Text

Issuance of Amendments Adoptiong of TSTF Traveler-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO
	ML15251A094
Person / Time
Site:	Saint Lucie
Issue date:	10/05/2015
From:	Farideh Saba; Plant Licensing Branch II
To:	Nazar M; Florida Power & Light Co
	Saba F DORL/LPL2-2 301-415-1447
References
	TAC MF5370, TAC MF5371
	Download: ML15251A094 (20)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, Florida 33408-0420 October 5, 2015

SUBJECT:

ST. LUCIE PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS REGARDING ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER-439, REVISION 2, "ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO" (TAC NOS. MF5370 AND MF5371)

Dear Mr. Nazar:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment Nos. 228 and 178 to Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant (St. Lucie), Unit Nos. 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated December 5, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14351A074).

The amendments issued with this letter revise St. Lucie, Unit Nos. 1 and 2, TSs to adopt Technical Specification Task Force Traveler-439, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [Limiting Condition for Operation]" (ADAMS Accession No. ML051860296). The second completion times associated with TS 3.6.2.1, "Containment Spray and Cooling Systems," are being deleted.

All work is complete on TAC Nos. MF5370 and MF5371. Accordingly, these TAC Nos. will be closed.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Docket Nos. 50-335 and 50-389

Enclosures:

1. Amendment No. 228 to DPR-67

2. Amendment No. 178to NPF-16

3. Safety Evaluation cc w/encls: Distribution via Listserv aeh E. Saba, Senior Project Manager nt Licensing Branch 11-2 ivision of Operator Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-335 ST. LUCIE PLANT UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 228 Renewed License No. DPR-67

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power & Light Company (the licensee),

dated December 5, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, Renewed Facility Operating License No. DPR-67 is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and by amending paragraph 3.B to read as follows:

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 2 2 8, are hereby incorporated in the renewed license.

FPL shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: o:::tx:t:Er 5, 2015 FOR THE NUCLEAR REGULATORY COMMISSION

~

ffr.,,crr Shana Helton, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT NO. 228 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-67 DOCKET NO. 50-335 Replace Page 3 of Renewed Facility Operating License No. DPR-67 with the attached Page 3.

Replace the following page of the Appendix A Technical Specifications with the attached page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Pages Insert Pages 314 6-15 3/4 6-15 applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A.

Maximum Power Level FPL is authorized to operate the facility at steady state reactor core power levels not in excess of 3020 megawatts (thermal).

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 2 2 8 are hereby incorporated in the renewed license.

FPL shall operate the facility in accordance with the Technical Specifications.

Appendix B, the Environmental Protection Plan (Non-Radiological), contains environmental conditions of the renewed license. If significant detrimental effects or evidence of irreversible damage are detected by the monitoring programs required by Appendix B of this license, FPL will provide the Commission with an analysis of the problem and plan of action to be taken subject to Commission approval to eliminate or significantly reduce the detrimental effects or damage.

C.

Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d), as revised on March 28, 2003, describes certain future activities to be completed before the period of extended operation. FPL shall complete these activities no later than March 1, 2016, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on March 28, 2003, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following issuance of this renewed license. Until that update is complete, FPL may make changes to the programs described in such supplement without prior Commission approval, provided that FPL evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

D.

Sustained Core Uncoverv Actions Procedural guidance shall be in place to instruct operators to implement actions that are designed to mitigate a small-break loss-of-coolant accident prior to a calculated time of sustained core uncovery.

Renewed License No. DPR-67 Amendment No. 228

CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY AND COOLING SYSTEMS LIMITING CONDITION FOR OPERATION 3.6.2.1 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY:

Containment Spray System: MODES 1, 2, and MODE 3 with Pressurizer Pressure.:: 1750 psia.

ACTION:

Containment Cooling System: MODES 1, 2, and 3.

1.

Modes 1, 2. and 3 with Pressurizer Pressure :::-: 1750 psia:

a.

With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months .

b.

With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c.

With one containment spray train and one containment cooling train inoperable, concurrently implement ACTIONS a. and b. The completion intervals for ACTION a. and ACTION b. shall be tracked separately for each train starting from the time each train was discovered inoperable.

NOTE Action not applicable when second containment spray train intentionally made inoperable.

d.

With two containment spray trains inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months verify TS 3.7.7, "Control Room Emergency Ventilation System," is met, and restore at least one containment spray train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

e.

With two containment cooling trains inoperable, restore one cooling train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

f.

With any combination of three or more trains inoperable, enter LCO 3.0.3 immediately.

2.

Mode 3 with Pressurizer Pressure< 1750 psia:

ST. LUCIE - UNIT 1

a.

With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise be in MODE 4 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b.

With two containment cooling trains inoperable, enter LCO 3.0.3 immediately.

3/4 6-15 Amendment No. 00, 4-a+, ~

/ 228

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY ORLANDO UTILITIES COMMISSION OF THE CITY OF ORLANDO. FLORIDA AND FLORIDA MUNICIPAL POWER AGENCY DOCKET NO. 50-389 ST. LUCIE PLANT UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 178 Renewed License No. NPF-16

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power & Light Company, et al. (the licensee), dated December 5, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I;

8.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 1 O CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, Renewed Facility Operating License No. NPF-16 is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and by amending paragraph 3.B to read as follows:

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 1 7 8, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

Attachment:

Changes to the Operating License and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION

~,/_ ~q:;v Shana Helton, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: October 5, 201 5

ATTACHMENT TO LICENSE AMENDMENT NO. 178 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-16 DOCKET NO. 50-389 Replace Page 3 of Renewed Facility Operating License No. NPF-16 with the attached Page 3.

Replace the following page of the Appendix A Technical Specifications with the attached page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Pages Insert Pages 3/4 6-15 3/4 6-15 neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required.

D.

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, FPL to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and E.

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, FPL to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

3.

This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission's regulations: 10 CFR Part 20, Section 30.34 of 10 FR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A.

Maximum Power Level FPL is authorized to operate the facility at steady state reactor core power levels not in excess of 3020 megawatts (thermal).

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 1 7 8 are hereby incorporated in the renewed license.

FPL shall operate the facility in accordance with the Technical Specifications.

Renewed License No. NPF-16 Amendment No. 1 7 8

CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZA TION AND COOLING SYSTEMS CONTAINMENT SPRAY AND COOLING SYSTEMS LIMITING CONDITION FOR OPERATION 3.6.2.1 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY:

Containment Spray System:

MODES 1, 2, and MODE 3 with Pressurizer Pressure~ 1750 psia.

ACTION:

Containment Cooling System:

MODES 1, 2, and 3.

1.

Modes 1, 2, and 3 with Pressurizer Pressure :2: 1750 psia:

a.

With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months .

b.

With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c.

With one containment spray train and one containment cooling train inoperable, concurrently implement ACTIONS a. and b. The completion intervals for ACTION a. and ACTION b. shall be tracked separately for each train starting from the time each train was discovered inoperable.

NOTE Action not applicable when second containment spray train intentionally made inoperable.

d.

With two containment spray trains inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months verify TS 3.7.7, "CREACS," is met, and restore at least one containment spray train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

e.

With two containment cooling trains inoperable, restore one cooling train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

f.

With any combination of three or more trains inoperable, enter LCO 3.0.3 immediately.

2.

Mode 3 with Pressurizer Pressure < 1750 psia:

a.

With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise be in MODE 4 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b.

With two containment cooling trains inoperable, enter LCO 3.0.3 immediately.

ST. LUCIE - UNIT 2 3/4 6-15 Amendment No. ~. +G, 4-771 1 7 8

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 228 AND 178 TO RENEWED FACILITY OPERATING LICENSES NOS. DPR-67 AND NPF-16 FLORIDA POWER AND LIGHT COMPANY. ET AL.

1.0 INTRODUCTION

ST. LUCIE PLANT. UNITS NOS. 1AND2 DOCKET NOS. 50-335 AND 50-389 By letter dated December 5, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14351A074), Florida Power and Light Company, et al. (the licensee) requested amendments to Renewed Operating Licenses DPR-67 and NPF-16 for St. Lucie Nuclear Plant (St. Lucie), Unit Nos. 1 and 2, respectively. The proposed amendment would modify the St. Lucie Technical Specifications (TSs) by eliminating second completion times limiting time from discovery of failure to meet a limiting condition for operation (LCO). The submittal included a request to adopt Technical Specification Task Force Traveler-439 (TSTF-439), Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" (ADAMS Accession No. ML051860296). The second completion times associated with TS 3.6.2.1, "Containment Spray and Cooling Systems," are being deleted.

2.0 REGULATORY EVALUATION

Title 1 O of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical specifications,"

paragraph (c)(2), "Limiting conditions for operation," states:

(i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. 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. When a limiting condition for operation of any process step in the system of a fuel reprocessing plant is not met, the licensee shall shut down that part of the operation or follow any remedial action permitted by the technical specifications until the condition can be met. In the case of a nuclear reactor not licensed under§ 50.21 (b) or§ 50.22 of this part or fuel reprocessing plant, the licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. The licensee shall retain the record of the results of each review until the Commission terminates the license for the nuclear reactor or the fuel reprocessing plant. In the case of nuclear power reactors licensed under§ 50.21(b) or§ 50.22, the licensee shall notify the Commission if required by § 50. 72 and shall submit a Licensee Event Report to the Commission as required by§ 50.73. In this case, licensees shall retain records associated with preparation of a Licensee Event Report for a period of three years following issuance of the report. For events which do not require a Licensee Event Report, the licensee shall retain each record as required by the technical specifications.

(ii) A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:

(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

(B) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(D) Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Title 10 of CFR Section 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," states:

The requirements of this section are applicable during all conditions of plant operation, including normal shutdown operations.

(a)(1) Each holder of an operating license for a nuclear power plant under this part and each holder of a combined license under part 52 of this chapter after the Commission makes the finding under§ 52.103(g) of this chapter, shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, as defined in paragraph (b) of this section, are capable of fulfilling their intended functions.

These goals shall be established commensurate with safety and, where practical, take into account industrywide operating experience. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken. For a nuclear power plant for which the licensee has submitted the certifications specified in§ 50.82(a)(1) or 52.11 O(a)(1) of this chapter, as applicable, this section shall only apply to the extent that the licensee shall monitor the performance or condition of all structures, systems, or components associated with the storage, control, and maintenance of spent fuel in a safe condition, in a manner sufficient to provide reasonable assurance that these structures, systems, and components are capable of fulfilling their intended functions.

(2) Monitoring as specified in paragraph (a)(1) of this section is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function.

(3) Performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months. The evaluations shall take into account, where practical, industry-wide operating experience. Adjustments shall be made where necessary to ensure that the objective of preventing failures of structures, systems, and components through maintenance is appropriately balanced against the objective of minimizing unavailability of structures, systems, and components due to monitoring or preventive maintenance.

(4) Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety.

(b) The scope of the monitoring program specified in paragraph (a)(1) of this section shall include safety related and nonsafety related structures, systems, and components, as follows:

(1) Safety-related structures, systems and components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelines in Sec. 50.34(a)(1 ), Sec. 50.67(b)(2), or Sec. 100.11 of this chapter, as applicable.

(2) Nonsafety related structures, systems, or components:

(i) That are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures (EOPs); or (ii) Whose failure could prevent safety-related structures, systems, and components from fulfilling their safety-related function; or (iii) Whose failure could cause a reactor scram or actuation of a safety-related system.

(c) The requirements of this section shall be implemented by each licensee no later than July 10, 1996.

3.0 BACKGROUND

NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants"

[Reference 2], included a second Completion Time for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the LCO. These Completion Times (henceforth referred to as "second Completion Times") are joined by an "AN" logical connector to the Condition-specific Completion Time and state "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second Completion Time was to preclude entry into and out of the Actions for an indefinite period of time without meeting the LCO by providing a limit on the amount of time that the LCO could not be met for various combinations of Conditions.

TSTF Traveler-439, Revision 2, deletes these second Completion Times from the affected Required Actions. By letter dated January 11, 2006 (ADAMS Accession No. ML060120272},

NRC approved TSTF-439, Revision 2.

4.0 TECHNICAL EVALUATION

4.1 Current TS 3.6.2.1 Actions 1.a and 1.b TS 3.6.2.1 Action 1.a currently states the following:

With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and within 1 O days from initial discovery of failure to meet the LCO; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months .

TS 3.6.2.1 Action 1.b currently states the following:

With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days and within 10 days from initial discovery of failure to meet the LCO; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

4.2 Proposed TS 3.6.2.1 Actions 1.a and 1.b Changes TS 3.6.2.1 Action 1.a proposed change is the following:

With one containment spray train inoperable, restore the inoperable spray train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months .

TS 3.6.2.1 Action 1.b proposed change is the following:

With one containment cooling train inoperable, restore the inoperable cooling train to OPERABLE status within 7 days; otherwise, be in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

4.3

NRC Staff Evaluation

Additional secondary completion times (such as limits on the period of time from discovery of the failure to meet the LCO) were specified to prevent repeated entry and exit from alternating TS Required Actions. Administrative controls will replace second completion times as described in the licensee's letter dated December 5, 2014. In addition, two programs provide a strong disincentive to licensees continuing operation with alternating Required Actions. These programs are the Maintenance Rule program and the Reactor Oversight Process.

Prior to 10 CFR 50.65, TSs were the primary rules governing operations, including what equipment must normally be in service, how long equipment can be out of service, compensatory actions, and surveillance testing to demonstrate equipment readiness. The goal of TSs is to provide adequate assurance of the availability and reliability of equipment needed to prevent, and if necessary mitigate, accidents and transients. The Maintenance Rule shares this goal and operates through a dynamic and comprehensive process.

Title 10 of CFR 50.65 assesses and manages inoperable equipment; however, the rule also considers all inoperable risk-significant equipment. Under the TSs, the Completion Time for one system within an LCO is not generally affected by inoperable equipment in another LCO.

However, the second completion time influenced the Completion Time for one system based on the condition of another system, but only if the two systems were required by the same LCO.

Plant Maintenance Rule programs implement risk-based configuration management programs that augment the deterministic Completion Times in the TSs. The NRC Resident Inspectors also monitor the licensee's Corrective Action process and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65 identify maintenance practices that would result from multiple entries into the Actions of the TSs which contribute to unacceptable unavailability of these SSCs.

NRC inspection findings for each plant are documented in inspection reports in accordance with Inspection Manual Chapter (IMC) 0612 and summarized in Plant Issues Matrices. Inspection findings are evaluated using the significance determination process in accordance with IMC 0609 to evaluate the safety significance of the findings.

St. Lucie, Unit Nos. 1 and 2, have not adopted the Standard Technical Specifications. The term "Completion Time" as used in the Standard Technical Specifications is equivalent to the term "Action Time" in the St. Lucie TSs. In the application, the licensee stated that the only TS with a secondary Completion Time for St. Lucie, Unit Nos. 1 and 2, is LCO 3.6.2.1, "Containment Spray and Cooling Systems." LCO 3.6.2.1 requires two containment spray and two containment cooling trains be operable. Conditions and Actions are provided for inoperability of one containment spray train and one containment cooling train, and for inoperability of two containment cooling trains. With two containment spray trains inoperable, or any combination or three or more trains inoperable, entry is made into TS 3.0.3, which requires the plant be placed in a condition in which the TS does not apply. The second Completion Time restricts operation with only one train inoperable, but the restriction is unnecessary because when only one train is inoperable, there are still three operable trains. The TS Bases state that during a design basis accident, one containment cooling train and one containment spray train are capable of maintaining the peak pressure and temperature within design limits.

Based on the above, the NRC staff concludes that multiple, continuous entries into TS Conditions, without meeting the LCO, will be adequately controlled by (1) the licensee's administrative controls and operations procedure which will not allow indefinite continued operation while not meeting the LCO, and (2) the configuration risk management programs implemented to meet the Maintenance Rule requirements to assess and manage risk. In addition, the NRC staff finds that compliance with the Maintenance Rule provides adequate assurance against inappropriate use of combinations of TS Conditions that result in a single contiguous occurrence of failing to meet the LCO. Accordingly, consistent with TSTF-439, Revision 2, the NRC staff finds the proposed changes to delete the second completion times to be acceptable.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the NRC staff notified the State of Florida official (Ms. Cynthia Becker, M.P.H., Chief of the Bureau of Radiation Control, Florida Department of Health) on August 26, 2015, of the proposed issuance of the amendments. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

These amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (80 FR 5801, dated February 3, 2015). Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

7.0 CONCLUSION

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

Principal Contributor: Margaret H. Chernoff Date: October 5, 2015

ML15251A094 OFFICE LPL 1-2/PM LPL2-2/LA NAME JLamb BClayton DATE 9/4/2015 9/15/2015 Sincerely,

/RA by Jlamb for/

Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation

via memo STSB/BC*

OGC LPL2-2/BC LPL2-2/PM RElliott EWilliamson Shelton FSaba (AHon for)

(JLamb for) 9/4/2015 9/12/2015 10/02/2015 10/05/2015

v t e Letter Sequence Approval
TAC:MF5370, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Open) TAC:MF5371, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Open)
Initiation Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2014-12-30 [Table View]

ML15251A094

Text

SUBJECT:

Dear Mr. Nazar:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 BACKGROUND

4.0 TECHNICAL EVALUATION

NRC Staff Evaluation

5.0 STATE CONSULTATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

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