L-2002-140, Proposed License Amendments Technical Specification Improvements Associated with Handling of Recently Irradiated Fuel Assemblies

Proposed License Amendments Technical Specification Improvements Associated with Handling of Recently Irradiated Fuel Assemblies

ML021980135
Person / Time
Site:	Saint Lucie
Issue date:	07/15/2002
From:	Jernigan D Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2002-140 L-2002-140
Download: ML021980135 (8)

Text

Florida Power & Light Company, 6501 South Ocean Drive, Jensen Beach, FL 34957 FPL L July 15, 2002 L-2002-140 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Technical Specification Improvements Associated with Handling of Recently Irradiated Fuel Assemblies By Letter L-2002-89 and pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requested to amend Facility Operating Licenses DPR-67 and NPF-16 for St. Lucie Units 1 and 2 on May 23, 2002. The proposed amendments revise Unit 1 and Unit 2 Technical Specifications (TS) to incorporate line item improvements associated with the handling of recently irradiated fuel assemblies in accordance with Revision 2 of NUREG-1432, Standard Technical Specifications Combustion Engineering Plants (STS) and a portion of Nuclear Energy Institute (NEI) TS Task Force (TSTF) change traveler TSTF-51, Revision

2. The proposed changes modify Unit 1 and Unit 2 TS Sections 3.9.4 and 3.9.9, Unit 1 TS Section 3.9.12, and Unit 2 TS Section 3.6.6.1.

On June 28, 2002, the NRC Project Manager for St. Lucie requested FPL to supplement the amendment request with respect to the changes requested to Unit 1 and Unit 2 TS 3.9.4, Refueling Operations, Containment Penetrations in the following three areas.

1. Supplement the proposed change to TS 3.9.4 to include a specific regulatory commitment that would be consistent with NUMARC 93-01, Revision 3, Section 11.3.6, Assessment Methods for Shutdown Conditions, subheading 11.3.6.5, Containment- Primary (PWR)ISecondary (BWR). The regulatory commitment is included in Attachment 1 and will be included in the bases for TS 3.9.4.

2. The proposed changes associated with TS 3.9.4 need to be revised to clarify that the new note added to Limiting Condition for Operation (LCO) for TS 3.9.4 applies only to LCO 3.9.4.c. Attachment 2 is a revised description of the changes to TS 3.9.4 and the supporting Safety Analysis.

3. FPL was asked to describe the administrative controls to be put in place during core alterations or movement of irradiated fuel inside containment. The administrative controls are to ensure that when containment penetrations are open they can be an FPL Group company

St. Lucie Unit Nos. 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-140 Page 2 promptly closed and the containment ventilation systems will be able to draw the release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored. The description of the administrative controls is included in Attachment 3.

The St. Lucie Facility Review Group and the Florida Power & Light Company Nuclear Review Board previously reviewed the proposed amendments. The previously submitted Determination of No Significant Hazards and Environmental Considerations bound these minor clarifications to TS 3.9.4 and remain valid.

In accordance with 10 CFR 50.91 (b)(1), a copy of the proposed amendment is being forwarded to the State Designee for the State of Florida.

Please c~nrpct George Madden at 772-467-7155 if there are any questions about this Vice Presid*nt St. Lucie Plant DEJ/GRM Attachments cc: Mr. William A. Passetti, Florida Department of Health

St. Lucie Unit Nos. 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-140 Page 3 STATE OF FLORIDA )

) ss.

COUNTY OF ST. LUCIE )

Donald E. Jernigan being first duly sworn, deposes and says:

That he is Vice President, St. Lucie Plant, for the Nuclear Division of Florida Power & Light Company, the Licensee herein; That he has executed the foregoing document; th th statements made in this document are true and correct to the best of his knowle e, in rmation, and belief, and that he is authorized to execute the document on beh f of s d Licensee.

/ (

-7" DonaIln STATE OF FLORIDA COUNTY OF ST LUCIE Sworn to and subscribed before me this L- __ day of 2002 by Donald E. Jernigan, who i-spersonally known to me.

Name of Notary ic - State of Florida Lesdie 1 Whitwefl MYCOMMISUON# DD020212 E SIRE BONDEDMay THRU 12,FAJN TROY 2005 INSURANC4 INC (Print, type or stamp Commissioned Name of Notary Public)

St. Lucie Unit Nos. 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-140 Attachment 1 Page 1 ATTACHMENT I REGULATORY COMMITMENT FPL will add the following regulatory commitment to the bases for TS 3.9.4, Refueling Operations, Containment Penetrations, which is consistent with NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3, Section 11.3.6, Assessment Methods for Shutdown Conditions, subheading 11.3.6.5, Containment- Primary (PWR)/Secondary (BWR).

The following guidelines are included in the assessment of systems removed from service during movement of irradiated fuel:

"During fuel handling/core alterations, ventilation system and radiation monitor availability(as defined in NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel. Following shutdown, radioactivity in the fuel decays away fairly rapidly. The basis of the Technical Specification operability amendment is the reduction in doses due to such decay. The goal of maintaining ventilation system and radiation monitor availability is to reduce doses even further below that provided by the natural decay and to avoid unmonitored releases.

"Asingle normal or contingency method to promptly close primary or secondary containment penetrations should be developed. Such prompt methods need not completely block the penetration or be capable of resisting pressure. The purpose of the "prompt methods" mentioned above are to enable ventilation systems to draw the release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored.

Availability as defined by NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, December 1991, relies on the definitions of functional, and operable. The NUMARC 91-06 definitions for these three terms follow.

" Available (Availability): The status of a system, structure, or component that is in service or can be placed in service in a functional or operable state by immediate manual or automatic actuation.

" Functional (Functionality): The ability of a system, structure, or component to perform its intended service with considerations that applicable technical specification requirements or licensing/design basis assumptions may not be maintained.

• Operable: The ability of a system to perform its specified function with all applicable TS requirements satisfied.

St. Lucie Unit Nos. 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-140 Attachment 2 Page 1 ATTACHMENT 2 Description of the Proposed Change In response to NRC request of June 28 2002, FPL proposes to revise the changes requested to Limiting Conditions for Operation for Unit 1 and Unit 2 TS 3.9.4. The following clarifications to FPL original submittal are provided in response to the NRC request. Revised text showing the changes when compared to the current TS are in Bold Italics.

1. Unit 1 TS 3/4.9.4, Refueling Operations, Containment Penetrations There are two changes requested for Unit 1 Limiting Condition for Operation (LCO) for TS 3.9.4:

1. For LCO 3.9.4.b, the special conditions for opening both airlock doors are deleted as indicated below:

b. A minimum of one door in each airlock is closed. or-, both dor-S of the containmcnt pcr-Sonnel airlockmay be open if:.

1. at least one personnel airlock door is capable of being

2. the plant is in MODE 6 with at least 23 feet of water above the fuel in thc reactor-corc, and 3.a dcsignated individual is available outsidc thc per-sonnel airlock to clOsc the door.F

2. For LCO 3.9.4.c, the new note added is indented such that it is clear that it applies only LCO 3.9.4.c as indicated below. The original FPL submittal considered the note applicable to all three subparts of LCO 3.9.4.

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. Closed by isolation valve, blind flange, or manual valve except for valves that are open on an intermittent basis under administrative control, or

2. Be capable of being closed by an OPERABLE automatic containment isolation valve, or

3. Be capable of being closed by an OPERABLE containment vacuum relief valve.

Note: Penetration flowpath(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrativecontrols.

St. Lucie Unit Nos. 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-140 Attachment 2 Page 2

2. Unit 2 TS 3/4.9.4, Refueling Operations, Containment Building Penetrations There are three changes requested for Unit 2 LCO for TS 3.9.4:

1. For LCO 3.9.4 a, the special conditions for opening the equipment door are deleted as indicated below:

a. The equipment door is closed and held in place by a minimum of four bolts, or thc e.u ipen door may be open i.f 1.it is caai f bcing coised with four-bolts within 30 2; The plant is in MODE 6 with at least 23 feet of water above the reactor pressure vessel fiange,-and close the doorF.

2. For LCO 3.9.4.b, the special conditions for opening both airlock doors are deleted as indicated below:

b. A minimum of one door in each airlock is closed., or both doors of each containment airlock may be open if:

1. At least one door.of each ai*rokIs capable of being cIosed,

2. The plant is in MODE 6 with at least 23 feet f water-above the reactor-pr-essur-e vessel flange, and

3. A designated individualis available outside each open airlock to close the door.

3. For LCO 3.9.4.c, the new note added is indented such that it is clear that it applies only LCO 3.9.4.c as indicated below. The original FPL submittal considered the note applicable to all three subparts of LCO 3.9.4.

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. Closed by an isolation valve, blind flange, or manual valve, or

2. Be capable of being closed by an OPERABLE automatic containment isolation valve.

Note: Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.

St. Lucie Unit Nos. 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-140 Attachment 3 Page 1 DISCUSSION OF ADMINISTRATIVE CONTROLS The handling and movement of irradiated fuel assemblies requires systems that mitigate the effects of a fuel handling accident (FHA) to be operable. This will assure that the resulting dose to control room operators and the public remain within prescribed limits.

However, the handling of irradiated fuel assemblies that have decayed beyond the time interval assumed in the FHA will result in acceptable doses without the reliance on the operability of the components addressed by the proposed changes. The FHA analyses demonstrate that sufficient decay has occurred such that the primary path for mitigating the dose consequences of the FHA no longer includes the functioning of the active containment systems. Instead water level and decay time are the primary success paths for mitigating the dose consequences of the FHA. The following guidelines are included in the assessment of systems removed from service during core alterations or movement of irradiated fuel in containment:

" During fuel handling/core alterations, containment ventilation system and radiation monitor availability (as defined in NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel. The goal of maintaining ventilation system and radiation monitor availability is to reduce doses even further below that provided by the natural decay and to avoid unmonitored releases.

" A single normal or contingency method to promptly close primary or secondary containment penetrations should be developed. Such prompt methods need not completely block the penetration or be capable of resisting pressure. The purpose of the "prompt methods" mentioned above are to enable ventilation systems to draw the release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored.

Availability as defined by NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, December 1991, relies on the definitions of functional, and operable. The NUMARC 91-06 definitions for these three terms follow.

" Available (Availability): The status of a system, structure, or component that is in service or can be placed in service in a functional or operable state by immediate manual or automatic actuation.

"* Functional (Functionality): The ability of a system, structure, or component to perform its intended service with considerations that applicable Technical

St. Lucie Unit Nos. 1 and 2 Docket Nos. 50-335 and 50-389 L-2002-140 Attachment 3 Page 2 Specification requirements or licensing/design basis assumptions may not be maintained.

Operable: The ability of a system to perform its specified function with all applicable TS requirements satisfied.

These administrative controls will include a preplanned method for the prompt closure of containment penetrations by designated individuals and the return to service of the ventilation and radiation monitoring systems by automatic or manual means. The closure of containment penetrations and the equipment, emergency air lock (EAL) and personnel airlock (PAL) doors include the requirements that the penetrations and doors are capable of being closed and that any cables or hoses across the doors have quick-disconnects to ensure they are capable of being closed in a timely manner. Administrative controls will be in place to assure that personnel are present to close at least one EAL and PAL door after containment evacuation and that the equipment door can be closed with 4 bolts within 30 minutes.