ML14198A074
| ML14198A074 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/14/2014 |
| From: | Jensen J Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-08-001, L-2014-029 | |
| Download: ML14198A074 (64) | |
Text
0July 14, 2014FPL. L-2014-02910 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001St, Lucie Nuclear PlantUnits 1 and 2Docket Nos. 50-335 and 50-389Renewed Facility Operating Licenses Nos. DPR-67 and NPF-16License Amendment Request, Application to Revise Technical Specifications to AdoptTechnical Specifications Task Force (TSTF) Traveler -523, "Generic Letter 2008-01,Managing Gas Accumulation," Using the Consolidated Line Item Improvement ProcessReferences1. Letter (L-2008-221) from G. L. Johnson (FPL) to Document Control Desk (NRC), "NineMonth Response to NRC Generic Letter 2008-01, Managing Gas Accumulation inEmergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"October 14, 2008 (ADAMS Accession No. ML082900487)Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) is submitting a request foramendment to the Technical Specifications for St. Lucie Nuclear Plant (St. Lucie), Units 1and 2.The proposed amendment would modify TS requirements to address NRC Generic Letter(GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay HeatRemoval, and Containment Spray Systems," as described in TSTF-523, Revision 2 "GenericLetter 2008-01, Managing Gas Accumulation." FPL committed to submit this proposedchange in Reference 1.Attachment 1 provides a description and assessment of the proposed change. Attachment 2provides the existing St. Lucie Unit 1 TS pages marked up to show the proposed change.Attachment 3 provides the St. Lucie Unit 1 revised (clean) TS pages. Attachment 4 providesthe existing St. Lucie Unit 1 TS Bases pages marked to show the proposed change.Attachment 5 provides the existing St. Lucie Unit 2 TS pages marked up to show theproposed change. Attachment 6 provides the St. Lucie Unit 2 revised (clean) TS pages.Attachment 7 provides the existing St. Lucie Unit 2 TS Bases pages marked to show theproposed change. Changes to the existing TS Bases, consistent with the technical andregulatory analyses, will be implemented under the Technical Specification Bases ControlProgram. They are provided in Attachments 4 and 7 for information only.Florida Power & Light Company6501 S. Ocean Drive, Jensen Beach, FL 34957 L-2014-029Page 2 of 2Approval of the proposed amendment is requested within one year of submittal. Once approvedthe amendment shall be implemented within 90 days.In accordance with 10 CFR 50.91, a copy of this application is being sent to the designatedState of Florida Official.This application has been reviewed by the St. Lucie Onsite Review Group.This letter satisfies FPL's commitment made in Reference 1 and makes no new commitments orchanges to any other existing commitments.If you have any questions or require additional information, please contact Eric Katzman at772-467-7734.I declare under penalty of perjury that the foregoing is true and correct.Executed on\\3 I1, 2014.icie Nuclear PlantAttachments:2.3.4.5.6.7.Description and AssessmentProposed St. Lucie Unit 1 TS Changes (marked-up pages)Proposed St. Lucie Unit 1 TS Changes (clean/typed pages)Proposed St. Lucie Unit 1 TS Bases Changes (marked-up pages) -For information onlyProposed St. Lucie Unit 2 TS Changes (marked-up pages)Proposed St. Lucie Unit 2 TS Changes (clean/typed pages)Proposed St. Lucie Unit 2 TS Bases Changes (marked-up pages) -For information onlycc: Ms. Cindy Becker, Florida Department of Health L-2014-029Attachment 1Page 1 of 5License Amendment Request forAdoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas AccumulationAttachment ISt. Lucie Nuclear PlantDescription and Assessment1.0 DESCRIPTION2.0 ASSESSMENT2.1 Applicability of Published Safety Evaluation2.2 Optional Changes and Variations3.0 REGULATORY ANALYSIS3.1 No Significant Hazards Consideration3.2 Applicable Regulatory Requirements/Criteria4.0 ENVIRONMENTAL EVALUATION
5.0 REFERENCES
L-2014-029Attachment 1Page 2 of 5ATTACHMENT IDESCRIPTION AND ASSESSMENT1.0 DESCRIPTIONThe proposed change revises or adds Surveillance Requirements to verify that the systemlocations susceptible to gas accumulation are sufficiently filled with water and to provideallowances which permit performance of the verification. The changes are being made toaddress the concerns discussed in NRC Generic Letter (GL) 2008-01, "Managing GasAccumulation in Emergency Core Cooling, Decay Heat Removal, and Containment SpraySystems," [Reference 2].The proposed amendment is consistent with Technical Specifications Task Force Traveler(TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" [Reference 3].2.0 ASSESSMENT2.1 Applicability of Published Safety EvaluationFlorida Power & Light Company (FPL) has reviewed the model safety evaluation publishedJanuary 15, 2014 as part of the Federal Register Notice of Availability, "TSTF-523, GenericLetter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item ImprovementProcess" (79 FR 2700) [Reference 4]. This review included the NRC staffs evaluation, as wellas the information provided in TSTF-523. As described in the subsequent paragraphs, FPL hasconcluded that the justifications presented in the TSTF-523 proposal and the model safetyevaluation prepared by the NRC staff are applicable to St. Lucie Units 1 and 2 and justify thisamendment for incorporation of the changes to the St. Lucie Technical Specifications (TS).2.2 Optional Changes and VariationsFPL is proposing the following variations or deviations from the TS changes described inTSTF-523, Revision 2 [Reference 3], or the applicable parts of the NRC staffs model safetyevaluation.St. Lucie Units 1 and 2 each have their own TS that differ in some areas. However, for the TSbeing changed in this proposal, the numbers and titles for the Unit 1 and Unit 2 TS are identical.The St. Lucie TS utilize different numbering, format, and titles than NUREG-1432, "StandardTechnical Specifications -Combustion Engineering Plants," [Reference 5] on which TSTF-523was based. Specifically, the numbering and title differences are provided in the table below.NUREG-1432 St. LucieStandard Technical Specifications Units I and 2Combustion Engineering Plants Technical Specifications3.4.6, RCS Loops -MODE 4 3/4.4.1.3, Reactor Coolant System -HotShutdown3.4.7, RCS Loops -MODE 5 Loops Filled 3/4.4.1.4.1, Reactor Coolant System -ColdI Shutdown -Loops Filled L-2014-029Attachment 1Page 3 of 5NUREG-1432 St. LucieStandard Technical Specifications Units 1 and 2Combustion Engineering Plants Technical Specifications3.4.8, RCS Loops -MODE 5 Loops Not Filled 3/4.4.1.4.2, Reactor Coolant System -ColdShutdown -Loops Not Filled3.5.2, ECCS -Operating 3/4.5.2, ECCS Subsystems -Operating3.6.6, Containment Spray and Cooling Systems 3/4.6.2, Depressurization and Cooling Systems -Containment Spray and Cooling Systems3.9.4, SDC and Coolant Circulation -High Water 3/4.9.8.1, Shutdown Cooling and CoolantLevel Circulation -High Water Level3.9.5, SDC and Coolant Circulation -Low Water 3/4.9.8.2, Shutdown Cooling and CoolantLevel Circulation -Low Water LevelThese differences are administrative and do not affect the applicability of TSTF-523 to St. Lucie.TSTF-523 and the model safety evaluation discuss the applicable regulatory requirements andguidance including 10 CFR 50, Appendix A, General Design Criteria (GDC). St. Lucie Unit 1was not licensed to 10 CFR 50, Appendix A, GDC. However, the St. Lucie Updated FinalSafety Analysis Report (UFSAR) Section 1.3, Conformance with the General Design Criteria,provides a discussion of the St. Lucie Unit 1 design with respect to each of the GDC. Thisdifference does not alter the conclusion that the proposed change is applicable to St. LucieUnit 1.St. Lucie Unit 2 was licensed and conforms to 10 CFR 50, Appendix A, General Design Criteria.3.0 REGULATORY SAFETY ANALYSIS3.1 No Significant Hazards Consideration DeterminationFlorida Power & Light Company (FPL) requests adoption of Technical Specification Task ForceTraveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," whichis an approved change to the standard technical specifications (STS), into the St. Lucie Units 1and 2 Technical Specifications (TS). The proposed change revises or adds SurveillanceRequirements (SRs) to verify that the system locations susceptible to gas accumulation aresufficiently filled with water and to provide allowances which permit performance of theverification.FPL has evaluated whether or not a significant hazards consideration is involved with theproposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuanceof amendment," as discussed below:1: Does the Proposed Change Involve a Significant Increase in the Probability orConsequences of an Accident Previously Evaluated?Response: No L-2014-029Attachment 1Page 4 of 5The proposed change revises or adds SRs that require verification that the Emergency CoreCooling Systems (ECCS), Residual Heat Removal (RHR) System, Shutdown Cooling (SDC)System, and Containment Spray (CS) System are not rendered inoperable due toaccumulated gas and to provide allowances which permit performance of the revisedverification. Gas accumulation in the subject systems is not an initiator of any accidentpreviously evaluated. As a result, the probability of any accident previously evaluated is notsignificantly increased. The proposed SRs ensure that the subject systems continue to becapable of performing their assumed safety function and are not rendered inoperable due togas accumulation. Thus, the consequences of any accident previously evaluated are notsignificantly increased.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the Proposed Change Create the Possibility of a New or Different Kind of Accidentfrom any Accident Previously Evaluated?Response: NoThe proposed change revises or adds SRs that require verification that the ECCS, RHRSystem, SDC System, and CS System are not rendered inoperable due to accumulated gasand to provide allowances which permit performance of the revised verification. Theproposed change does not involve a physical alteration of the plant (i.e., no new or differenttype of equipment will be installed) or a change in the methods governing normal plantoperation. In addition, the proposed change does not impose any new or differentrequirements that could initiate an accident. The proposed change does not alterassumptions made in the safety analysis and is consistent with the safety analysisassumptions.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any accident previously evaluated.3. Does the Proposed Change Involve a Significant Reduction in a Margin of Safety?Response: NoThe proposed change revises or adds SRs that require verification that the ECCS, RHRSystem, SDC System, and CS System are not rendered inoperable due to accumulated gasand to provide allowances which permit performance of the revised verification. Theproposed change adds new requirements to manage gas accumulation in order to ensurethat the subject systems are capable of performing their assumed safety functions. Theproposed SRs are more comprehensive than the current SRs and will ensure that theassumptions of the safety analysis are protected. The proposed change does not adverselyaffect any current plant safety margins or the reliability of the equipment assumed in thesafety analysis. Therefore, there are no changes being made to any safety analysisassumptions, safety limits, or limiting safety system settings that would adversely affect plantsafety as a result of the proposed change.
L-2014-029Attachment 1Page 5 of 5Therefore, the proposed change does not involve a significant reduction in a margin ofsafety.3.2 Applicable Regulatory Requirements/CriteriaBased on the above, FPL concludes that the proposed change presents no significant hazardsconsideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of"no significant hazards consideration" is justified.4.0 ENVIRONMENTAL EVALUATIONThe proposed amendment would change a requirement with respect to installation or use of afacility component located within the restricted area, as defined in 10 CFR Part 20, or wouldchange an inspection or surveillance requirement. However, the proposed change does notinvolve (i) a significant hazards consideration, (ii) a significant change in the types or significantincrease in the amounts of any effluent that may be released offsite, or (iii) a significant increasein individual or cumulative occupational radiation exposure. Accordingly, the proposed changemeets 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 environmentalassessment need be prepared in connection with the proposed change.
5.0 REFERENCES
- 1. Letter (L-2008-221) from G. L. Johnson (FPL) to Document Control Desk (NRC), "NineMonth Response to NRC Generic Letter 2008-01, Managing Gas Accumulation inEmergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"October 14, 2008 (ADAMS Accession No. ML082900487)2. Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling,Decay Heat Removal, and Containment Spray Systems," January 11, 2008, (ADAMSAccession No. ML072910759)3. Technical Specifications Task Force (TSTF)-523, Revision 2, "Generic Letter 2008-01,Managing Gas Accumulation," February 23, 2013, (ADAMS Accession No.ML13053A075)4. Federal Register Notice of Availability, "TSTF-523, Generic Letter 2008-01 ManagingGas Accumulation Using the Consolidated Line Item Improvement Process," publishedJanuary 15, 2014 (79 FR 2700)5. NUREG-1432, Revision 4, "Standard Technical Specifications -CombustionEngineering Plants," April 2012 (ADAMS Accession No. ML12102A169)
L-2014-029Attachment 2Page 1 of 8License Amendment Request forAdoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas AccumulationAttachment 2St. Lucie Unit 1Technical Specifications ChangesMarked Up Pages3/4 4-1c3/4 4-1d3/4 4-1e3/4 5-43/4 6-15a3/4 9-83/4 9-8a L-2014-029Attachment 2Page 2 of 8REACTOR COOLANT SYSTEMHOT SHUTDOWNSURVEILLANCE REQUIREMENTS4.4.1.3.1 The required reactor coolant pump(s), if not in operation, shall bedetermined to be OPERABLE once per 7 days by verifying correct breaker align-ments and indicated power availability.4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE byverifying the secondary side water level to be > 10% of narrow range indica-tion at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.3 At least one reactor coolant or shutdown cooling loop shall beverified to be in operation and circulating reactor coolant at least onceper 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.4 Verify required shutdown cooling train locations susceptibleto gas accumulation are sufficiently filled with water at least once per31 days.*1* Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.ST. LUCIE -UNIT 13/4 4-1cAmendment No. 5&
L-2014-029Attachment 2Page 3 of 8REACTOR COOLANT SYSTEMCOLD SHUTDOWN -LOOPS FILLEDLIMITING CONDITION FOR OPERATION3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and inoperation* and either:a. One additional shutdown cooling loop shall be OPERABLE, orb. The secondary side water level of at least two steam generatorsshall be greater than 10% of narrow range indication.APPLICABILITY: MODE 5 with reactor coolant loops filledACTION:a. With less than the above required loops OPERABLE or with less thanthe required steam generator level, within one (1) hour initiatecorrective action to return the required loops to OPERABLE statusor to restore the required level.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 andwithin one (1) hour initiate corrective action to return the required shutdown loopto operation.SURVEILLANCE REQUIREMENTS4.4.1.4.1.1 The secondary side water level of at least two steam generatorswhen required shall be determined to be within limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be inoperation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.3 Verify required shutdown cooling train locations susceptible to gasaccumulation are sufficiently filled with water at least once per 31 days.* The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided 1) no operationsare permitted that would cause introduction into the RCS, coolant with boron concentrationless than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and2) core outlet temperature is maintained at least 10OF below saturation temperature.# One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting provided the other shutdown cooling loop is OPERABLE and in operation.## A reactor coolant pump shall not be started with two idle loops unless thesecondary water temperature of each steam generator is less than 309F aboveeach of the Reactor Coolant System cold leg temperatures.ST. LUCIE- UNIT 13/4 4-1 dAmendment No. &G, 1-,., 403,44L.,1z7L L-2014-029Attachment 2Page 4 of 8REACTOR COOLANT SYSTEMCOLD SHUTDOWN -LOOPS NOT FILLEDLIMITING CONDITION FOR OPERATION3.4.1.4.2 Two shutdown cooling loops shall be OPERABLEf and at least one shut-down cooling loop shall be in operation*.APPLICABILITY: MODE 5 with reactor coolant loops not filled.ACTION:a. With less than the above required loops OPERABLE, within one (1) hourinitiate corrective action to return the required loops toOPERABLE status.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 andwithin one (1) hour initiate corrective action to return the required shutdowncooling loop to operation.SURVEILLANCE REQUIREMENTS4.4.1.4.2 At least one shutdown cooling loop shall be determined to be inoperation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.2.1 Verify shutdown cooling train locations susceptible to gasaccumulation are sufficiently filled with water at least once per 31 days.# One shutdown cooling loop may be Inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting provided the other shutdown cooling loop is OPERABLE and in operation.The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided 1) nooperations are permitted that would cause introduction into the RCS, coolant with boronconcentration less than required to meet the SHUTDOWN MARGIN of TechnicalSpecification 3.1.1.2 and 2) core outlet temperature is maintained at least 10F belowsaturation temperature.ST. LUCIE -UNIT 13M4 4-1eAmendment No. 66, 4-3, ff9 L-2014-029Attachment 2Page 5 of 8EMERGENCY CORE COOLING SYSTEMSSURVEILLANCE REQUIREMENTS4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following valvesare in the indicated positions with power to the valve operatorsremoved:d0)QCLC WSU)0 75W EM)>oc)iValve Number1. V-36592. V-3660Valve Function1. Mini-flowisolation2. Mini-flowIsolationValve Position1. Open2. Openb. At least once per 31 days by:1. Verifying that each valve (manual, power operated orautomatic) in the flow path that is not locked, sealed, orotherwise secured in position, is in its correct position.c. By a visual inspection which verifies that no loose debris (rags,trash, clothing, etc.) is present In the containment which could betransported to the containment sump and cause restriction of thepump suctions during LOCA conditions. This visual inspection shallbe performed:1. For all accessible areas of the containment prior toestablishing CONTAINMENT INTEGRITY, and2. At least once daily of the areas affected within containmentby the containment entry and during the final entry whenCONTAINMENT INTEGRITY is established.d. At least once per 18 months by:1. Verifying proper operation of the open permissive interlock(OPI) and the valve open/high SDCS pressure alarms forisolation valves V3651, V3652, V3480, V3481.2. A visual inspection of the containment sump and verifying thatthe subsystem suction inlets are not restricted by debris andthat the sump components (trash racks, screens, etc.) show noevidence of structural distress or corrosion.I Not required to be met for system vent flow paths opened underadministrative control.IST. LUCIE -UNIT 13/4 5-4Amendment No. 00, 420,-420 L-2014-029Attachment 2Page 6 of 8SURVEILLANCE REQUIREMENTS4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:a. At least once per 31 days by verifying that each valve (manual, power operated orautomatic) in the flow path that is not locked, sealed, or otherwise secured inposition, is positioned to take suction from the RVVT on a Containment Pressure-High High test signal.b. By verifying that each spray pump develops the specified discharge pressurewhen tested pursuant to the Inservice Testing Program.Ic. At least once per 31 days, by verifying containment spray systemlocations susceptible to gas accumulation are sufficiently filled with water.1" Not required to be met for system vent flow paths opened under administrative control.IST. LUCIE -UNIT 1314 6-15SaAmendment No. 4..4..-4. 1$04-L-2014-029Attachment 2Page 7 of 8REFUELING OPERATIONSSHUTDOWN COOLING AND COOLANT CIRCULATIONHIGH WATER LEVELLIMITING CONDITION FOR OPERATION3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation*.APPLICABILITY: MODE 6 when the water level above the top of irradiatedfuel assemblies seated within the reactor pressure vesselis greater than or equal to 23 feet.ACTION:a. With less than one shutdown cooling loop in operation, suspend alloperations involving an increase in reactor decay heat load or operations thatwould cause introduction into the RCS, coolant with boron concentration lessthan required to meet the boron concentration of Technical Specification 3.9.1.Close all containment penetrations providing direct access from thecontainment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.b. The provisions of Specification 3.0.3 are not applicable.SURVEILLANCE REQUIREMENTS4.9.8.1 At least one shutdown cooling loop shall be verified to be in operationand circulating reactor coolant at a flow rate of greater than or equal to3000 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gasaccumulation are sufficiently filled with water at least once per 31 days.The shutdown cooling loop may be removed from operation for up to 1 hourper 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period during the performance of CORE ALTERATIONS in the vicinityof reactor pressure vessel hot legs, provided no operations are perrrmtted that would cause .introduction into the RCS, coolant with boron concentration less than required to meet theSHUTDOWN MARGIN of Technical Specification 3.9.1.ST. LUCIE -UNIT 13/4 9-8Amendment No. 66, 4ý L-2014-029Attachment 2Page 8 of 8REFUELING OPERATIONSLOW WATER LEVELLIMITING CONDITION FOR OPERATION3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and atleast one shutdown cooling loop shall be in operation.'APPLICABILITY: MODE 6 when the water level above the top of irradiatedfuel assemblies seated within the reactor pressure vesselis less than 23 feet.ACTION:a. vVWth less than the required shutdown cooling loops OPERABLE, withinone (1) hour 1) initiate corrective action to return the requiredloops to OPERABLE status, or 2) establish greater than or equal to23 feet of water above irradiated fuel assemblies seated within thereactor pressure vessel.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet the boron concentration of Technical Specification 3.9.1. andwithin one (1) hour initiate corrective action to return the required shutdowncooling loop to operation. Close all containment penetrations providing directaccess from the containment atmosphere to the outside atmosphere within 4hours.c. The provisions of Specification 3.0.3 are not applicable.SURVEILLANCE REQUIREMENTS4.9.8.2 At least one shutdown cooling loop shall be verified to be in opera-tion and circulating reactor coolant at a flow rate of greater than or equalto 3000 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.9.8.2.1 Verity shutdown cooling loop locations susceptible to gasaccumulation are sufficiently filled with water at least once per 31 days.One required shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance 4'testing, provided that the other shutdown cooling loop is OPERABLE and in operation.ST. LUCIE -UNIT 13/4 9-8aAmendment No. 46,. 4-3,4. 4 0R... L-2014-029Page 1 of 8License Amendment Request forAdoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas AccumulationAttachment 3St. Lucie Unit 1Technical Specifications ChangesRetyped/Clean Pages3/4 4-1c3/4 4-1d3/4 4-1e3/4 5-43/4 6-15a3/4 9-83/4 9-8a L-2014-029Page 2 of 8REACTOR COOLANT SYSTEMHOT SHUTDOWNSURVEILLANCE REQUIREMENTS4.4.1.3.1 The required reactor coolant pump(s), if not in operation, shall bedetermined to be OPERABLE once per 7 days by verifying correct breaker align-ments and indicated power availability.4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE byverifying the secondary side water level to be > 10% of narrow range indica-tion at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.3 At least one reactor coolant or shutdown cooling loop shall beverified to be in operation and circulating reactor coolant at least onceper 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.4 Verify required shutdown cooling train locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days. ** Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.ST. LUCIE -UNIT 13M4 4-1 cAmendment No. ý6 L-2014-029Page 3 of 8REACTOR COOLANT SYSTEMCOLD SHUTDOWN -LOOPS FILLEDLIMITING CONDITION FOR OPERATION3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and inoperation* and either:a. One additional shutdown cooling loop shall be OPERABLE#, orb. The secondary side water level of at least two steam generatorsshall be greater than 10% of narrow range indication.APPLICABILITY: MODE 5 with reactor coolant loops filledACTION:a. With less than the above required loops OPERABLE or with less thanthe required steam generator level, within one (1) hour initiatecorrective action to return the required loops to OPERABLE statusor to restore the required level.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 andwithin one (1) hour initiate corrective action to return the required shutdown loopto operation.SURVEILLANCE REQUIREMENTS4.4.1.4.1.1 The secondary side water level of at least two steam generatorswhen required shall be determined to be within limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be inoperation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.3 Verify required shutdown cooling train locations susceptible to gas accumulationare sufficiently filled with water at least once per 31 days.The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided 1) no operationsare permitted that would cause introduction into the RCS, coolant with boron concentrationless than required to meet the SHUTDOWN MARGIN of Technical Specification 3.1.1.2 and2) core outlet temperature is maintained at least 10=F below saturation temperature.# One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting provided the other shutdown cooling loop is OPERABLE and in operation.## A reactor coolant pump shall not be started with two idle loops unless thesecondary water temperature of each steam generator is less than 301F aboveeach of the Reactor Coolant System cold leg temperatures.ST. LUCIE -UNIT 1 314 4-1d Amendment No. ,9, 84. 49.4-79,49.7 L-2014-029Page 4 of 8REACTOR COOLANT SYSTEMCOLD SHUTDOWN -LOOPS NOT FILLEDLIMITING CONDITION FOR OPERATION3.4.1.4.2 Two shutdown cooling loops shall be OPERABLE# and at least one shut-down cooling loop shall be in operations.APPLICABILITY: MODE 5 with reactor coolant loops not filled.ACTION:a. With less than the above required loops OPERABLE, within one (1) hourinitiate corrective action to return the required loops toOPERABLE status.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2 andwithin one (1) hour initiate corrective action to return the required shutdowncooling loop to operation.SURVEILLANCE REQUIREMENTS4.4.1.4.2 At least one shutdown cooling loop shall be determined to be inoperation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.2.1 Verify shutdown cooling train locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.# One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting provided the other shutdown cooling loop is OPERABLE and in operation.* The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided 1) nooperations are permitted that would cause introduction into the RCS, coolant with boronconcentration less than required to meet the SHUTDOWN MARGIN of TechnicalSpecification 3.1.1.2 and 2) core outlet temperature is maintained at least 10*F belowsaturation temperature.ST. LUCIE -UNIT 13/4 4-1 eAmendment No. 5W, 403,479 L-2014-029Page 5 of 8EMERGENCY CORE COOLING SYSTEMSSURVEILLANCE REQUIREMENTS4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following valvesare in the indicated positions with power to the valve operatorsremoved:Valve Number Valve Function Valve Position1. V-3659 1. Mini-flow 1. Openisolation2. V-3660 2. Mini-flow 2. Openisolationb. At least once per 31 days by:1. Verifying that each valve (manual, power operated orautomatic) in the flow path that is not locked, sealed, orotherwise secured in position, is in its correct position.*2. Verifying ECCS train locations susceptible to gas accumulation aresufficiently filled with water.c. By a visual inspection which verifies that no loose debris (rags,trash, clothing, etc.) is present in the containment which could betransported to the containment sump and cause restriction of thepump suctions during LOCA conditions. This visual inspection shallbe performed:1. For all accessible areas of the containment prior toestablishing CONTAINMENT INTEGRITY, and2. At least once daily of the areas affected within containmentby the containment entry and during the final entry whenCONTAINMENT INTEGRITY is established.d. At least once per 18 months by:1. Verifying proper operation of the open permissive interlock(OPI) and the valve open/high SDCS pressure alarms forisolation valves V3651, V3652, V3480, V3481.2. A visual inspection of the containment sump arnd verifying thatthe subsystem suction inlets are not restricted by debris andthat the sump components (trash racks, screens, etc.) show noevidence of structural distress or corrosion.Not required to be met for system vent flow paths opened under administrative control.ST. LUCIE- UNIT 1 3/4 5-4 Amendment No. 00, 420, L-2014-029Page 6 of 8SURVEILLANCE REQUIREMENTS4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:a. At least once per 31 days by verifying that each valve (manual, power operated orautomatic) in the flow path that is not locked, sealed, or otherwise secured inposition, is positioned to take suction from the RWT on a Containment Pressure-- High High test signal.*b. By verifying that each spray pump develops the specified discharge pressurewhen tested pursuant to the Inservice Testing Program.c. At least once per 31 days, by verifying containment spray system locationssusceptible to gas accumulation are sufficiently filled with water.Not required to be met for system vent flow paths opened under administrative control.ST. LUCIE -UNIT 13/4 6-15aAmendment No. 4,34-, 445,494 L-2014-029Page 7 of 8REFUELING OPERATIONSSHUTDOWN COOLING AND COOLANT CIRCULATIONHIGH WATER LEVELLIMITING CONDITION FOR OPERATION3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation*.APPLICABILITY: MODE 6 when the water level above the top of irradiatedfuel assemblies seated within the reactor pressure vesselis greater than or equal to 23 feet.ACTION:a. With less than one shutdown cooling loop in operation, suspend alloperations involving an increase in reactor decay heat load or operations thatwould cause introduction into the RCS, coolant with boron concentration lessthan required to meet the boron concentration of Technical Specification 3.9.1.Close all containment penetrations providing direct access from thecontainment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.b. The provisions of Specification 3.0.3 are not applicable.SURVEILLANCE REQUIREMENTS4.9.8.1 At least one shutdown cooling loop shall be verified to be in operationand circulating reactor coolant at a flow rate of greater than or equal to3000 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.The shutdown cooling loop may be removed from operation for up to 1 hourper 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period during the performance of CORE ALTERATIONS in the vicinityof reactor pressure vessel hot legs, provided no operations are permitted that would causeintroduction into the RCS, coolant with boron concentration less than required to meet theSHUTDOWN MARGIN of Technical Specification 3.9.1.ST. LUCIE -UNIT 13/4 9-8Amendment No. W5, 47- L-2014-029Page 8 of 8REFUELING OPERATIONSLOW WATER LEVELLIMITING CONDITION FOR OPERATION3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and atleast one shutdown cooling loop shall be in operation.*APPLICABILITY: MODE 6 when the water level above the top of irradiatedfuel assemblies seated within the reactor pressure vesselis less than 23 feet.ACTION:a. With less than the required shutdown cooling loops OPERABLE, withinone (1) hour 1) initiate corrective action to return the requiredloops to OPERABLE status, or 2) establish greater than or equal to23 feet of water above irradiated fuel assemblies seated within thereactor pressure vessel.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet the boron concentration of Technical Specification 3.9.1. andwithin one (1) hour initiate corrective action to return the required shutdowncooling loop to operation. Close all containment penetrations providing directaccess from the containment atmosphere to the outside atmosphere within 4hours.c. The provisions of Specification 3.0.3 are not applicable.SURVEILLANCE REQUIREMENTS4.9.8.2 At least one shutdown cooling loop shall be verified to be in opera-tion and circulating reactor coolant at a flow rate of greater than or equalto 3000 gpm at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.9.8.2.1 Verify shutdown cooling loop locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.One required shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting, provided that the other shutdown cooling loop is OPERABLE and in operation.ST. LUCIE -UNIT t3149MaAmendment No. W0, 403, 479,4-9 L-2014-029Attachment 4Page 1 of 12License Amendment Request forAdoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas AccumulationAttachment 4St. Lucie Unit 1Technical Specifications Bases ChangesMarked Up PagesFor Information Only L-2014-029Attachment 4Page 2 of 12SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PAGEL.3/4.4 BASES ATTACHMENT 6 OF ADM-25.04 3 df'36R VISCNN.: REACTOR COOLANT SYSTEM-6-ST. LUCIE UNIT 1BASES F OR SECTION 314.4 77,'3/4.4 REACTOR COOLANT SYSTEMBASES3W4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATIONThe plant is designed to operate with both reactor coolant loops andassociated reactor coolant pumps in operation, and maintain DNBR abovethe DNBR limit during all normal operations and anticipated transients. InMODES 1 and 2 with one reactor coolant loop not in operation, thisspecification requires that the plant be in at least HOT STANDBY within1 hour.In MODE 3, a single reactor coolant loop provides sufficient heat removalcapability for removing decay heat' however, single failure considerationsrequire that two loops be OPERABLE.in In MODE 4, and in MODE 5 with reactor coolant loops filled, a single<- C reactor coolant loop or shutdown cooling loop provides sufficient heat0 LU removal capability for removing decay heat; but single failure.s considerations require that at least two loops (either shutdown cooling or.L E RCS) be OPERABLE. In MODE 5 with reactor coolant loops not filled, aa single shutdown cooling loop provides sufficient heat removal capabilityfor removing decay heat; but single failure considerations and the-unavailability of the steam generators as a heat removing component,0 require that at leasttwo shutdown cooling loops be OPERABLEE_..4-0The operation of one Reactor Coolant Pump or one shutdown cooling5 pump provides adequate flowto ensure mbing, prevent stratification andproduce gradual reactivity changes during boron concentration reductionsX in the Reactor Coolant System. The reactivity change rate associatedwith boron reductions will, therefore, be within the capability of operatorrecognition and control.If no coolant loops are in operation during shutdown operations,suspending the introduction of coolant into the RCS with boronconcentration less than required to meet the minimum SDM of LCO3.1.1.1 or 3.1.1.2 is required to assure continued safe operation.Introduction of coolant inventory must be from sources that have a boronconcentration greater than what would be required in the RCS forminimum SDM or refueling boron concentration. This may result in anoverall reduction in RCS boron concentration, but provides acceptablemargin to maintaining subcritical operation.
L-2014-029Attachment 4Page 3 of 12SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PAGEt-:.3/4.4 BASES ATTACHM ENT 6 OF ADM-25.04 4 df35RNEVSCIN NO.: REA CTO R COO0LA NT SY STE M ST. LUCIE UNIT 1r.3/4.4 REACTOR COOLANT SYSTEM (continued) [7BASES (continued)314.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION (continued)The restrictions on starting a Reactor Coolant Pump are provided toprevent RCS pressure transients, caused by energy additions from thesecondary system, which could exceed the limits of Appendix G to10 CFR 50. The RCS will be protected against overpressure transientsand will not exceed the limits of Appendix 0 by restricting starting of theReactor Coolant Pumps to when the secondary water temperature of eachsteam generator is less than 30IF above each of the Reactor CoolantSystem cold leg temperatures.3/4.4.2 DELETED INSERT 13/4.4.3 SAFETY VALVES (net page)The pressurizer code safety valves operate to prevent the RCS from beingpressurized above its Safety Limit of 2750 psia. Each safety valve isdesigned to relieve 2 x 105 lbs per hour of saturated steam at the valvesetpoint. The relief capacity of a single safety valve is adequate to relieveany over-pressure condition which could occur during shutdown. In theevent that no safety valves are OPERABLE, an operating shutdowncooling loop, connected to the RCS, provides overpressure reliefcapability and will prevent RCS overpressurization.During operation, all pressurizer code safety valves must be OPERABLEto prevent the RCS from being pressurized above its safety limit of 2750psia. The combined relief capacity of these valves is sufficient to limit theReactor Coolant System pressure to within its Safety Limit of 2750 psiafollowing a complete loss of turbine generator load while operating atRATED THERMAL POWER and assuming no reactor trip until the firstReactor Protective System trip setpoint (Pressurizer Pressure-High) isreached (i.e., no credit istaken for a direct reactor trip on the loss ofturbine) and also assuming no operation of the pressurizer poweroperated relief valve or steam dump valves.Surveillance Requirements are specified in the Inservice Testing Program.Pressurizer code safety valves are to be tested in accordance with therequirements of Section XI of the ASME Code, which provides theactivities and the frequency necessary to satisfy the SurveillanceRequirements. No additional requirements are specified.
L-2014-029Attachment 4Page 4 of 12I'sET1IShutdown Cooling System piping and components have the potential to develop voids andpockets of entrained gases. Preventing and managing gas intrusion and accumulation isnecessary for proper operation of the required shutdown cooling loops and may also preventwater hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel.Selection of Shutdown Cooling System locations susceptible to gas accumulation is based on areview of system design information, including piping and instrument drawings, isometricdrawings, plan and elevation drawings, and calculations. The design review is supplemented bysystem walkdowns to validate the system high points and to confirm the location and orientationof important components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration. Susceptible locationsdepend on plant and system configuration, such as standby versus operating conditions.The Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.Acceptance criteria are established for the volume of accumulated gas at susceptible locations.If accumulated gas is discovered that exceeds the acceptance criteria for the susceptiblelocation (or the volume of accumulated gas at one or more susceptible locations exceeds anacceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance isnot met. If it is determined by subsequent evaluation that the Shutdown Cooling System is notrendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), theSurveillance may be declared met. Accumulated gas should be eliminated or brought within theacceptance criteria limits.Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gasis found, the gas volume is compared to the acceptance criteria for the location. Susceptiblelocations in the same system flow path which are subject to the same gas intrusion mechanismsmay be verified by monitoring a representative subset of susceptible locations. Monitoring maynot be practical for locations that are inaccessible due to radiological or environmentalconditions, plant configuration, or personnel safety concerns. For these locations, alternativemethods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptiblelocations. Monitoring is not required for susceptible locations where the maximum potentialaccumulated gas void volume has been evaluated and determined to not challenge systemOPERABILITY. The accuracy of the method used for monitoring the susceptible locations andtrending of the results should be sufficient to assure system OPERABILITY during theSurveillance interval.SR 4.4.1.3.4 is modified by a Note that states the Surveillance Requirement is not required to beperformed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4. In a rapid shutdown, there may be insufficienttime to verify all susceptible locations prior to entering MODE 4.The 31 -day frequency for ensuring locations are sufficiently filled with water takes intoconsideration the gradual nature of gas accumulation in the SDC System piping and theprocedural controls governing system operation.
L-2014-029Attachment 4Page 5 of 12;E:TION NO.: TITLE: TECHNICAL SPECIFICATIONS FAE: I' I3/4.5 BASES ATTACHMENT 7 OF ADM-25.04 -4 6RIEVSON NO.: EMERGENCY CORE COOLING SYSTEMS (ECCS)-9--- ST. LUCIE UNIT 13/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued)BASES (continued)3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMSThe OPERABILITY of two separate and independent ECCS subsystemsensures that sufficient emergency core cooling capability will be available inthe event of a LOCA assuming the loss of one subsystem through anysingle failure consideration. Either subsystem operating in conjunction withthe safety injection tanks is capable of supplying sufficient core cooling tolimit the peak cladding temperatures within acceptable limits for allpostulated break sizes ranging from the double ended break of the largestRCS cold leg pipe downward. In addition, each ECCS subsystem provideslong term core cooling capability in the recirculation mode during theo2 accident recoverypqýTS 3.5.2.c and 3.5.3.a require that ECCS subsystem(s) have ano independent OPERABLE flow path capable of automatically transferringE suction to the containment sump on a Recirculation Actuation Signal.L The containment sump is defined as the area of containment below the.>: minimumflood level in the vicinity of the containment sump strainers.h- Therefore, the LCOs are satisfied when an independent OPERABLE flowc, path to the containment sump strainer is available.o n TS 3.5.2.d requires that an ECCS subsystem(s) have OPERABLE chargingcaDC pump and associated flow path fromthe BAMT(s). Reference toTS 3.1.2.2_o requires thatthe Train A charging pump flowpath isfrom the BAMT(s)o through the boric acid makeup pump(s). The Train B charging pumpM W flowpath isfrom the BAMT(s) through the gravity feed valve(s).TS 3.5.2, ACTION a.l. provides an allowed outage/action completion time(AOT) of upto 7 daysfrom initial discovery of failure to meet the LCOprovided the affected ECCS subsystem is inoperable only because itsassociated LPSI train is inoperable. This 7 day AOT is based on thefindings of a deterministic and probabilistic safety analysis and is referred toas a "risk-informed" AOT extension. Entry into this ACTION requires that arisk assessment be performed in accordance with the Configuration RiskManagement Program (CRMP) which is described in the AdministrativeProcedure (ADM-17.08) that implements the Maintenance Rule pursuant to10 CFR 50.65.The Surveillance Requirements provided to ensure OPERABILITY of eachcomponent ensure that at a minimum, the assumptions used in the accidentanalyses are met and that subsystem OPERABILITY is maintained.
L-2014-029Attachment 4Page 6 of 12C:TION NO.: TrrLE: TECHNICAL SPECIFICATIONS PAO l3f4.5 BASES ATTACHMENT 7 OF ADM-25.04 56fR FV INN.: EMERGENCY CORE COOLING SYSTEMS (ECCS) 5 o-ST. LUCIE UNIT 131/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued) A- 'K-.-BASES (continued)3/4.5.2 and 3X4.5.3 ECCS SUBSYSTEMS (continued)Periodic surveillance testing of ECCS pumps to detect gross degradationcaused by impeller structural damage or other hydraulic component problemsis required by Section XI of the ASME Code. This type of testing may beaccomplished by measuring the pump developed head at only one point onthe pump characteristic curve. This verifies both that the measuredperformance is within an acceptable tolerance of the original pump baselineperformance and thatthe performance atthe test flow is greater than or equalto the performance assumed in the unit safety analysis. SurveillanceRequirements are specified in the Inservice Testing Program, wthichencompasses Section Xl of the ASME Code.Section XI ofthe ASME Codeprovides the activities and frequencies necessary to satisfy the requirements..TS Surveillance Requirement 4.5.2.c requires that each ECCS shall bedemonstrated OPERABLE by visual inspection which verifies that no loosedebris (rags, trash, clothing, etc.) is present in the containment which couldbe transported to the containment sump and cause restriction of the sumpI- suctions during LOCA conditions.co TS Surveillance Requirement 4.5. 2.d.2 requires that each ECCS subsystemZ- be demonstrated OPERABLE at least overy 18 months by visual inspectionof the containment sump and verifying that the suction inlets are notrestricted by debris and that the sump components (trash racks, screens,etc.) show no evidence of structural distress or corrosion.There are no trash racks or screens associated with the sump components,but the current Technical Specification of"sump components (trash racks,screens, etc.)" sufficiently encompasses the strainer modules. Therefore,the surveillance requirements are satisfied when visual inspection verifiesthat loose debris is not present which could be transported to the strainers,and by visual inspection of the strainer modules and associated equipmentfor structural distress or corrosion.The Iimftations on HPSI pump operability when the RCS temperature ise 270OF and _ 236PF, and the associated Surveillance Requirementsprovide additional administrative assurance that the pressure/temperaturelimits (Figures 3.4-2a and 3.4-2b) will not be exceeded during a massaddition transient mitigated by a single PORV. A limit on the maimumnumber of operable HPSI pumps is not necessary when the pressurizermanway cover or the reactor vessel head is removed.
L-2014-029Attachment 4Page 7 of 12INSERT 2TS Surveillance Requirement 4.5.2.b.1 is modified by a Note which exempts system vent flowpaths opened under administrative control. The administrative control should beproceduralized and include stationing a dedicated individual at the system vent flow path who isin continuous communication with the operators in the control room. The individual will have amethod to rapidly close the system vent path if directed.TS Surveillance Requirement 4.5.2.b.2 ensures that ECCS locations susceptible to gasaccumulation are sufficiently filled with water.ECCS piping and components have the potential to develop voids and pockets of entrainedgases. Preventing and managing gas intrusion and accumulation is necessary for properoperation of the ECCS and may also prevent a water hammer, pump cavitation, andpumping of noncondensible gas into the reactor vessel.Selection of ECCS locations susceptible to gas accumulation is based on a review of systemdesign information, including piping and instrument drawings, isometric drawings, plan andelevation drawings, and calculations. The design review is supplemented by system walkdownsto validate the system high points and to confirm the location and orientation of importantcomponents that can become sources of gas or could otherwise cause gas to be trapped ordifficult to remove during system maintenance or restoration. Susceptible locations depend onplant and system configuration, such as standby versus operating conditions.The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations. If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criterion for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas(i.e., the system is sufficiently filled with water), the Surveillance may be declared met.Accumulated gas should be eliminated or brought within the acceptance criteria limits.ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gasvolume is compared to the acceptance criteria for the location. Susceptible locations in the samesystem flow path which are subject to the same gas intrusion mechanisms may be verified bymonitoring a representative subset of susceptible locations. Monitoring may not be practical forlocations that are inaccessible due to radiological or environmental conditions, plant configuration,or personnel safety concerns. For these locations, alternative methods (e.g., operatingparameters, remote monitoring) may be used to monitor the susceptible locations. Monitoring isnot required for susceptible locations where the maximum potential accumulated gas void volumehas been evaluated and determined to not challenge system OPERABILITY. The accuracy of themethod used for monitoring the susceptible locations and trending of the results should besufficient to assure system OPERABILITY during the Surveillance interval.The 31 -day frequency for SR 4.5.2.b.1 takes into consideration the gradual nature of gasaccumulation in the ECCS piping and the procedural controls governing system operation.
L-2014-029Attachment 4Page 8 of 1210.: TITLE: TECHNICAL SPECIFICATIONS3T4.6 BASES ATTACHMENT 8 OF ADM-25.04 5 0f-10REVS NNO.: 'CONTAINMENT SYSTEMS9 ST. LUCIE UNIT 13/4.6 CONTAINMENT SYSTEMS (continued)BASES (continued)3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMSThe OPERABILITY of the containment spray and cooling systemsensures that depressurization and cooling capability will be available tolimit post-accident pressure and temperature in the containment to>: acceptable values. During a Design Basis Accident (DBA), at least onecontainment cooling train and one containment spray train are capable ofS-J maintaining the peak pressure and temperature within design limits. One-< containment spray train has the capability, in conjunction with the Sprayac Additive System, to remove iodine fromthe containment atmosphere andw0a- maintain concentrations belowthose assumed in the safety analyses. ToE ensure that these conditions can be met considering single-failure criteria,Co C) two spray trains and two cooling trains must be OPERABLE.The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action interval specified in ACTION 1.a and ACTION 1.d, and-.the 7 day action interval specified in ACTION 1.b take into account theredundant heat removal capability and the iodine removal capability of the' ~ remaining operable systems, and the low probability of a DBA occurringduring this period. The 10 day constraint for ACTIONS 1.a and 1.b is* s c based on coincident entry into two ACTION conditions (specified in2,- ACTION 1.c) coupled with the low probability of an accident occurringo during thistime. If the system(s) cannot be restored to OPERABLE statuswithin the specified completion time, alternate actions are designed tobring the unit to a mode for which the LCO does not apply. The extendedinterval (54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />) specified in ACTION 1.a to be in MODE 4 includes48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of additional time for restoration of the inoperable CS train, andtakes into consideration the reduced driving force for a release ofradioactive material fromthe RCS when in MODE 3. With twocontainment spray trains or any combination of three or more containmentspray and containment cooling trains inoperable in MODES 1, 2, or Mode3 with Pressurizer Pressure >_ 1750 psia, the unit is in a condition outsidethe accident analyses and LCO 3.0.3 must be entered immediately. InMODE 3 with Pressurizer Pressure < 1750 psia, containment spray is notrequired.The specifications and bases for LCO 3.6.2.1 are consistent withNUREG-1432, Revision 0 (9/28/92), Specification 3.6.6A (ContainmentSpray and Cooling Systems; Credit taken for iodine removal by theContainment Spray System), and the plant safety analyses.
L-2014-029Attachment 4Page 9 of 12SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PACE:_ ,3X4.6 BASES ATTACHMENT 8 OF ADM-25.04 6 oi1EVISON MO.: CONTAINMENT SYSTEMS-6-- ST. LUCIE UNIT 114.6 CONTAINMENT SYSTEMS (continued)UhSLS (continued)P1/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS (continued)3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS (continued)Ensuring that the containment spray pump discharge pressure is met satisfiesthe periodic surveillance requirementto detect gross degradation caused by ,impeller structural damage or other hydraulic component problems. Along withthis requirement,Section XI of the ASME Code verifies the pump developedhead at one point on the pump characteristic curve to verify both that themeasured performance is within an acceptable tolerance of the original pumpbaseline performance and that the performance at the test flow is greaterthanor equal to the performance assumed in the unit safety analysis. SurveillanceRequirements are specified in the Inservice Testing Program, whichencompasses Section Xl of the ASME Code.Section XI ofthe ASM E Codeprovjdes the activities and frequencies necessary to satisfy the requirements.314.6.2.2 SPRAY ADDITIVE SYSTEM INSERT 3(next page) IThe OPERABILITY of the spray additive system ensures that sufficientNaOH is added to the containment spray in the event of a LOCA. Thelimits on NaOH volume and concentration ensure a containment sump pHvalue of between 7.0 and 9.66 for the solution recirculated withincontainment after a LOCA. This pH band minimizesthe evolution ofiodine and minimizes the effect of chloride and caustic stress corrosion onmechanical systems and components. The contained water volume limitincludes an allowance for water not usable because of tank discharge linelocation or other physical characteristics. These assumptions areconsistent with the iodine removal efficiency assumed in the accidentanalyses.3/4.6.2.3 DELETED314.6.3 CONTAINMENT ISOLATION VALVESThe OPERABILITY of the containment isolation valves ensures that thecontainment atmosphere will be isolated fromthe outside environment inthe event of a release of radioactive material to the containmentatmosphere or pressurization of the containment. Containment isolationwithin the time limits specified ensures that the release of radioactivematerial to the environment will be consistent with the assumptions usedin the analyses for a LOCA.
L-2014-029Attachment 4Page 10 of 12INSERT 3Containment Spray System flow path piping and components have the potential to developvoids and pockets of entrained gases. Preventing and managing gas intrusion andaccumulation is necessary for proper operation of the containment spray trains and may alsoprevent a water hammer and pump cavitation.Selection of Containment Spray System locations susceptible to gas accumulation is based ona review of system design information, including piping and instrument drawings, isometricdrawings, plan and elevation drawings, and calculations. The design review is supplemented bysystem walkdowns to validate the system high points and to confirm the location and orientationof important components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration. Susceptible locationsdepend on plant and system configuration, such as standby versus operating conditions.The Containment Spray System is OPERABLE when it is sufficiently filled with water.Acceptance criteria are established for the volume of accumulated gas at susceptible locations.If accumulated gas is discovered that exceeds the acceptance criteria for the susceptiblelocation (or the volume of accumulated gas at one or more susceptible locations exceeds anacceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance isnot met. If it is determined by subsequent evaluation that the Containment Spray System isnot rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),the Surveillance may be declared met. Accumulated gas should be eliminated or brought withinthe acceptance criteria limits.Containment Spray System locations susceptible to gas accumulation are monitored and, if gasis found, the gas volume is compared to the acceptance criteria forthe location. Susceptiblelocations in the same system flow path which are subject to the same gas intrusion mechanismsmay be verified by monitoring a representative subset of susceptible locations. Monitoring maynot be practical for locations that are inaccessible due to radiological or environmentalconditions, plant configuration, or personnel safety concerns. For these locations, alternativemethods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptiblelocations. Monitoring is not required for susceptible locations where the maximum potentialaccumulated gas void volume has been evaluated and determined to not challenge systemOPERABILITY. The accuracy of the method used for monitoring the susceptible locations andtrending of the results should be sufficient to assure system OPERABILITY during theSurveillance interval.The 31-day frequency for SR 4.6.2.1 .c takes into consideration the gradual nature of gasaccumulation in the Containment Spray System piping and the procedural controls governingsystem operation.TS Surveillance Requirement 4.6.2.1 .a is modified by a Note which exempts system vent flowpaths opened under administrative control. The administrative control should be roceduralizedand include stationing a dedicated individual at the system vent flow path who is in continuouscommunication with the operators in the control room. The individual will have a method torapidly close the system vent path if directed.
L-2014-029Attachment 4Page 11 of 12GSECTIO N NO.: TrTLE: TECHNI CAL SPECIF ICATIO NS AG 3/4.9 BASES ATTACHMENT 11 OF ADM-25. 04 6 6, 6REVLSION NO.: REFUELING OPERATIONS--6-- ST. LUCIE UNIT 1314.9 REFUELING OPERATIONS (continued)BASES (continued)3/4.9.5 COMMUNICATIONSThe requirement for communications capability ensures that refuelingstation personnel can be promptly informed of significant changes in thefacility status or core reactivity condition during CORE ALTERATIONS.3/4.9.6 MANIPULATOR CRANE OPERABILITYThe OPERABIUTIY requirements of the cranes used for movement of fuelassemblies ensures that: 1) each crane has sufficient load capacity to lift afuel element, and 2) the core internals and pressure vessel are protectedfrom excessive lifting force in the event they are inadvertently engagedduring lifting operations.314.9.7 DELETED314.9.8 SHUTDO1VA COOLING AND COOLANT CIRCULATIONThe requirement that at least one shutdown cooling loop be in operationensures that 1) sufficient cooling capacity is available to remove decayheat and maintain the water in the reactor pressure vessel below 1 40PF asrequired during the REFUELING MODE, and 2) sufficient coolantcirculation is maintained through the reactor core to minimize the effects ofa boron dilution incident and prevent boron stratification.'5 mC If SDC loop requirements are not met, there will be no forced circulation too w provide mixing to establish uniform boron concentrations. SuspendingoE a- positive reactivity additions that could result in failure to meet the minimum._E c boron concentration limit is required to assure continued safe operation.a) Introduction of coolant inventory must be from sources that have a boron5 concentration greater than what would be required in the RCS for minimumrefueling boron concentration. This may result in an overall reduction in= *~RCS boron concentration, but provides acceptable margin to maintaining0o subcritical operations._,0-C The requirement to have two shutdown cooling loops OPERABLE when& 0*I = there is less than 23 feet of water above the irradiated fuel in the corecr, -ensuresthat a single failure of the operating shutdown cooling loop will notM ~ result in a complete loss of decay heat removal capability. With the reactorvessel head removed and 23 feet of water above the irradiated fuel in thecore, a large heat sink is available for core cooling, thus in the event of afailure of the operating shutdown cooling loop, adequate time is provided toinitiate emergency proceduresto cool the core.JINSERT 4 (next page)
L-2014-029Attachment 4Page 12 of 12INSERT 4Shutdown Cooling System piping and components have the potential to develop voids andpockets of entrained gases. Preventing and managing gas intrusion and accumulation isnecessary for proper operation of the Shutdown Cooling loops and may also preventwater hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.Selection of Shutdown Cooling System locations susceptible to gas accumulation is based on areview of system design information, including piping and instrument drawings, isometricdrawings, plan and elevation drawings, and calculations. The design review is supplemented bysystem walkdowns to validate the system high points and to confirm the location and orientationof important components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration. Susceptible locationsdepend on plant and system configuration, such as standby versus operating conditions.The Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.Acceptance criteria are established for the volume of accumulated gas at susceptible locations.If accumulated gas is discovered that exceeds the acceptance criteria for the susceptiblelocation (or the volume of accumulated gas at one or more susceptible locations exceeds anacceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance isnot met. If it is determined by subsequent evaluation that the Shutdown Cooling System isnot rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),the Surveillance may be declared met. Accumulated gas should be eliminated or brought withinthe acceptance criteria lirTfts.Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gasis found, the gas volume is compared to the acceptance criteria for the location. Susceptiblelocations in the same system flow path which are subject to the same gas intrusion mechanismsmay be verified by monitoring a representative subset of susceptible locations. Monitoring maynot be practical for locations that are inaccessible due to radiological or environmentalconditions, plant configuration, or personnel safety concerns. For these locations, alternativemethods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptiblelocations. Monitoring is not required for susceptible locations where the maximum potentialaccumulated gas void volume has been evaluated and determined to not challenge systemOPERABILITY. The accuracy of the method used for monitoring the susceptible locations andtrending of the results should be sufficient to assure system OPERABILITY during theSurveillance interval.The 31-day frequency for ensuring locations are sufficiently filled with water takes intoconsideration the gradual nature of gas accumulation in the Shutdown Cooling System pipingand the procedural controls governing system operation.
L-2014-029Attachment 5Page 1 of 8License Amendment Request forAdoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas AccumulationAttachment 5St. Lucie Unit 2Technical Specifications ChangesMarked Up Pages3/4 4-43/4 4-53/4 4-63/4 5-4314 6-15a3/4 9-83/4 9-9 L-2014-029Attachment 5Page 2 of 8REACTOR COOLANT SYSTEMHOT SHUTDOWNSURVEILLANCE REQUIREMENTS4.4.1.3.1 The required Reactor Coolant pump(s), if not in operation, shall bedetermined to be OPERABLE once per 7 days by verifying correct breakeralignments and indicated power availability.4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE byverifying the secondary side water level to be > 10% indicated narrow rangelevel at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.3 At least one Reactor Coolant or shutdown cooling loop shall beverified to be in operation and circulating Reactor Coolant at least once per12 hours.4.4.1.3.4 Verify required shutdown cooling trains locationssusceptible to gas accumulation are sufficiently filled with water atleast once per 31 days.*1* Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.IST. LUCIE -UNIT 2314 4-4TAmendment No.
L-2014-029Attachment 5Page 3 of 8REACTOR COOLANT SYSTEMCOLD SHUTDOWN -LOOPS FILLEDLIMITING CONDITION FOR OPERATION3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and inoperation*, and either:a. One additional shutdown cooling loop shall be OPERABLE, orb. The secondary side water level of at least two steam generatorsshall be greater than 10% indicated narrow range level.APPLICABILITY: MODE 5 with Reactor Coolant loops filledACTION:a. With one of the shutdown cooling loops inoperable and with less thanthe required steam generator level, immediately initiate correctiveZ -action to return the inoperable shutdown cooling loop to OPERABLE-status or to restore the required steam generator level as soon aspossible.UO)M) u) b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less than0_ orequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2t6 Iand immediately initiate corrective action to return the required shutdowno cooling loop to operation.U)ISSURVEILLANCE REOUIREMENTS' 4; 4.4.1.4.1.1 The secondary side water level of at least two steam generators when0 "5 required shall be determined to be within limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.3 A 4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be in0>'1 operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.I-0 0The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided1) no operations are permitted that would cause introduction into the RCS, coolant withC boron concentration less than required to meet the SHUTDOWN MARGIN of TechnicalSpecification 3.1.1.2 and 2) core outlet temperature is maintained at least 10°F below0-c saturation temperature.#Ej One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for(I E surveillance testing provided the other shutdown cooling loop is OPERABLE0 and in operation.S## A Reactor Coolant pump shall not be started with two idle loops unlessthe secondary water temperature of each steam generator Is less than 4OWFabove each of the Reactor Coolant System cold leg temperatures.ST. LUCIE -UNIT 23/4 4-5Amendment No. 46, 34,14, 422-L-2014-029Attachment 5Page 4 of 8REACTOR COOLANT SYSTEMCOLD SHUTDOWN -LOOPS NOT FILLEDLIMITING CONDITION FOR OPERATION3.4.1.4.2 Two shutdown cooling loops shall be OPERABLE# and at least oneshutdown cooling loop shall be in operation.*APPLICABILITY: MODE 5 with reactor coolant loops not filled.ACTION:a. With less than the above required loops OPERABLE, within 1 hourinitiate corrective action to return the required loops to OPERABLEstatus as soon as possible.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate corrective action to return the required shutdowncooling loop to operation.SURVEILLANCE REQUIREMENTS4.4.1.4.2 At least one shutdown cooling loop shall be determined to be inoperation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.2.1 Verify shutdown cooling trains locations susceptible to gasaccumulation are sufficiently filled with water at least once per 31 days.# One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting provided the other shutdown cooling loop is OPERABLE and in operation.The shutdown cooling pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided (1) nooperations are permitted that would cause introduction into the RCS, coolant with boronconcentration less than required to meet the SHUTDOWN MARGIN of TechnicalSpecification 3.1.1.2 and (2) core outlet temperature is maintained at least 101F belowsaturation temperature.ST. LUCIE -UNIT 23/4 4-6Amendment No.
L-2014-029Attachment 5Page 5 of 8EMERGENCY CORE COOLING SYSTEMSSURVEILLANCE REQUIREMENTS4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following valvesare in the indicated positions with power to the valve operatorsremoved:Valve Numbera. V3733V3734b. V3735V3736c. V3737V3738V3739V3740Valve Functiona. SIT VentValvesb. SITVentValvesc. SIT Vent ValvesValve Positiona. Locked Closedb. Locked Closedc. Locked Closed)towWi .2.Q W0..t U)-_ 0_ 1=b. At least once per 31 days by verifying that each valve (manual,power-operated or automatic) in the flow path that is not locked,sealed, or otherwise secured In position, Is in its correct c. B.ha EGGS piping at L..__1Zaccsible p -- s follow " ligc-e, shutdowncl orany " ich could caused. By a visual inspection which verifies that no loose debris (rags,trash, clothing, etc.) is present in the containment which could betransported to the containment sump and cause restriction of thepump suctions during LOCA conditions. This visual inspection shallbe performed:1. For all accessible areas of the containment prior toestablishing CONTAINMENT INTEGRITY, and2. At least once daily of the areas affected within containmentby the containment entry and during the final entry whenCONTAINMENT INTEGRITY is established.-14e. At least once per 18 months by:1. Verifying automatic isolation and interlock action of theshutdown cooling system from Reactor Coolant System whenRCS pressure (actual or simulated) is greater than or equal to515 psia, and that the interlocks prevent opening the shutdowncooling system isolation valves when RCS pressure (actual orsimulated) is greater than or equal to 276 psia.1* Not required to be met for system vent flow paths opened under administrative control.ST. LUCIE -UNIT 23/4 5-4Amendment N o. -?-
L-2014-029Attachment 5Page 6 of 8SURVEILLANCE REQUIREMENTS4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:a. At least once per 31 days by verifying that each valve (manual, power-operated, orautomatic) in the flow path that is not locked, sealed, or otherwise secured inposition, is positioned to take suction from the RWT on a Containment Pressure --High-High test signal.b. By verifying that each spray pump develops the specified discharge pressure whentested pursuant to the Inservice Testing Program.c. At least once per 18 months, during shutdown, by:1. Verifying that each automatic valve in the flow path actuates to its correctposition on a CSAS test signal.2. Verifying that upon a Recirculation Actuation Test Signal (RAS), thecontainment sump isolation valves open and that a recirculation mode flowpath via an OPERABLE shutdown cooling heat exchanger is established.d. At least once per 31 days, by verifying containment spray system locationssusceptible to gas accumulation are sufficiently filled with water.i Not required to be met for system vent flow paths opened under administrative control. IST. LUCIE -UNIT 2314 6-15aAmendment No.- 2, ", 48&-
L-2014-029Attachment 5Page 7 of 8REFUELING OPERATIONS314.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATIONHIGH WATER LEVELLIMITING CONDITION FOR OPERATION3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation.*APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vesselflange is greater than or equal to 23 feet.ACTION:With no shutdown cooling loop OPERABLE and in operation, suspend all operations involving anincrease in reactor decay heat load or operations that would cause introduction into the RCS,coolant with boron concentration less than required to meet the boron concentration of TechnicalSpecification 3.9.1 and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate corrective action to return the required shutdowncooling loop to OPERABLE and operating status as soon as possible. Close all containmentpenetrations providing direct access from the containment atmosphere to the outside atmospherewithin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.SURVEILLANCE REQUIREMENTS4.9.8.1 At least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s:a. At least one shutdown cooling loop shall be verified to be in operationb. The total flow rate of reactor coolant to the reactor pressure vessel shall beverified to be greater than or equal to 3000 gpm.**4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gas accumulationare sufficiently filled with water at least once per 31 daysThe shutdown cooling loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour periodduring the performance of CORE ALTERATIONS in the vicinity of reactor pressure vesselhot legs, provided no operations are permitted that would cause introduction into the RCS,coolant with boron concentration less than required to meet the SHUTDOWN MARGIN ofTechnical Specification 3.9.1.The reactor coolant flow rate requirement may be reduced to 1850 gpm if the followingconditions are satisfied before the reduced requirement is implemented: the reactor hasbeen determined to have been subcritical for at least 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />, the maximum RCStemperature is _< 1170F, and the temperature of CCW to the shutdown cooling heatexchanger is < 870F.ST. LUCIE
- UNIT 23/4 9-8Amendment No. 76, 122 L-2014-029Attachment 5Page 8 of 8REFUELING OPERATIONSLOW WATER LEVELLIMITING CONDITION FOR OPERATION3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and at least oneshutdown cooling loop shall be in operation.-APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vesselflange is less than 23 feet.ACTION:a. With less than the required shutdown cooling loops OPERABLE, within 1 hourinitiate corrective action to return the required loops to OPERABLE status, or toestablish greater than or equal to 23 feet of water above the reactor pressurevessel flange, as soon as possible.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet the boron concentration of Technical Specification 3.9.1 andwithin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate corrective action to return the required shutdown coolingloop to operation. Close all containment penetrations providing direct accessfrom the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.SURVEILLANCE REQUIREMENTS4.9.8.2 At least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s:a. At least one shutdown cooling loop shall be verified to be in operation.b. The total flow rate of reactor coolant to the reactor pressure vessel shall beverified to be greater than or equal to 3000 gpm.'4.9.8.2.1 Verify shutdown cooling trains locations susceptible to gasaccumulation are sufficiently filled with water at least once per 31 daysThe reactor coolant flow rate requirement may be reduced to 1850 gpm if the followingconditions are satisfied before the reduced requirement is implemented: the reactor hasbeen determined to have been subcritical for at least 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />, the maximum RCStemperature is < 11 7F, and the temperature of CCW to the shutdown cooling heatexchanger is < 87*F.One required shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting, provided that the other shutdown cooling loop is OPERABLE and in operation.ST. LUCIE -UNIT 2 3/4 9.9 Amendment No. 48, 0, 7-6, 422, 430,-4118 L-2014-029Page 1 of 8License Amendment Request forAdoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas AccumulationAttachment 6St. Lucie Unit 2Technical Specifications ChangesRetyped/Clean Pages3/4 4-43/4 4-53/4 4-63/4 5-43/4 6-15a3/4 9-83/4 9-9 L-2014-029Page 2 of 8REACTOR COOLANT SYSTEMHOT SHUTDOWNSURVEILLANCE REQUIREMENTS4.4.1.3.1 The required Reactor Coolant pump(s), if not in operation, shall bedetermined to be OPERABLE once per 7 days by verifying correct breakeralignments and indicated power availability.4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE byverifying the secondary side water level to be > 10% indicated narrow rangelevel at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.3.3 At least one Reactor Coolant or shutdown cooling loop shall beverified to be in operation and circulating Reactor Coolant at least once per12 hours.4.4.1.3.4 Verify required shutdown cooling trains locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.*Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.ST. LUCIE -UNIT 23/4 4-4 Amendment No. L-2014-029Page 3 of 8REACTOR COOLANT SYSTEMCOLD SHUTDOWN -LOOPS FILLEDLIMITING CONDITION FOR OPERATION3.4.1.4.1 At least one shutdown cooling loop shall be OPERABLE and inoperation*, and either:a. One additional shutdown cooling loop shall be OPERABLE#, orb. The secondary side water level of at least two steam generatorsshall be greater than 10% indicated narrow range level.APPLICABILITY: MODE 5 with Reactor Coolant loops filledACTION:a. With one of the shutdown cooling loops inoperable and with less thanthe required steam generator level, immediately initiate correctiveaction to return the inoperable shutdown cooling loop to OPERABLEstatus or to restore the required steam generator level as soon aspossible.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2and immediately initiate corrective action to return the required shutdowncooling loop to operation.SURVEILLANCE REQUIREMENTS4.4.1.4.1.1 The secondary side water level of at least two steam generators whenrequired shall be determined to be within limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.2 At least one shutdown cooling loop shall be determined to be inoperation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.1.3 Verify required shutdown cooling trains locations susceptible to gas accumulationare sufficiently filled with water at least once per 31 days.The shutdown cooling pump may be de-energized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided1) no operations are permitted that would cause introduction into the RCS, coolant withboron concentration less than required to meet the SHUTDOWN MARGIN of TechnicalSpecification 3.1.1.2 and 2) core outlet temperature is maintained at least 10F belowsaturation temperature.# One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> forsurveillance testing provided the other shutdown cooling loop is OPERABLEand in operation.A Reactor Coolant pump shall not be started with two idle loops unlessthe secondary water temperature of each steam generator is less than 40PFabove each of the Reactor Coolant System cold leg temperatures.ST. LUCIE -UNIT 23/4 4-5Amendment No. 46, 34,46,422 L-2014-029Page 4 of 8REACTOR COOLANT SYSTEMCOLD SHUTDOWN -LOOPS NOT FILLEDLIMITING CONDITION FOR OPERATION3.4.1.4.2 Two shutdown cooling loops shall be OPERABLE# and at least oneshutdown cooling loop shall be in operation.*APPLICABILITY: MODE 5 with reactor coolant loops not filled.ACTION:a. With less than the above required loops OPERABLE, within 1 hourinitiate corrective action to return the required loops to OPERABLEstatus as soon as possible.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet SHUTDOWN MARGIN of Technical Specification 3.1.1.2and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate corrective action to return the required shutdowncooling loop to operation.SURVEILLANCE REQUIREMENTS4.4.1.4.2 At least one shutdown cooling loop shall be determined to be inoperation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.4.1.4.2.1 Verify shutdown cooling trains locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.# One shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting provided the other shutdown cooling loop is OPERABLE and in operation.The shutdown cooling pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided (1) nooperations are permitted that would cause introduction into the RCS, coolant with boronconcentration less than required to meet the SHUTDOWN MARGIN of TechnicalSpecification 3.1.1.2 and (2) core outlet temperature is maintained at least 10*F belowsaturation temperature.ST. LUCIE -UNIT 23/4 4-6Amendment No. 42-2 L-2014-029Page 5 of 8EMERGENCY CORE COOLING SYSTEMSSURVEILLANCE REQUIREMENTS4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following valvesare in the indicated positions with power to the valve operatorsremoved:Valve Number Valve Function Valve Positiona. V3733 a. SITVent Valves a. Locked ClosedV3734b. V3735 b. SITVent Valves b. Locked ClosedV3736c. V3737 c. SITVentValves c. Locked ClosedV3738V3739V3740b. At least once per 31 days by verifying that each valve (manual,power-operated or automatic) in the flow path that is not locked,sealed, or otherwise secured in position, is in its correct position.*c. At least once per 31 days, by verifying ECCS locations susceptible to gasaccumulation are sufficiently filled with water.d. By a visual inspection which verifies that no loose debris (rags,trash, clothing, etc.) is present in the containment which could betransported to the containment sump and cause restriction of thepump suctions during LOCA conditions. This visual inspection shallbe performed:1. For all accessible areas of the containment prior toestablishing CONTAINMENT INTEGRITY, and2. At least once daily of the areas affected within containmentby the containment entry and during the final entry whenCONTAINMENT INTEGRITY is established.e. At least once per 18 months by:1. Verifying automatic isolation and interlock action of theshutdown cooling system from Reactor Coolant System whenRCS pressure (actual or simulated) is greater than or equal to515 psia, and that the interlocks prevent opening the shutdowncooling system isolation valves when RCS pressure (actual orsimulated) is greater than or equal to 276 psia.Not required to be met for system vent flow paths opened under administrative control.ST. LUCIE -UNIT 23/4 5-4Amendment No.-7 L-2014-029Page 6 of 8SURVEILLANCE REQUIREMFNTS4.6.2.1 Each containment spray system shall be demonstrated OPERABLE:a. At least once per 31 days by verifying that each valve (manual, power-operated, orautomatic) in the flow path that is not locked, sealed, or otherwise secured inposition, is positioned to take suction from the RWT on a Containment Pressure --High-High test signal.*b. By verifying that each spray pump develops the specified discharge pressure whentested pursuant to the Inservice Testing Program.c. At least once per 18 months, during shutdown, by:1. Verifying that each automatic valve in the flow path actuates to its correctposition on a CSAS test signal.2. Verifying that upon a Recirculation Actuation Test Signal (RAS), thecontainment sump isolation valves open and that a recirculation mode flowpath via an OPERABLE shutdown cooling heat exchanger is established.d. At least once per 31 days, by verifying containment spray system locationssusceptible to gas accumulation are sufficiently filled with water.Not required to be met for system vent flow paths opened under administrative control..ST. LUCIE -UNIT 23/4 6-15aAmendment No. 7-0, 04,4 L-2014-029Page 7 of 8REFUELING OPERATIONS314.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATIONHIGH WATER LEVELLIMITING CONDITION FOR OPERATION3.9.8.1 At least one shutdown cooling loop shall be OPERABLE and in operation.*APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vesselflange is greater than or equal to 23 feet.ACTION:With no shutdown cooling loop OPERABLE and in operation, suspend all operations involving anincrease in reactor decay heat load or operations that would cause introduction into the RCS,coolant with boron concentration less than required to meet the boron concentration of TechnicalSpecification 3.9.1 and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate corrective action to return the required shutdowncooling loop to OPERABLE and operating status as soon as possible. Close all containmentpenetrations providing direct access from the containment atmosphere to the outside atmospherewithin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.SURVEILLANCE REQUIREMENTS4.9.8.1 At least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s:a. At least one shutdown cooling loop shall be verified to be in operationb. The total flow rate of reactor coolant to the reactor pressure vessel shall beverified to be greater than or equal to 3000 gpm.**4.9.8.1.1 Verify required shutdown cooling loop locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.The shutdown cooling loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour periodduring the performance of CORE ALTERATIONS in the vicinity of reactor pressure vesselhot legs, provided no operations are permitted that would cause introduction into the RCS,coolant with boron concentration less than required to meet the SHUTDOWN MARGIN ofTechnical Specification 3.9.1.The reactor coolant flow rate requirement may be reduced to 1850 gpm if the followingconditions are satisfied before the reduced requirement is implemented: the reactor hasbeen determined to have been subcritical for at least 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />, the maximum RCStemperature is < 11 7F, and the temperature of CCW to the shutdown cooling heatexchanger is < 87*F.ST. LUCIE -UNIT 23/4 9-8Amendment No. :76, 422 L-2014-029Page 8 of 8REFUELING OPERATIONSLOW WATER LEVELLIMITING CONDITION FOR OPERATION3.9.8.2 Two independent shutdown cooling loops shall be OPERABLE and at least oneshutdown cooling loop shall be in operation.-APPLICABILITY: MODE 6 when the water level above the top of the reactor pressure vesselflange is less than 23 feet.ACTION:a. With less than the required shutdown cooling loops OPERABLE, within 1 hourinitiate corrective action to return the required loops to OPERABLE status, or toestablish greater than or equal to 23 feet of water above the reactor pressurevessel flange, as soon as possible.b. With no shutdown cooling loop in operation, suspend operations that wouldcause introduction into the RCS, coolant with boron concentration less thanrequired to meet the boron concentration of Technical Specification 3.9.1 andwithin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate corrective action to return the required shutdown coolingloop to operation. Close all containment penetrations providing direct accessfrom the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.SURVEILLANCE REQUIREMENTS4.9.8.2 At least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s:a. At least one shutdown cooling loop shall be verified to be in operation.b. The total flow rate of reactor coolant to the reactor pressure vessel shall beverified to be greater than or equal to 3000 gpm.*4.9.8.2.1 Verify shutdown cooling trains locations susceptible to gas accumulation aresufficiently filled with water at least once per 31 days.The reactor coolant flow rate requirement may be reduced to 1850 gpm if the followingconditions are satisfied before the reduced requirement is implemented: the reactor hasbeen determined to have been subcritical for at least 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />, the maximum RCStemperature is < 11 7F, and the temperature of CCW to the shutdown cooling heatexchanger is < 870F.One required shutdown cooling loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillancetesting, provided that the other shutdown cooling loop is OPERABLE and in operation.ST. LUCIE -UNIT 2 3/4 9-9 Amendment No. 48, 40, 76, 4-22, 4465 L-2014-029Attachment 7Page 1 of 13License Amendment Request forAdoption of Technical Specifications Task Force Traveler(TSTF)-523, Revision 2,Generic Letter 2008-01, Managing Gas AccumulationAttachment 7St. Lucie Unit 2Technical Specifications Bases ChangesMarked Up PagesFor Information Only L-2014-029Attachment 7Page 2 of 13Pa&TPJN NO.: P iE ,1,: :TrrLE: TECHNICAL SPECIFICATIONS A .314.4 BASES ATTACHM ENT 6 OF ADM-25.04( of 37,RAFV GIN NO.: REACTOR COOLANT SYSTEM rf .-9--- ST. LUCIE UNIT2 2BASES FOR SECTION 3/4.4 K_.3/4.4 REACTOR COOLANT SYSTEM314.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATIONThe plant is designed to operate with both reactor coolant loops andassociated reactor coolant pumps in operation, and maintain DNBR abovethe DNBR limit during all normal operations and anticipated transients. InMODES 1 and 2 with one reactor coolant loop not in operation, thisspecification requires that the plant be in at least HOT STANDBY within 1hour.In MODE 3, a single reactor coolant loop provides sufficient heat removalcapability for removing decay heat; however, single failure considerationsrequire that two loops be OPERABLE.In MODE 4, and in MODE 5 with reactor coolant loops filled, a single reactorH coolant loop or shutdown cooling loop provides sufficient heat removalLi capability for removing decay heat; but single failure considerations require'E M that at least two loops (either shutdown cooling or RCS) be OPERABLE-. a In M ODE 5 with reactor coolant loops not filled, a single shutdown cooling.E o loop provides sufficient heat removal capability for removing decay heat; but.s2 E single failure considerations and the unavailability or the steam generators asCDZ5 a heat removing component, require that at least two shutdown cooling loops> I be OPERABLE7-E The operation of one reactor coolant pump or one shutdown cooling pumpprovides adequate flow to ensure mixing, prevent stratification and produce2 ~gradual reactivity changes during boron concentration reductions in theReactor Coolant System. The reactivity change rate associated with boronM -reductions will, therefore, be within the capability of operator recognition and-control.If no coolant loops are in operation during shutdown operations, suspendingthe introduction of coolant into the RCS with boron concentration less thanrequired to meet the minimum SDM of LCO 3.1.1.1 or 3.1.1.2 is required toassure continued safe operation. Introduction of coolant inventory must befrom sourcesthat have a boron concentration greaterthan what would berequired in the RCS for minimum SDM or refueling boron concentration. Thismay result in an overall reduction in RCS boron concentration, but providesacceptable margin to maintaining subcritical operation.
L-2014-029Attachment 7Page 3 of 13SECTION NO.: TITLE: TECHNICAL SPECIFICATIONS PXOE,;,3f4.4 BASES ATTACHMENT 6 OF ADM-25.04 7 '. .LEVSIONO.: REACTOR COOLA NT SYSTEM9 ST. LUCIE UNIT 2314.4 REACTOR COOLANT SYSTEM (continued)BASES (continued)3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION (continued)The restriction on starting a reactor coolant pump in MODES 4 and 5, withtwo idle loops and one or more RCS cold leg temperatures lessthan or equalto that specified in Table 3.4-3 is provided to prevent RCS pressuretransients, caused by energy additions from the secondary system fromexceeding the limits of Appendix 0 to 10 CFR 50. The RCS will be protectedagainst overpressure transients by (1) sizing each PORV to mitigate thepressure transient of an inadvertent safety injection actuation in a water-solidRCS with pressurizer heaters energized, (2) restricting starting of the RCPsto when the secondary water temperature of each steam generator is lessthan 40?F above each of the RCS cold leg temperatures, (3) using SDCRVsto mitigate RCP start transients and the transients caused by inadvertentSIAS actuation and charging water, and (4) rendering one HPSI pumpinoperable when the RCS is at low temperatures.314.4.2 SAFETY1VALVES Insert 1 (next page)The pressurizer code safety valves operate to prevent the RCS from beingpressurized above its Safety Limit of 2750 psia. Each safety valve isdesigned to relieve 212,182 lbs per hour of saturated steam atthe valvesetpoint. The relief capacity of a single safety valve is adequate to relieveany overpressure condition which could occur during shutdown. In the eventthat no safety valves are OPERABLE, an operating shutdown cooling loop,connected to the RCS, provides overpressure relief capability and willprevent RCS overpressurization. In addition, the Overpressure ProtectionSystem provides a diverse means of protection against RCSoverpressurization at low temperatures.During operation, all pressurizer code safety valves must be OPERABLE toprevent the RCS from being pressurized above its safety limit of 2750 psia.The combined relief capacity of these valves is sufficient to limit the systempressure to within its Safety Limit of 2750 psia following a complete loss ofturbine generator load while operating at RATED THERMAL POWER andassuming no reactortrip until the first Reactor Protective System trip setpoint(Pressurizer Pressure-High) is reached (i.e., no credit is taken for a directreactortrip on the loss of turbine) and also assuming no operation of thepressurizer power-operated relief valve or steam dump valves.
L-2014-029Attachment 7Page 4 of 13iisERT 1Shutdown Cooling System piping and components have the potential to develop voids andpockets of entrained gases. Preventing and managing gas intrusion and accumulation isnecessary for proper operation of the required shutdown cooling loops and may also preventwater hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel.Selection of Shutdown Cooling System locations susceptible to gas accumulation is based on areview of system design information, including piping and instrument drawings, isometricdrawings, plan and elevation drawings, and calculations. The design review is supplemented bysystem walkdowns to validate the system high points and to confirm the location and orientationof important components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration. Susceptible locationsdepend on plant and system configuration, such as standby versus operating conditions.The Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.Acceptance criteria are established for the volume of accumulated gas at susceptible locations.If accumulated gas is discovered that exceeds the acceptance criteria for the susceptiblelocation (or the volume of accumulated gas at one or more susceptible locations exceeds anacceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance isnot met. If it is determined by subsequent evaluation that the Shutdown Cooling System is notrendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), theSurveillance may be declared met. Accumulated gas should be eliminated or brought within theacceptance criteria limits.Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gasis found, the gas volume is compared to the acceptance criteria for the location. Susceptiblelocations in the same system flow path which are subject to the same gas intrusion mechanismsmay be verified by monitoring a representative subset of susceptible locations. Monitoring maynot be practical for locations that are inaccessible due to radiological or environmentalconditions, plant configuration, or personnel safety concerns. For these locations, alternative methods(e.g., operating parameters, remote monitoring) may be used to monitor the susceptiblelocations. Monitoring is not required for susceptible locations where the maximum potentialaccumulated gas void volume has been evaluated and determined to not challenge systemOPERABILITY. The accuracy of the method used for monitoring the susceptible locations andtrending of the results should be sufficient to assure system OPERABILITY during theSurveillance interval.SR 4.4.1.3.4 is modified by a Note that states the Surveillance Requirement is not required to beperformed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4. In a rapid shutdown, there may be insufficienttime to verify all susceptible locations prior to entering MODE 4.The 31 -day frequency for ensuring locations are sufficiently filled with water takes intoconsideration the gradual nature of gas accumulation in the SDC System piping and theprocedural controls governing system operation.
L-2014-029Attachment 7Page 5 of 13SBC:TIN NO.: TrTLE: TECHNICAL SPECIFICATIONS .....314.5 BASES ATTACHMENT 7 OF ADM-25.04 AREV ISIO N NO.: EMERGENCY CORE COOLING SYSTEMS (ECCS) --of7)-. ST. LUCIE UNIT 23/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued) '7777,BASES (continued)314.5.2 and 34.&5.3 EC CS SUBSYSTEMSThe OPERABIUTY of two separate and independent ECCS subsystemsensures that sufficient emergency core cooling capability will be availablein the event of a LOCA assuming the loss of one subsystem through anysingle failure consideration. Either subsystem operating in conjunctionwith the safety injection tanks is capable of supplying sufficient corecooling to limit the peak cladding temperatures within acceptable limits forall postulated break sizes ranging from the double-ended break of thelargest RCS hot leg pipe downward. In addition, each ECCS subsystemprovides long-term core cooling capability in the recirculation mode duringthe accident recovery .perinri-TS 3.5.2. c and 3.5.3 require that ECCS subsysterr(s) have an independento OPERABLE flow path capable of automatically transferring suction to thecontainment on a Recirculation Actuation Signal. The containment sump isdefined as the area of containment below the minimum flood level in theo >_ vicinity of the containment sump strainers. Therefore, the LCOs are satisfied.--- -q when an independent OPERABLE flow path to the containment sump strainer-- mn is available.> I TS 3.5.2.d requiresthat an ECCS subsystem(s) have an OPERABLEc0 charging pump and associated flow path from the BAMT(s). Reference toTS3.1.2.2 requires that the one charging pump flow path is from the BAMT(s)týD- through the boric acid makeup pump(s). The second charging pump flowpath2 iP isfromthe BAMT(s)through the gravity feed valves.C._oC'; TS 3.5.2, ACTION a.l. provides an allowed outage/action completion time(AOT) of up to 7 days from initial discovery of failure to meet the LCOprovided the affected ECCS subsystem is inoperable only because itsassociated LPSI train is inoperable. This 7 day AOT is based on thefindings of a deterministic and probabilistic safety analysis and is referredto as a "risk-informed"AOT extension. Entry into this ACTION requiresthat a risk assessment be performed in accordance with the ConfigurationRisk Management Program (CRMP) which is described in theAdministrative Procedure (ADM-1 7.08) that implements the MaintenanceRule pursuantto 10 CFR 50.65.In Mode 3 with RCS pressure < 1750 psia and in Mode 4, oneOPERABLE ECCS subsystem is acceptable without single failureconsideration on the basis ofthe stable reactivity condition of the reactorand the limited core cooling requirements.
L-2014-029Attachment 7Page 6 of 13TrrLE: TECHNICAL SPECIFICATIONS .A -,T 4.5 BASES ATTACHMENT 7 OF ADM-25.04 .REV IO N ND.: EMERGENCY CORE COOLING SYSTEMS (ECCS) Li of 7--2--- ST. LUCIE UNIT 2314.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) (continued)BASES (continued)314.5.2 and 3f4.5.3 ECCS SUBSYSTEMS (continued)S eriodic surveillance testing ofECCS pumpsto detect gross degradationcaused by impeller structural damage or other hydraulic component problems2is required by Section XI of the ASME Code. This type of testing may beaccomplished by measuring the pump developed head at only one point onC the pump characteristic curve. This verifies both that the measuredperformance is within an acceptable tolerance of the original pump baselineH performance and thatthe performance at the test flow is greaterthan or equaluJ to the performance assumed in the unit safety analysis. SurveillanceZ Requirements are specified in the Inservice Testing Program, whichencompassesSection XI of the ASME Code.Section XI of the ASME Codeprovides the activities and frequencies necessary to satisfy the requirements.* Refer to UFSAR for flow balancing requirementsThe practice of calibrating and testing the SDC isolation valve interlockfunction below 515 psia (the current plant practice is to set and test theinterlock function at 500 psia) meets the requirements of TechnicalSpecification Surveillance 4.5.2.e.1. The staff accepted that testing theSDC isolation interlock at a more conservative setpoint demonstratesoperability at and above the setpoint (NRC letter from William C. G leavesto J.A. Stall dated November 2, 1999, subject"St. Lucie Unit 2-Amendment Request Regarding Safety Injection Tank and ShutdownCooling System Isolation Interlock Surveillances (TAC No. MA561 9).<- INSERT 3 (next page)314.5.4 REFUELING WATER TANKThe OPERABILITY of the Refueling Water Tank (RW-T) as part oftheECCS ensuresthat a sufficient supply of borated water is available forinjection by the ECCS in the event of a LOCA. The limits on RVVTminimum volume and boron concentration ensure that (1) sufficient wateris available within containment to permit recirculation cooling flow to thecore, and (2) the reactor will remain subcritical in the cold conditionfollowing mixing of the RWT and the RCS water volumes with all controlrods inserted except for the most reactive control assembly. Theseassumptions are consistent with the LOCA analyses.The contained water volume limit includes an allowance forwater notusable because of tank discharge line location or other physicalcharacteristics.
L-2014-029Attachment 7Page 7 of 13INSERT 2TS Surveillance Requirement 4.5.2.b is modified by a Note which exempts system vent flowpaths opened under administrative control. The administrative control should beproceduralized and include stationing a dedicated individual at the system vent flow path who isin continuous communication with the operators in the control room. The individual will have amethod to rapidly close the system vent path if directed.INSERT 3ECCS piping and components have the potential to develop voids and pockets of entrainedgases. Preventing and managing gas intrusion and accumulation is necessary for properoperation of the ECCS and may also prevent a water hammer, pump cavitation, andpumping of noncondensible gas into the reactor vessel.Selection of ECCS locations susceptible to gas accumulation is based on a review of systemdesign information, including piping and instrument drawings, isometric drawings, plan andelevation drawings, and calculations. The design review is supplemented by system walkdownsto validate the system high points and to confirm the location and orientation of importantcomponents that can become sources of gas or could otherwise cause gas to be trapped ordifficult to remove during system maintenance or restoration. Susceptible locations depend onplant and system configuration, such as standby versus operating conditions.The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations. If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criterion for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas(i.e., the system is sufficiently filled with water), the Surveillance may be declared met.Accumulated gas should be eliminated or brought within the acceptance criteria limits.ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gasvolume is compared to the acceptance criteria for the location. Susceptible locations in thesame system flow path which are subject to the same gas intrusion mechanisms may beverified by monitoring a representative subset of susceptible locations. Monitoring may not bepractical for locations that are inaccessible due to radiological or environmental conditions,plant configuration, or personnel safety concerns. For these locations, alternative methods(e.g., operating parameters, remote monitoring) may be used to monitor the susceptiblelocations. Monitoring is not required for susceptible locations where the maximum potentialaccumulated gas void volume has been evaluated and determined to not challenge systemOPERABILITY. The accuracy of the method used for monitoring the susceptible locations andtrending of the results should be sufficient to assure system OPERABILITY during theSurveillance interval.The 31 day frequency takes into consideration the gradual nature of gas accumulation in theECCS piping and the adequacy of the procedural controls governing system operation.
L-2014-029Attachment 7Page 8 of 1338mTIDN NO.: PA :lTrrLE: TECHNICAL SPECIFICATIONS ,',<3/4.6 BASES ATTACHMENT 8 OF ADM-25.04 6 of 11 VREV WSN N.: CONTAINMENT SYSTEMS t of 11 ST. LUCIE UNIT 2314.6 CONTAINMENT SYSTEMS (continued) -BALLE (continued)314.6.2 DEPRESSURIZATION AND COOLING SYSTEMS314.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMSThe O PERABILITY of the containment spray and cooling systems ensuresthat depressurization and cooling capability will be available to limit post-accident pressure and temperature in the containment to acceptable values:During a Design Basis Accident (DBA), at least one containment cooling trainand one containment spray train are capable of maintaining the peak pressureand temperature within design limits. One containment spray train has thecapability, in conjunction with the Iodine Removal System, to remove iodineoJ 2 from the containment atmosphere and maintain concentrations below thoseM assumed in the safety analyses. To ensure thatthese conditions can be metconsidering single-failure criteria, two spray trains and two cooling trains musta- be OPERABLE.--E The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action interval specified in ACTION l.a and ACTION 1.d, and theID 7 day action interval specified in ACTION 1 .b take into account the redundantheat removal capability and the iodine removal capability of the remainingoperable systems, and the low probability of a DBA occurring during thisperiod. The 10 day constraint forACTIONS 1.a and 1.b is based on coincidententry into two ACTION conditions (specified in ACTION 1 .c) coupled with thelow probability of an accident occurring during this time. If the system(s)cannot be restored to OPERABLE status within the specified completion time,alternate actions are designed to bring the unitto a mode for which the LCOdoes not apply. The extended interval (54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />) specified in ACTION 1.a tobe in MODE 4 includes 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of additional time for restoration of theinoperable CS train, and takes into consideration the reduced driving force fora release of radioactive material fromthe RCS when in MODE 3. With twocontainment spray trains or any combination of three or more containmentspray and containment cooling trains inoperable in MODES 1, 2, or Mode 3with Pressurizer Pressure > 1750 psia, the unit is in a condition outside theaccident analyses and LCO 3.0.3 must be entered immediately. In MODE 3with Pressurizer Pressure < 1750 psia, containment spray is not required.The specifications and bases for LCO 3.6.2.1 are consistent withNUREG-1432, Revision 0 (9128/92), Specification 3.6.6A (Containment Sprayand Cooling Systems; Credit taken from iodine removal by the ContainmentSpray System), and the plant safety analyses.
L-2014-029Attachment 7Page 9 of 13mBTIJN NO.: PG~;TrrLE: TECHNICAL SPECIFICATIONS PAGE _ 'r3T4.6 BASES ATTACHMENT 8 OF ADM-25.04NEISDN IO.: CONTAINMENT SYSTEMS -: 11 ST. LUCIE UNIT 2314.6 CONTAINMENT SYSTEMS (continued) ;47.BASES (continued)14.6.2 DEPRESSURIZATION AND COOLING SYSTEMS (continued)W4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS (continued)Ensuring thatthe containment spray pump discharge pressure is met satisfiesthe periodic surveillance requirement to detect gross degradation caused byimpeller structural damage or other hydraulic component problems. Along withthis requirement,Section XI of the ASME Code verifies the pump developedhead at one point on the pump characteristic curve to verify both that themeasured performance is within an acceptable tolerance of the original pumpbaseline performance and that the performance at the test flow is greater thanor equal to the performance assumed in the unit safety analysis. SurveillanceRequirements are specified in the Inservice Testing Program, whichencompassesSection XI of the ASME Code.Section XI of the ASME Codeprovides the activities and frequencies necessary to satisfy the requirements.34.6.2.2 IODINE REMOVAL SYSTEM INSERT 4 (next page)The OPERABILITY of the Iodine Removal System ensuresthat sufficient N2Htis added to the containment spray in the event of a LOCA. The limits on N2H4volume and concentration ensure a minimum of 50 ppm of N2H4 concentrationavailable in the spray for a minimum of 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per pump for a total of 13hours to provide assumed iodine decontamination factors on the containmentatmosphere during spray function and ensure a pH value of between 7.0 and8.1 for the solution recirculated within containment after a LOCA. This pHband minimizes the evolution of iodine and minirrizes the effect of chloride andcaustic stress corrosion on mechanical systems and components. Thecontained watervolume limit includes an allowance forwater not usablebecause of tank discharge line location or other physical characteristics.These assumptions are consistent with the iodine removal efficiency assumedin the safety analyses.334.6.2.3 DELETED34.6.3 CONTAINMENT ISOLATION VALVESThe OPERABILITY of the containment isolation valves ensuresthat thecontainment atmosphere will be isolated from the outside environment in theevent of a release of radioactive material to the containment atmosphere orpressurization of the containment and is consistent with the requirements ofGDC 54 through GDC 57 ofAppendixA to 10 CFR Part 50. Containmentisolation within the time limits specified for those isolation valves designed toclose automatically ensures that the release of radioactive material to theenvironment will be consistent with the assumptions used in the analysesfor aLOCA.
L-2014-029Attachment 7Page 10 of 13INSERT 4Containment Spray System flow path piping and components have the potential to developvoids and pockets of entrained gases. Preventing and managing gas intrusion andaccumulation is necessary for proper operation of the containment spray trains and mayalso prevent a water hammer and pump cavitation.Selection of Containment Spray System locations susceptible to gas accumulation is based ona review of system design information, including piping and instrument drawings, isometricdrawings, plan and elevation drawings, and calculations. The design review is supplemented bysystem walkdowns to validate the system high points and to confirm the location and orientationof important components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration. Susceptible locationsdepend on plant and system configuration, such as standby versus operating conditions.The Containment Spray System is OPERABLE when it is sufficiently filled with water.Acceptance criteria are established for the volume of accumulated gas at susceptible locations.If accumulated gas is discovered that exceeds the acceptance criteria for the susceptiblelocation (or the volume of accumulated gas at one or more susceptible locations exceeds anacceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance isnot met. If it is determined by subsequent evaluation that the Containment Spray System isnot rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),the Surveillance may be declared met. Accumulated gas should be eliminated or brought withinthe acceptance criteria limits.Containment Spray System locations susceptible to gas accumulation are monitored and, if gasis found, the gas volume is compared to the acceptance criteria for the location. Susceptiblelocations in the same system flow path which are subject to the same gas intrusion mechanismsmay be verified by monitoring a representative subset of susceptible locations. Monitoring maynot be practical for locations that are inaccessible due to radiological or environmentalconditions, plant configuration, or personnel safety concerns. For these locations, alternative methods(e.g., operating parameters, remote monitoring) may be used to monitor the susceptiblelocations. Monitoring is not required for susceptible locations where the maximum potentialaccumulated gas void volume has been evaluated and determined to not challenge systemOPERABILITY. The accuracy of the method used for monitoring the susceptible locations andtrending of the results should be sufficient to assure system OPERABILITY during theSurveillance interval.The 31-day frequency for SR 4.6.2.1 .d takes into consideration the gradual nature of gasaccumulation in the Containment Spray System piping and the procedural controlsgoverning system operation.TS Surveillance Requirement 4.6.2.1 .a is modified by a Note which exempts systemvent flow paths opened under administrative control. The administrative control should beproceduralized and include stationing a dedicated individual at the system vent flow path whois in continuous communication with the operators in the control room. The individual will havea method to rapidly close the system vent path if directed.
L-2014-029Attachment 7Page 11 of 13SECTION NO.: TITLE TECHNICAL SPECIFICATIONS PAGE:314.9 BASES ATTACHMENT 11 OF ADM-25.04 6 of 8REVISION NO.: REFUELING OPERATIONS-4-- ST. LUCIE UNIT 23/4.9 REFUELING OPERATIONS (continued)BASES (continued)314.9.6 MANIPULATOR CRANEThe OPERABILITY requirements for the refueling machine ensures that:(1) manipulator cranes will be used for movement of fuel assemblies, withor without CEAs, (2) each crane has sufficient load capacity to lift a fuelassembly, with or without CEAs, and (3) the core internals and pressurevessel are protected from excessive lifting force in the event they areinadvertently engaged during lifting operations.3/4.9.7 DELETED3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATIONThe requirement that at least one shutdown cooling loop be in operationensures that (1) sufficient cooling capacity is available to remove decayheat and maintain the water in the reactor pressure vessel below 140OF asrequired during the REFUELING MODE, and (2) sufficient coolantcirculation is maintained through the reactor core to minimize the effects ofa boron dilution incident and prevent boron stratification.If SDC loop requirements are not met, there will be no forced circulation toprovide mixing to establish uniform boron concentrations. Suspendingpositive reactivity additions that could result in failure to meet the minimumboron concentration limit is required to assure continued safe operation.Introduction of coolant inventory must be from sources that have a boronconcentration greater than what would be required in the RCS for minimumrefueling boron concentration. This may result in an overall reduction inRCS boron concentration. but provides acceptable margin to maintainingsubcritical operations.sManaging of gas voids Is important to shutdown coolingIsystem OPERABILITY.
L-2014-029Attachment 7Page 12 of 13SECTION NO.: TITLEE TECHNICAL SPECIFICATIONS PAGE:3/4.9 BASES ATTACHMENT 11 OF ADM-25.04 7 of 8REVISION NO.: REFUELING OPERATIONS-,4--- ST. LUCIE UNIT 23/4.9 REFUELING OPERATIONS (continued)BASES (continued)3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION (continued)The requirement to have two shutdown cooling loops OPERABLE whenthere is less than 23 feet of water above the reactor pressure vessel flangewith irradiated fuel in the core ensures that a single failure of the operatingshutdown cooling loop will not result in a complete loss of decay heatremoval capability. With the reactor vessel head removed and 23 feet ofwater above the reactor pressure vessel flange with irradiated fuel in thecore, a large heat sink is available for core cooling, thus in the event of afailure of the operating shutdown cooling loop, adequate time is provided toinitiate emergency procedures to cool the core.The footnote providing for a minimum reactor coolant flow rate of>_1850 gpm considers one of the two RCS injection points for a SDCStrain to be isolated. The specified parameters include 50 gpm for flowmeasurement uncertainty, and 30F uncertainty for RCS and CCWtemperature measurements. The conditions of minimum shutdown time,maximum RCS temperature, and maximum temperature of CCWto theshutdown cooling heat exchanger are initial conditions specified to assurethat a reduction in flow rate from 3000 gpm to 1800 gpm will not result in atemperature transient exceeding 140OF during conditions when the RCSwater level is at an elevation > 29.5 feet.E 5 (next page) 13/4.9.9 CONTAINMENT ISOLATION SYSTEMThe OPERABILITY of this system ensures that the containment isolationvalves will be automatically isolated upon detection of high radiation levelswithin the containment. The OPERABILITY of this system is required torestrict the release of radioactive material resulting from a fuel handlingaccident of a recently irradiated fuel assembly from the containmentatmosphere to the environment. Recently irradiated fuel is defined as fuelthat has occupied parts of a critical reactor core within the previous 72hours.
L-2014-029Attachment 7Page 13 of 13INSERT 5Shutdown Cooling System piping and components have the potential to develop voids andpockets of entrained gases. Preventing and managing gas intrusion and accumulation isnecessary for proper operation of the Shutdown Cooling loops and may also preventwater hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.Selection of Shutdown Cooling System locations susceptible to gas accumulation is based on areview of system design information, including piping and instrument drawings, isometricdrawings, plan and elevation drawings, and calculations. The design review is supplemented bysystem walkdowns to validate the system high points and to confirm the location and orientationof important components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration. Susceptible locationsdepend on plant and system configuration, such as standby versus operating conditions.The Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.Acceptance criteria are established for the volume of accumulated gas at susceptible locations.If accumulated gas is discovered that exceeds the acceptance criteria for the susceptiblelocation (or the volume of accumulated gas at one or more susceptible locations exceeds anacceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance isnot met. If it is determined by subsequent evaluation that the Shutdown Cooling System isnot rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),the Surveillance may be declared met. Accumulated gas should be eliminated or brought withinthe acceptance criteria limits.Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gasis found, the gas volume is compared to the acceptance criteria for the location. Susceptiblelocations in the same system flow path which are subject to the same gas intrusion mechanismsmay be verified by monitoring a representative subset of susceptible locations. Monitoring maynot be practical for locations that are inaccessible due to radiological or environmentalconditions, plant configuration, or personnel safety concerns. For these locations, alternativemethods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptiblelocations. Monitoring is not required for susceptible locations where the maximum potentialaccumulated gas void volume has been evaluated and determined to not challenge systemOPERABILITY. The accuracy of the method used for monitoring the susceptible locations andtrending of the results should be sufficient to assure system OPERABILITY during theSurveillance interval.The 31 -day frequency for ensuring locations are sufficiently filled with water takes intoconsideration the gradual nature of gas accumulation in the Shutdown Cooling Systempiping and the procedural controls governing system operation.