotion ol the Risi<

l~A-d-d-,-,---t-e_d_"~

0818 Informed Com!'let1on Time Program:

a. Tho items listed in tho table of implementation items in the enclosure to FPL letter L 2018 006, "Tnircl Response to Request for Additional Information Regarding License Amendment Request to /\dept Risk Informed Completion Times TSTF 505 , Revision 1,

'Pmvide Rislc Informed Extended Completion Tifl'les RITSTF Initiative 4b'," February 1, 2018 , end

b. Tne six iFl'lpleFl'lentation iteffls listed in Attachment 1 to FPL letter L 2018 201 , "Fourtn Supplcfflcnt to License Afflendfflcnt Request to Adopt Risk lnforrned Gornplction Tirnes TSTF §0§ , Revision 1,

'P1 ovide Risk-II 1fo1111ed Exte11ded Co111pletio11 Times RITSTF hiitiatiue 4b'," November 9, 2018.

2. The risk assessment approach and methods, shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant; and reflect the operating experience of the plant as specified in RG 1.200.

Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRC for generic use. If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRC approval via a license amendment.

4. This renewed license is effective as of the date of issuance and shall expire at midnight on March 1, 2036.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY J. E. Dyer, Director Office of Nuclear Reactor Regulation

Attachments:

1. Appendix A, Technical Specifications

2. Appendix B, Environmental Protection Plan Renewed License No. DPR-67 Amendment No. ~

Revised by letter dated July 2, 2019

ELECTRICAL POWER SYSTEMS 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPERA TING LIMITING CONDITION FOR OPERATION 3.8.2.1 The following A.C. 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 A.C. Instrument Bus 1MA 120 volt A.C. Instrument Bus 1MB 120 volt A.C. Instrument Bus 1MC 120 volt A.C. Instrument Bus 1MD APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

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

~ ,rlemergency 1 4 With less than the above complement of A.C."husses 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 .

Add "b." SURVEILLANCE REQUIREMENTS See INSERT 4.8.2.1 The specified A.C. busses shall be determined OPERABLE and energized from A.C.

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

ST. LUCIE - UNIT 1 3/4 8-8 Amendment No. ~. 249

INSERT

b. With one A.C. Instrument Bus either not energized from its associated inverter, or with the inverter not connected to its associated D.C. Bus: (1) re-energize the A.C. Instrument Bus within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or in accordance with the Risk Informed Completion Time Program, 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 and (2) re-energize the A.C. Instrument Bus from its associated inverter connected to its associated D.C. Bus within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or in accordance with the Risk Informed Completion Time Program, 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 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

St. Lu cie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos. 50-335 and 50-389 Enclosure Page 23 of 34 ATTACHMENT 2 ST. LUCIE UNIT 2 TECHNICAL SPECIFICATION PAGES (MARKUP)

(3 pages follow)

NRC dated December 9, 2003, and October 29, 2004, in response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 6.15.d, shall be within 36 months in a staggered test basis, plus the 138 days allowed by SR 4.0.2, as measured from November 13, 2006, which is the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

N. FATES38 Safety Analyses (Westinghouse Fuel Only)

FATES3B has been specifically approved for use for St. Lucie Unit 2 licensing basis analyses based on FPL maintaining the more restrictive operational/design radial power fall-off curve limits as specified in Attachment 4 to FPL Letter L-2012-121, dated March 31, 2012 as compared to the FATES38 analysis radial power fall-off curve limits. The radial power fall-off curve limits shall be verified each cycle as part of the R s ad Safety Analy ~ nd XX*st (RSAC) process.

2

0. FPL is authorized to implement t e Risk In armed Completion Time Program as approved in License Amendmen o. 199 ubject to the following conditions:

1. , 1' FPL will ~om~lete the fellO'Nin~ prior to implementation of tl"le Risi< Informed

~IA_d_d-,-,---t-e_d_"~~

0 8 18 Completion Time Pro~ram:

a. The items listeEI in tt:ie table of implementation items in tl"le eAelosure to FPL letter L 2018 006, "Tl"lire Response to Re1:1uest for AeeitioAal Information Re9ardin9 License AmenElment Request to AElopt Risk Informed Completion Times TSTF §0§ , Re*1ision 1, 'ProviEle Risk Informed Extended Completion Times RITSTF Initiative 4b',"

February 1, 2018 , and-

b. Tl"le six implementation ite111s listed ii 1Attacl 1111e11t 1 to FPL lette1 L 2018 201 , "rourtt:i Sup13lement to Lioense Amendment Request to Adopt Risk Informed Completion Times TSTF §0§ , Revision 1,

'Provide Risk Informed ~xtenEleel Com13letion Times RITSTF Initiative 4b,'" November 9, 2018.

2. The risk assessment approach and methods, shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200.

Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRC for generic use. If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRC approval via a license amendment.

Renewed License No. NPF-16 Amendment No. 499-Revised by letter dated July 2, 2019

!This page provided for information only.I ELECTRICAL POWER SYSTEMS 3/4.8.3 ONSITE POWER DISTRIBUTION OPERATING LIMITING CONDITION FOR OPERATION 3.8.3.1 The following electrical busses shall be energized in the specified manner with both tie breakers open between redundant busses and between St. Lucie Unit 1 and Unit 2.

a. Train A A.C. Emergency Susses consisting of:

1. 4160 volt Emergency Bus #2A3

2. 480 volt Emergency Bus #2A2

3. 480 volt Emergency Bus #2A5

4. 480 volt MCC Emergency Bus #2A5

5. 480 volt MCC Emergency Bus #2A6

6. 480 volt MCC Emergency Bus #2A7

7. 480 volt MCC Emergency Bus #2A8

8. 480 volt MCC Emergency Bus #2A9

b. Train B A.C. Emergency Susses consisting of:

1. 4160 volt Emergency Bus #283

2. 480 volt Emergency Bus #282

3. 480 volt Emergency Bus #285

4. 480 volt MCC Emergency Bus #285

5. 480 volt MCC Emergency Bus #2B6

6. 480 volt MCC Emergency Bus #2B7

7. 480 volt MCC Emergency Bus #2B8

8. 480 volt MCC Emergency Bus #2B9

c. 120 volt AC. Instrument Bus# 2MA energized from its associated inverter connected to D.C. Bus# 2A*.

d. 120 volt A.C. Instrument Bus# 2MB energized from its associated inverter connected to D.C. Bus# 2B*.

e. 120 volt A.C. Instrument Bus# 2MC energized from its associated inverter connected to D.C. Bus# 2A*.

f. 120 volt A.C. Instrument Bus# 2MD energized from its associated inverter connected to D.C. Bus# 28*.

g. 125 volt D.C. Bus# 2A energized from Battery Bank# 2A.

h. 125 volt D.C. Bus# 2B energized from Battery Bank# 2B.

APPLICABILITY: MODES 1, 2, 3, and 4.

Two inverters may be disconnected from their D.C. Bus for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , as necessary, for the purpose of performing an equalizing charge on their associ-ated battery bank provided (1) their vital busses are energized, and (2) the vital busses associated with the other battery bank are energized from their associated inverters and connected to their associated D.C. Bus.

ST. LUCIE - UNIT 2 3/4 8-14

ELECTRICAL POWER SYSTEMS ACTION:

NOTE Enter applicable ACTIONS of LCO 3.8.2.1, "D.C. Sources - Operating," for DC trains made inoperable by inoperable AC distribution system.

a. With one of the required trains of AC. Emergency busses not fully energized, re-energize the train 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 .

b. With one AC. Instrument Bus either not energized from its associated inverter, or with the inverter not connected to its associated D.C. Bus: (1) re-energize the A.C. Instrument Bus within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 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 SHUT WN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months and (2) re-energize the AC. Instrument Bu from its associated inverter connected to its associated D.C. Bus within 24 ho rs 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 SH OWN 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 en ri g HOT SHUTDOWN.

c. With one D.C. Bus not energized from ts ssociated Battery Bank, re-energize the D.C. Bus from its associated Batte ank within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 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 a din COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

!or in accordance with the Risk Informed Completion Time Program , I SURVEILLANCE REQUIREMENTS 4.8.3.1 The specified busses shall be determined energized in the required manner in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated voltage on the busses.

ST. LUCIE - UNIT 2 3/4 8-15 Amendment No. ~. 4-84,~

St. Lu cie Nuclear Plant, Un its 1 and 2 L-2020-1 64 Docket Nos. 50-335 and 50-389 Enclos ure Page 27 of 34 ATTACHMENT 3 ST. LUC IE UNIT 1 TECHN ICAL SPECIFICATION BASES PAGES (MARKUP)

(3 pages follow)

Section No.

ST. LUCIE UNIT 1 3/4.8 Attachment No.

TECHNICAL SPECIFICATIONS 10 BASES ATTACHMENT 10 Current Revision No.

OF ADM-25.04 FPL SAFETY RELATED

Title:

ELECTRICAL POWER SYSTEMS Responsible Department: Licensing REVISION

SUMMARY

Revision 9 - Incorporated PCR 2316140 to allow the performance of selected EOG surveillance requirements during power operation and by relocating to licensee control.

(Author: N. Davidson)

Revision 8 - Incorporated PCR 2290704 to include the Risk Informed Completion Time (RICT) Program. (Author: K. Frehafer)

AND Incorporated PCR 2324261 to include the LCO 3.0.6 Program. (Author: K. Frehafer)

Revision 7 - Incorporated PCR 2087288 based on NRC approval of TSTF-422, Change in Technical Specifications End States (CE NPSD-1186). (Author: N. Davidson)

Revision 6 - Incorporated PCR 2053666 based on NRC approval of the TSTF-425 LAR that implements the Surveillance Frequency control Program. (Author: K. Frehafer)

Revision 5 - Incorporated PCR 1948779 to modify TS requirements for Mode change limitations in LCO 3.0.4 and SR 4.0.4. (Author: N. Elmore)

Revision 4 - Incorporated PCR 1880845 to update DC battery surveillance TS changes required. (Author: K. Frehafer)

Revision 3 - Incorporated PCR 09-2643 to update EOG fuel oil testing ASTM standards.

(Author: K.W. Frehafer)

Revision Approved By Approval Date UNIT# UNIT 1 DATE 0 R.G. West 08/30/01 DOCT PROCEDURE DOCN Section 3/4.8 SYS 9 M. Jones 09/18/18 STATUS COMPLETED REV 9

OF PGS

SECTION NO.: PAGE:

TITLE: TECHNICAL SPECIFICATIONS 3/4.8 BASES ATTACHMENT 10 OF ADM -25. 04 11 of 11 REVISION NO .: ELECTRICAL POWER SYSTEMS 9 ST. LUCIE UNIT 1 3/4.8 ELECTRICAL POWER SYSTEMS (continued)

BASES (continued)

Particulate concentrations should be determined in accordance with ASTM D6217 or ASTM D2276. This method involves a gravimetric determination of total particulate concentration in the fuel oil and has a limit of 10 mg/I. It is acceptable to obtain a field sample for subsequent laboratory testing in lieu of field testing.

The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

ASTM Standards: D4057; D975 and 0975 Table 1; 01298; 04176; D2709; D2622; D6217; D5453; 03120; 02276. ASTM Standard "year" designations are located in Chemistry Procedures COP-05.10 and COP-07.16.

This concludes the TS Bases discussion for SR 4.8.1.1.2.c.

The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommendations of Regulatory Guide 1.108, "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977, Regulatory Guide 1.137, "Fuel Oil Systems for Standby Diesel Generators," Revision 1, October 1979, Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," dated July 2, 1984, and NRC staff positions reflected in Amendment No. 48 to Facility Operating License NPF-7 for North Anna Unit 2, dated April 25, 1985; as modified by Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation," dated September 27, 1993, and Generic Letter 94-01, "Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," dated May 31, 1994. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

INSERT from next

~

page

Unit 1 TS Bases INSERT Specification 3.8.2.1, ACTION b, specifies requirements for one A.C. Instrument Bus either not energized from its associated inverter, or with the inverter not connected to its associated D.C.

Bus. ACTION b(1) establishes a 2-hour Completion Time to re-energize the AC instrument bus within two hours. Alternatively, a Completion Time can be in accordance with the Risk Informed Completion Time Program. ACTION b(2) establishes a 24-hour Completion Time to re-energize the A.C. Instrument Bus from its associated inverter connected to its associated D.C. Bus.

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If either Completion Times cannot be met, the unit must be placed 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 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

St. Lucie Nuclear Plant, Units 1 and 2 L-2020-164 Docket Nos . 50-335 and 50-389 Enclosure Page 31 of 34 ATTACHMENT 4 ST. LUCIE UNIT 2 TECHNICAL SPECIFICATION BASES PAGES (MARKUP)

(3 pages follow)

Section No.

ST. LUCIE UNIT 2 3/4.8 Attachment No.

TECHNICAL SPECIFICATIONS 10 BASES ATTACHMENT 10 Current Revision No.

OF ADM-25.04 FPL SAFETY RELATED

Title:

ELECTRICAL POWER SYSTEMS Responsible Department: Licensing REVISION

SUMMARY

Revision 10 - Incorporated PCR 2316140 to allow the performance of selected EOG surveillance requirements during power operation and by relocating to licensee control.

(Author: N. Davidson)

Revision 9 - Incorporated PCR 2290704 to include the Risk Informed Completion Time (RICT) Program. (Author: K. Frehafer)

AND Incorporated PCR 2324261 to include the LCO 3.0.6 Program. (Author: K. Frehafer)

Revision 8 - Incorporated PCR 2087288 based on NRC approval of TSTF-422, Change in Technical Specifications End States (CE NPSD-1186). (Author: N. Davidson)

Revision 7 - Incorporated PCR 2053666 based on NRC approval of the TSTF-425 LAR that implements the Surveillance Frequency control Program. (Author: K. Frehafer)

Revision 6 - Incorporated PCR 1948783 to modify TS requirements for Mode change limitations in LCO 3.0.4 and SR 4.0.4. (Author: N. Elmore)

Revision 5 - Incorporated PCR 1671445 to update Diesel Fuel Oil Testing program TS changes required. (Author: K. Frehafer)

Revision 4 - Incorporated PCR 1880845 to update DC battery surveillance TS changes required. (Author: K. Frehafer)

Revision 3 - Incorporated PCR 09-2643 to update EOG fuel oil testing ASTM standards.

(Author: K.W. Frehafer)

Revision Approved By Approval Date UNIT# UNIT2 DATE 0 R.G. West 08/30/01 DOCT PROCEDURE DOCN Section 3/4.8 SYS 10 M. Jones 09/18/18 STATUS COMPLETED REV 10

OF PGS

SECTI ON NO.: PAGE:

TITLE: TEC HNICAL SPECIFICATION S 3/4. 8 BASES ATTACHM ENT 10 OF ADM -25.04 13 of 13 REVISION NO.: ELECTRICAL POWER SYSTEMS 10 ST. LUCIE UNIT 2 3/4.8 ELECTRICAL POWER SYSTEMS (continued) r BASES (continued) 3/4.8. 1, 3/4.8.2 and 3/4.8.3 A.C . SOURCES , D.C. SOURCES and ONSITE POWER DISTRIBUTION SYSTEMS (continued)

Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8-2 is permitted for up to 7 days.

During this 7 day period: (1) the allowable values for electrolyte level ensures no physical damage to the plates with an adequate electron transfer capability; (2) the allowable value for the average specific gravity of all the cells, not more than .020 below the manufacturer's recommended full charge specific gravity, ensures that the decrease in rating will be less than the safety margin provided in sizing; (3) the allowable value for an individual cell's specific gravity, ensures that an individual cell's specific gravity will not be more than .040 below the manufacturer's full charge specific gravity and that the overall capability of the battery will be maintained within an acceptable limit; and (4) the allowable value for an individual cell's float voltage, greater INSERT from next than 2.07 volts, ensures the battery's capability to perform its design function.

pa!=je 3/4.8.4 ELECTRICAL EQUIPM ENT PROTECTIVE DEVICES The OPERABILITY of the motor operated valves thermal overload protection and/or bypass devices ensures that these devices will not prevent safety related valves from performing their function. The Surveillance Requirements for demonstrating the OPERABILITY of these devices are in accordance with Regulatory Guide 1.106 "Thermal Overload Protection for Electric Motors on Motor Operated Valves," Revision 1, March 1977.

Unit 2 TS Bases INSERT Specification 3.8.3.1, ACTION b, specifies requirements for one A.C. Instrument Bus either not energized from its associated inverter, or with the inverter not connected to its associated D.C.

Bus. ACTION b(1) establishes a 2-hour Completion Time to re-energize the AC instrument bus within two hours. Alternatively, a Completion Time can be in accordance with the Risk Informed Completion Time Program. ACTION b(2) establishes a 24-hour Completion Time to re-energize the A.C. Instrument Bus from its associated inverter connected to its associated D.C. Bus.

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. If either Completion Times cannot be met, the unit must be placed 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 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

v t e Letter Sequence Other
EPID:L-2021-LLA-0283, (Approved, Closed)
Initiation Acceptance... Supplement Administration Questions Answers 12 May 2021 Results Approval Other: L-2020-164, License Amendment to Allow Risk Informed Completion Times (RICT) for the 120-Volt AC Instrument Bus Requirements
MONTHYEAR2021-05-12 [Table View]

L-2020-164, License Amendment to Allow Risk Informed Completion Times (RICT) for the 120-Volt AC Instrument Bus Requirements

Text

References:

1.0 DESCRIPTION

3.0 REGULATORY EVALUATION

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

1.0 DESCRIPTION

3.0 REGULATORY EVALUATION

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

Title:

SUMMARY

Title:

SUMMARY

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