ML17229A844

From kanterella
Jump to navigation Jump to search
Proposed Tech Specs Removing Obsolete License Conditions & Incorporating Revs Which Clarify Component Operations That Must Be Verified in Response to Containment Sump Recirculation Actuation Signal
ML17229A844
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 08/24/1998
From:
FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17229A843 List:
References
NUDOCS 9808310069
Download: ML17229A844 (35)


Text

St.,Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments L'ce se o di 'ons date and T larificatio TTA ME 3 Letter ST. LUCIE UNIT 1 MARKED-UP TECHNICAL SPECIFICATION PAGES Page 3/4 5-5 Page 3/4 7-20 PDR ADGCK 05000835 l

EMERGENCY CO E C NG SYSTEMS

e. At least once per 18 months, during shutdown, by:

Verifying that each automatic valve in the flow path actuates to its correct position on a Safety Injection Actuation Signal.

Verifying that each of the following pumps start @bmaticalty upon receipt oi a Safely Injection Actuation Signal;

a. High-Pressure Safety Injection Pump.
b. Low-Pressure Safety Injection Pump.

Nyiag-e~urAp-ReereolatieaAetuatiea-Yes -

i9na, e-seatainraeFI~m~sela@e elves-opeA-aA5@e-reeireulatiei-'I-valve-te@~fueliFI~er-tarik4esed:

f. By venfying that each of the following pumps develops the specified total developed head on recirculation flow when tested pursuant to the lnservice Testing Program.
1. High-Pressure Safety Injection pumps: greater than or equal to 2571 ft.
2. Low-Pressure Safety Injection pumps: greater than or equal to 350 ft.

'f n g that upon receipt of an actual or simulated Sump Recirculation Actuation Signal: each Veriyi isolation

'; low-pressure safety. injection pump stops, each containment sump recirculation p

valve to tIle refueling water tank outlet valve closes, and each safety injection system t

refueling water tank closes.

ST. LUCIE - UNIT 1 Amendment No. 26, Be,

'I PLANT SYSTEMS 3/4.7.7 CONTROL ROOM EMERGENCY YENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7.1 The control room emergency ventilation system shall be. OPERABLE with:

a ~ Two booster fans,

b. Two isolation valves in each outside air intake duct, c~ Two isolation valves in the toilet area air exhaust duct,
d. One filter train, t r n o 'n unit ~and Va VeS tn %he k,q A M E, 2, WWO ISO CL+iae n

l f

+e~ <<Iavck duck.

ACTION:

a ~ With one booster fan inoperable, restore the inoperable fan to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours.

b. With one isolation valve per air duct inoperable, operation may continue provided the other isolation valve in the same duct is maintained closed; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

C. With the filter train inoperable, restore the filter train to OPERABl E status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

d. With only one air conditioning unii OPERABLE, restore at 1east two air conditioning units to OPERABLE status within 7 days or be in at, least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

ST. LUCIE - UNIT 1 3/4 7-2O

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments License onditions date and T larificatio to L Lette L-98-2 ST. LUCIE UNIT 2 MARKED-UP TECHNICAL SPECIFICATION PAGE Page 3/4 5-5

EM RGENCY COR C NG SY MS 2..- A visual inspection of the containment sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

3. Verifying that a minimum total of 173 cubic feet of solid granular trisodium phosphate dodecahydrate (TSP) is contained within the TSP storage baskets.

Verifying that when a representative sample of 70.5+ 0.5 grams of TSP from a TSP storage basket is submerged, without agitation, in 10.0+ 0.1 gallons of 120+ 10'F borated water from the RWT, the pH of the mixed solution is raised to greater than or equal to 7 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

f. At least once per 18 months, during shutdown, by:

Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and/or RAS test signals.

2. Verifying that each of the following pumps start'automatically upon receipt of a Safety Injection Actuation Test Signal:
a. High-Pressure Safety Injection pump.
b. Low-Pressure Safety Injection pump.
3. -VeRfyin>ha&+a-Scrap-Reeireulatie~etuatieR-Test-SIQRal-,thecontainment~mp-

-iselatieR-valvesepe~Rd-the-reeireulatio alve-t~e-refueling-water-tank-elesed-.

g. By verifying that each of the following pumps develops the specified total developed head on recirculation flow when tested pursuant to the lnservice Testing Program:
1. High-Pressure Safety Injection pumps: greater than, or equal to 2854 ft.

2, Low'-Pressure Safety Injection pump: greater than or equal to 374 ft.

h. By verifying the correct position of each electrical and/or mechanical position stop for the following ECCS throttle valves:
1. During valve stroMng operation or following maintenance on the valve and prior to declaring the valve OPERABLE when the ECCS subsystems are required to be OPERABLE.

i Verifying that upon receipt of an actual or simulated Sump Recirculation Actuation Signal: each I

low-pressure safety injection pump stops, each containment sump isolation valve opens, each refueling water tank outlet valve closes, and each safety injection system recirculation valve to the, refueling water tank closes.

ST. LUCIE - UNIT 2 Amendment No.

0 r s

-0 8/P7p>>

Distri51.txt Distribution Sheet Priority: Normal From: Elaine Walker Action Recipients: Copies:

Internal Recipients:

~FILE CENTER 01~ Paper Copy External Recipients:

NOAC Paper Copy Total Copies:

Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 003693718

Subject:

St. Lucie Plant, Units 1 and 2, RE: completion of licensing action for generic letter 98-02

, "loss of reactor coolant inventory and associated potential for loss of emergency mitig ation function while in a shutdown condition" Body:

ADAMS DISTRIBUTION NOTIFICATION.

Electronic Recipients can RIGHT CLICK and OPEN the first Attachment to View the Document in ADAMS. The Document may also be viewed by searching for Accession Number ML003693718.

DF01 - Direct Flow Distribution: 50 Docket (PDR Avail)

Docket: 05000335 Docket: 05000389 Page 1

i l

t

    • kg 4

t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 27, 2000

~reruns Mr. T. F. Plunkett President- Nuclear Division Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 83408-0420

SUBJECT:

ST. LUCIE PLANT, UNITS 1 AND 2, RE: COMPLETION OF LICENSING ACTION FOR GENERIC LETTER 98-02, "LOSS OF REACTOR COOLANT INVENTORYAND ASSOCIATED POTENTIAL FOR LOSS OF EMERGENCY MITIGATIONFUNCTION WHILE IN A SHUTDOWN CONDITION" (TAC NOS.

MA4808 AND MA4809)

Dear Mr. Plunkett:

On May 28, 1998, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 98-02, to all holders of operating licenses for Pressurized Water Reactors (PWR), except those who have permanently ceased operations, and have certified that fuel has been permanently removed from the reactor vessel. The NRC issued GL 98-02 to request that PWR licensees evaluate a September 17, 1994, event, which occurred at Wolf Creek, which had the potential to draindown the reactor coolant system (RCS) to the refueling water storage tank and, at the same time, render the emergency core cooling system (ECCS) and residual heat removal (RHR) system inoperable by introducing a steam/water mixture to the suction side of the ECCS and RHR pumps. Addressees of GL 98-02 were requested to provide the following information within 180 days: (1) an assessment of whether the addressee's facility is vulnerable to the September 17, 1994, Wolf Creek event, and (2), if the facility is found to be vulnerable, an assessment of the plant-specific 10 CFR Part 50, Appendix B, quality assurance program attributes which will prevent the subject event. If the addressee's facility was determined to be vulnerable, a response to information item (1) was to be provided pursuant to 10 CFR 50.54(f) and 10 CFR 50.4, and the responses to information items (1) and (2) were to be kept in a licensee's retrievable system for use by the NRC staff on an as-needed basis.

In response to GL 98-02, you provided a letter dated November 22, 1998, for St. Lucie Plant, Units 1 and 2. The submittal indicated that both Units 1 and 2, were vulnerable to the type of incident which occurred at'Wolf Creek and further indicated that the plant evaluation concerning the subject vulnerability (information item (2) of GL 98-02), was being kept in a retrievable licensee system that the NRC can verify on an as-needed or sample basis, in accordance with GL 98-02.

By letter dated December 13, 1999, the Region II NRC staff issued NRC Inspection Report No. 50-335/99-07; 50-389/99-07. The subject inspection report contained details of the NRC staff's on-site verification of activities which you undertook in response to GL 98-02 for

~8j/II; Pig ll'$ ilk~ ll;IllfF' St. Lucie, Units 1 and 2. Specifically, the inspector verified that,S(.,Luciethyg.effectively,~.

t(

% )

T. F. Plunkett implemented administrative controls and operating procedures to preclude an inadvertent drain down event as described in GL 98-02. Operator Training Lesson Plan 0802208, Outage Tasks and Outage Related Events, was revised to include a review of GL 98-02 and the drain down flow paths that had been identified for each unit. Training was provided to the operators using the revised lesson plan to understand the susceptible flow paths, and the administrative and operational controls in place to minimize the potential for human factor contributors to the initiation of a drain down event. The above measures were found by the inspector to be appropriate.

The NRC staff has reviewed your response to GL 98-02 and has concluded that (1) all the information requested by GL 98-02 has been provided, and (2) that your on-site activities adequately addressed the concerns of GL 98-02 for St. Lucie, Units 1 and 2; therefore, we consider GL 98-02 to be closed for St. Lucie, Units 1 and 2.

Sincerely, William C. Gleaves, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389 cc: See next page

t ~

I

Mr. T. F. Plunkett ST. LUCIE PLANT Florida Power and Light Company CC:

Senior Resident Inspector Mr. R. G. West St. Lucie Plant Plant General Manager U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant P.O. Box 6090 6351 South Ocean Drive Jensen Beach, Florida 34957 Jensen Beach, Florida 34957 Joe Myers, Director E. J. Weinkam Division of Emergency Preparedness Licensing Manager Department of Community Affairs St. Lucie Nuclear Plant 2740 Centerview Drive 6351 South Ocean Drive Tallahassee, Florida 32399-2100 Jensen Beach, Florida 34957 M. S. Ross, Attorney Mr. John Gianfrancesco Floiida Power & Light Company Manager, Administrative Support P.O. Box 14000 and Special Projects Juno Beach, FL 33408-0420 P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Douglas Anderson Co'unty Administrator Mr. J. A. Stall St. Lucie County Vice President - Nuclear Engineering 2300 Virginia Avenue Florida Power & Light Company Fort Pierce, Florida 34982 P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. William A. Passetti, Chief Department of Health Mr. J. Kammel Bureau of Radiation Control Radiological Emergency 2020 Capital Circle, SE, Bin ¹C21 Planning Administrator Tallahassee, Florida 32399-1741 Department of Public Safety 6000 SE. Tower Drive Mr. Rajiv S. Kundalkar Stuart, Florida 34997 Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957

t 3~gf-/4~

~~ gza-CL4

~ ~ig 1

T. F. Plunkett March 27, 2000

~Q ~

implemented administrative controls and operating procedures to preclude an inadvertent drain down event as described in GL 98-02. Operator TraIning Lesson Plan 0802208, Outage Tasks and Outage Related Events, was revised to include a review of, GL 98-02 and the drain down flow paths that had been identified for each unit. Training was provided to the operators using the revised lesson plan to understand the susceptible flow paths, and the administrative and operational controls in place to minimize the potential for human factor contributors to the initiation of a drain down event. The above measures were found by the inspector to be appropriate.

The NRC staff has reviewed your response to GL 98-02 and has concluded that (1) all the information requested by GL 98-02 has been provided, and (2) that your on-site activities adequately addressed the concerns of GL 98-02 for St. Lucie, Units 1 and 2; therefore, we consider GL 98-02 to be closed for St. Lucie, Units 1 and 2.

Sincerely,

/Im/

William C. Gleaves, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389 cc: See next page DISTRIBUTION:

CFile.Center

'UBLIC PDII-2 Reading RCorreia BClayton WGleaves JDonohew MRazzaque CLauron J Davis OGC ACRS LWert, Rll DOCUMENT NAME: G:FPDII-2>St. Lucie>LTRGL9802CLOPSL.w d

o:receive:a co .:o .t is', ocument,in icate::.: .:.in::t e: ox OFFICE PDII-2/PM PDII-2/LA PDIV-1 M C SR /SC PDII-2/SC NAME WGleau BClayton JDo hew RC ruso RC DATE Q/4 /00 Ioo 3 I hloo 7 a. Ioo /~i/oo OFFICIAL RECORD COPY

4 r ra J

f 1 1'

V

~/P Distri14.txt Distribution Sheet Priority: Normal From: Stefanie Fountain Action Recipients: Copies:

Intet'naPReeiptenta.

FILE CENTER 01 Paper Copy External Recipients:

NOAC Paper Copy Total Copies:

Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 003688970:1

Subject:

St. LUCIE UNITS 1 AND 2-'EQUEST FOR ADDITIONALINFORMATION REGARDING EX TENSION OF THE ALLOWED OUTAGE TIME FOR THE EMERGENCY DIESEL GENERAT ORS (TAC NOS. MA7205 AND MA7206).

Body:

ADAMS DISTRIBUTION NOTIFICATION.

Electronic Recipients can RIGHT CLICK and OPEN the first Attachment to View the Document in ADAMS.,The Document may also be viewed by searching for Accession Number ML003688970.

DF01 - Direct Flow Distribution: 50 Docket (PDR Avail)

Docket: 05000335 Docket: 05000389 Page 1 l

March 1, 2000 Mr. Thomas F. Plunkett President - Nuclear Division Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

St. LUCIE UNITS 1 AND 2 - REQUEST FOR ADDITIONALINFORMATION REGARDING EXTENSION OF THE ALLOWED OUTAGE TIME FOR THE EMERGENCY DIESEL GENERATORS (TAC NOS. MA7205 AND MA7206)

Dear Mr. Plunkett:

By letter dated November 17, 1999, Florida Power and Light Company (FPL) proposed technical specification (TS) changes for St. Lucie Units 1 and 2. The proposed changes would revise the 72-hour allowed outage time in TS 3.8.1.1, Action b, to 14 days to restore an inoperable emergency diesel generator set to operable status.

The U.S. Nuclear Regulatory Commission staff has reviewed FPL's submittal and has determined that additional information is needed by the staff before it can complete its review.

The enclosed request for additional information (RAI) has been discussed with George Madden of your staff. A target date for your response has been agreed upon to be 60 days from your receipt of this RAI. Should a situation occur that prevents you from meeting the target date, please contact me at (301) 415-1 496.

Sincerely, Kahtan N. Jabbour, Senior Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation l

Docket Nos. 50-335 and 50-389

Enclosure:

Request for Additional Information

'c w/encl: See next page Distribution:

t File Center '~ LBerry PUBLIC OGC PDI I-2 R/F ACRS S Black LWert RCorreia DThatcher BClayton MReinhart KJabbour

  • See previous concurrence DOCUMENT NAME: GAPDII-2>St. LucieIIRAIA7205.wpd INDICATE IN BOX: "C"=COPY W/0 ATTACHMENT/ENCLOSURE, "E"3:COPY W/ATT/ENCL, "N"+NO COPY OFFICE PM:PDII-2 LA:PDII-2 EEIB:SC'PSB:SC'C:PDII-2 NAME KJabbour 8 BCla on DThatcher MReinhart RCorrei DATE 02 / 53/00 02/'23/00 02/ 18 /00 02/18/00 02/ /00 OFFICIAL RECORD COPY

I 5 I

II

t*

lf

+g***y+

r t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 1, 2000 J//'///3'r.

Thomas F. Plunkett President - Nuclear Division Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

St. LUCIE UNITS 1 AND 2 - REQUEST FOR ADDITIONALINFORMATION REGARDING EXTENSION OF THE ALLOWED OUTAGE TIME FOR THE EMERGENCY DIESEL GENERATORS (TAC NOS. MA7205 AND MA7206)

Dear Mr. Plunkett:

By letter dated November 17, 1999, Florida Power and Light Company (FPL) proposed technical specification (TS) changes for St. Lucie Units 1 and 2. The proposed changes would revise the 72-hour allowed outage time in TS 3.8.1.1, Action b, to 14 delays to restore an inoperable emergency diesel generator set to operable status.

The U.S. Nuclear Regulatory Commission staff has reviewed FPL's submittal and has determined that additional information is needed by the staff before it can complete its review.

The enclosed request for additional information (RAI) has been discussed with George Madden of your staff. A target date for your response has been agreed upon to be 60 days from your receipt of this RAI. Should a situation occur that prevents you from meeting the target date, please contact me at (301) 41 5-1 496.

Sincerely,

+~m nJ, 3 Kahtan N. Jabbour, Senior Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389

Enclosure:

Request for Additional Information cc w/encl: See next page

e REQUEST FOR ADDITIONALINFORMATION RELATED TO THE AMENDMENTOF THE TECHNICAL SPECIFICATIONS FOR THE EMERGENCY DIESEL GENERATORS ST.'UCIE UNITS 1 AND 2 FLORIDA POWER AND LIGHT COMPANY DOCKET NOS. 50-335 AND 50-389 The staff is concerned over your use of "trigger values" to ensure that the emergency diesel generator (EDG) reliability for St. Lucie Units 1 and 2 remains greater than or equal to the target reliability chosen for your EDGs to meet station blackout (SBO) rule.

Please justify your amendment request without relying on the "trigger values."

Your staff indicated in a telephone conference on January 19, 2000, that each of the Unit 1 and Unit 2 EDGs is capable of powering its dedicated division of safety loads in addition to the complement of selected Unit 1 or Unit 2 toads necessary to maintain the units in Hot Standby through the duration of the SBO event. Your staff also indicated that procedures are in place to accomplish the above throng) the SBO crosstie. Please clarify this aspect of the design for Unit 2 in your application.. In addition, indicate that the time it takes to establish this connection satisfies the availability requirements of an alternate AC source used for the SBO event.

I Page 8, Table 4 - Explain the relationship among the early containment failure probability (0.01 or 0.1), core damage frequency (CDF), and large early release frequency (LERF) ~

Pages 6, 7 and 8, Tables 1, 2 and 3- In Tables 1 and 2, 1.39E-5/yr was referred to as a conditional CDF based on zero EDG unavailability. The same value was referred to as an average baseline CDF in Table 3. Explain.

5. The staff finds that the loss of grid initiating event frequency does not include plant-centered loss of offsite power (LOOP). Does the FPL's risk evaluation include the risk impact of the proposed change due to this plant-centered LOOP initiating event?

Explain.

Is the crosstie recovery event failure probability (0.1) identical for both units? Explain why the asymmetry in design between the units was not captured.

7. Explain how the. recommended Tier 2 restriction is going to be implemented.
8. Explain EOP-99, Appendix G for manual C auxiliary feedwater pump start, and justify the basic event failure probability used for it in your PRA.

ENCLOSURE

0 l

Mr. T. F. Plunkett ST. LUCIE PLANT Florida Power and Light Company CC:

Senior Resident Inspector Mr. R. G. West St. Lucie Plant Plant General Manager U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant P.O. Box 6090 6351 South Ocean Drive Jensen Beach, Florida 34957 Jensen Beach, Florida 34957 Joe Myers, Director E. J. Weinkam Division of Emergency Preparedness Licensing Manager Department of Community Affairs St. Lucie Nuclear Plant 2740 Centerview Drive 6351 South Ocean Drive Tallahassee, Florida 32399-2100 Jensen Beach, Florida 34957 M. S. Ross, Attorney Mr. John Gianfrancesco Florida Power & Light Company Manager, Administrative Support P.O. Box 14000 and Special Projects Juno Beach, FL 33408-0420 P.O. Box 14000 Beach, FL 33408-0420

'uno Mr. Douglas Anderson County Administrator Mr. J. A. Stall St. Lucie County Vice President - Nuclear Engineering 2300 Virginia Avenue Florida Power 8 Light Company Fort Pierce, Florida 34982 P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. William A. Passetti, Chief Department of Health Mr. J. Kammel Bureau of Radiation Control Radiological Emergency 2020 Capital Circle, SE, Bin ¹C21 Planning Administrator Tallahassee, Florida 32399-1741 Department of Public Safety 6000 SE. Tower Drive Mr. Rajiv S. Kundalkar Stuart, Florida 34997 Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957

Distri86.txt Distribution Sheet Priority: Normal From: Elaine Walker Action Recipients: Copies:

ernal g tp FILE CENTER 01 Not Found External Recipients:

NRC PDR Not Found NOAC Not Found Total Copies:

Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 993250295

Subject:

ST. LUCIE PLANT, UNITS I AND 2 - PAST AND FUTURE COMPLIANCE WITH 10 CFR 50.7 1(e)(4) FOR REVISIONS TO THE UFSAR Body:

PDR ADOCK 05000335 P Docket: 05000335, Notes: N/A Docket: 05000389, Notes: N/A Page 1

0 pe,R RE0y UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 2055~01

+0 ~ 'qO November 10, 1999

~>>*<<+

Mr. T. F. Plunkett President - Nuclear Division Florida Power and Light Company P.O. Box 14000 Juno Beach; Florida 33408-0420

SUBJECT:

ST. LUCIE PLANT, UNITS 1 AND 2 - PAST AND FUTURE COMPLIANCE WITH 10 CFR 50.71(e)(4) FOR REVISIONS TO THE UFSAR t

(TAC NOS. M72478 AND M72479)

Dear Mr. Plunkett:

The purpose of this letter is to clarify any misunderstanding of th'e U.S. Nuclear Regulatory Commission (NRC's) regulations that relate to Title 10 of the Code of Federal Regulafions (10 CFR), Subsection 50.71(e)(4). Subsection 50.71(e)(4) specifies the schedular requirements whereby licensees are to submit revisions to their Final Safety Analysis Reports (FSARs). It requires revisions to be made, "... annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months."

In a 1997 survey of licensees, we found numerous cases of noncompliance with this schedular requirement, in both single- and multi-unit sites. A common example of this noncompliance was a multi-unit site that based their submission schedule for all units on the schedule of one of the units.

We understand that an NRC letter to Commonwealth Edison Company (ComEd), dated June 15, 1993, may have caused some confusion about the proper interpretation of the regulation. The letter endorsed an alternative submission schedule proposed by ComEd.

Neither ComEd's proposed schedule, nor the staff's endorsement, were in compliance with the regulation. Nevertheless, many licensees adopted the staff position expressed in the June 15~ letter and deviated from the schedular requirements of the regulation. In order to correct the error, the staff recently granted exemptions to the ComEd plants. The transmittal letter to the exemption (D. Skay to O. D. Kingsley, dated July 27, 1999), states, "this [Skay]

letter and the enclosed exemptions supersede our letter of June 15, 1993."

We note that you have not requested a schedular exemption to Subsection 50.71(e)(4) for St.

Lucie plant. This indicates that you intend to comply with the literal interpretation of the regulation, regardless of how you have interpreted the regulation in the past. We will exercise enforcement discretion, in accordance with Section VII.B.6 of the NRC Enforcement Policy, for past violation(s) of Subsection 50.71(e)(4). In the future, we will enforce the schedular requirements as prescribed, or as modified by an exemption.

0 I

T.F. Plunkett s We do not require a response to this letter. If you have any questions or comments, please call me at 301-415-1479.

~

Sincerely,

> JA~g William C. Gleaves, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389 cc: See next page

~ 'E

~ '

Mr. T. F. Plunkett ST. LUCIE PLANT

'Florida Power and Light Company

~ M CC:

Senior Resident Inspector Mr. R. G. West St. Lucie Plant Plant General Manager U.S. Nuclear Regulatory Commission St. Lucie Nuclear Plant P.O. Box 6090 6351 South Ocean Drive Jensen Beach, Florida 34957 Jensen Beach, Florida 34957, Joe Myers, Director E. J. Weinkam Division of Emergency Preparedness Licensing Manager Department of Community Affairs St. Lucie Nuclear Plant 2740 Centerview Drive 6351 South Ocean Drive Tallahassee, Florida 32399-2100 Jensen Beach, Florida 34957 M. S. Ross, Attorney Mr. John Gianfrancesco Florida Power & Light Company Manager, Administrative Support P.O. Box 14000 and Special Projects Juno Beach, FL 33408-0420 P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Douglas Anderson County Administrator Mr. Rajiv S. Kuhdalkar St. Lucie County Vice President- Nuclear Engineering 2300 Virginia Avenue Florida Power & Light Company Fort Pierce, Florida 34982 P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. William A. Passetti, Chief Department of Health Mr. J. Kammel Bureau of Radiation Control Radiological Emergency 2020 Capital Circle, SE, Bin ¹C21 Planning Administrator Tallahassee, Florida 32399-1741 Department of Public Safety 6000 SE. Tower Drive J. A. Stall, Site Vice President Stuart, Florida 34997 St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, Florida 34957

~ //

yI b

T.F. Plupkett s

~> a We do not require a response to this letter. If you have any questions or comments, please call me at 301-415-1479.

Sincerely, I

Ot'i.ginal signed bs K. 3abbour for William G. Gleaves, Project Manager, Section 2

,'Project Directorate II Division of L'icensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389 cc: See next page F

DISTRIBUTION'--FIIe.Centei PUBLIC St. Lucie RIF PDII-2ISC (A)

B Clayton WGleaves PTam (e-mail PST))

OGC ACRS LWert, Rll DOCUMENT NAME: G:\PDII-21St. LucieLM72478ufsar.ltr.wpd To receive e co of thts document Indicete In the born C a Co whhout ettechment/enclosure E ~ Co with ettechrnent/enclosure N ~ No co OFFICE PDII-2' P Dll-2ttLA PDII-25SC A PDI NAME DATE WGIeaves 11/t499 r" J /'Cla 11/0/99 ton a~ 11/,0/99 HB r 11M 9 11/ /99 OFFICIAL RECORD COPY

k

't

~ ~

J L

l li i