L-77-174, 06/09/1977 Letter Request to Amend Appendix a of Facility Operating Licenses. Revised 05/03/1976 Proposal on Subject of Air Filtration Systems

06/09/1977 Letter Request to Amend Appendix a of Facility Operating Licenses. Revised 05/03/1976 Proposal on Subject of Air Filtration Systems

ML18227D838
Person / Time
Site:	Turkey Point
Issue date:	06/09/1977
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-77-174
Download: ML18227D838 (17)

Text

NRC FoRM 195 '~ U.S. NUCLEAR REGULATORY COM. ATION DOCKET NUMBF. R (2-76 I 5e- @54. S r'ILE NUMBER NRC DISTRIBUTION FoR PART 5Q DOCKET MATERIAL

,TO: F ROVi'. DATE OF DOCUMENT Florida Power & Light Company 6/9/77 Mri Victor Stello Miami, Flai DATE RECEIVED Robert ED Uhri 6/15/77

~ETTER ClNOTORI2ED INPUT FORM NUMBER OF COPIES RECEIVED

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PROP QORIGINAI N C LASS I F I E 0

~Or Y DESCRIPTION ENCLOSURE Amdti to OL/change to Appendix A tech specs. ~ . no tor is ed 6/1Q/77 ~ ~ o concer ns the ACKNOWLEDGED air filtration systemsi ~ ~ ~

DONOT REMOVE (2-P) (1Q-P)

PMNT NAME: Turkey Point Units 3 & 4 R JL 6/17/77 FOR ACTION/INFORMATION ENVIRNBIENTAL Do ASSIGNED AD. Vo MOORE LTR

< C BRANCH CHIEF:

ECT MANAGER: ~.X/Cr- PRO JECT ? SNAGER:

ICEN ING ASSXSTANT: LXCENSING ASSXSTANT:

Ba HARLESS INTERNAL D IST Rl BUTION SY'SFMSS SAFETY PLANT SYSTEMS SXTE SAPETY &

HEINEMAN TEDESCO ENVIRON ANALYSIS EDER BENAROYA DENTON & MULLER ENGINEERING IPPOLITO ENVIRO TECH ERNST OPERATING REACTORS BALLARD 0 NGBLOOD BAER VAK GRILL 2 0 ZTACZY GRIMES CHECK SITE ANALYSIS VOLLMER AT&I BUNCH SALTFiiIIiN Jo COLLINS UTBERG KREGER EXTERNAL DISTRIBUTION CONTROL NUMBER TIC NSIC

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P RFG IV J HAViCHETT 16 CYS ACRS SEiNT CAT GO Y NRC F ORM 196 I2 7B)

FLORIDA POWER & LIGHT COMPANY June 9, 1977 L-77-174 g,(;ye<>>"

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Directox of Nuclear Reactor Regulation Attention: Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Nashington, D. C. 20555

Dear Mr. Stello:

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Point Units and 4 1I %a +~4>~

Re: Tu key 3 '1$ yl ~

Docket Nos. 50-250 and 50-251 Proposed Amendment to Facility Oaeratin Licenses DPR-31 and DPR-41 In accoxdance with 10 CFR 50.30, Florida Power 6 Light Company submits herewith three (3) signed originals and forty (40) copies of a request to amend Appendix A of Facility Operating Licenses DPR-31 and DPR-41.

In response to telephone requests from members of your staff, we have revised our proposal of May 3, 1976 on the subject of air filtration systems. The present proposal conforms as near as possible to the Standard Technical Specifications without our having to make hardware modifications. The pxoposed changes are described below and shown on the accompanying Technical Specification pages bearing the date of this letter in the lower right hand corner.

Pa. es ii and iii Revised Table of Contents.

-4 Specificat'ion 3.4.3.b is revised. This specification concerns" the'imiting conditions for operation applicable to the Emergency Containment Filtering Sy tern" during power operation.

Pa e 3.13-1 New specification 3.13 is added. This specif"cation concerns the limiting conditions for operation applicable to the Control Room Ventilation System and the': Post Accident Containmen" Vent System.

P II'171.00)&

PEOPLE... SERVING PEOPLE

Director of Nuclear Reactor Regulation Page Two Pa es 4.7-1 through 4.7-3 The surveillance requirements of specifications 4.7.1 (Emergency Containment Filtering System) and 4.7.2 (Post Accident Containment Vent System) are revised. A new specification 4.7.3 (Control Room Ventilation System) is added.

Pa e B3.13-1 A new section B3.13-1 -is added to provide bases for new specification 3.13.

Pa e B4.7-1 The bases for specification 4.7 are revised to include the Control Room Ventilation System.

The proposed amendment has- been reviewed by the Turkey Point Plant Nuclear Safety Committee and the Florida Power & Light Company Nuclear Review Board and the conclusion reached that involve an unreviewed safety question.

it does not Very truly yours,

+SS.<

Robert E. Uhrig Vice President REU/MAS/cpc Attachment cc: Mr. Norman C. Moseley, Region II Robert Lowenstein, Esquire

TE OF CONTENTS (eontlnued) ~

Section Title ~Pa pe 3.7 Electrical Systems 3. 7-1 3.8 Steam and Power Co..version Systems 3. 8-1 3.g Radioactive Materials Release 3. 9-1 Liquid Wastes 3. 9-1 Gaseous Wastes 3e9-2 Containerized Wastes 3.9-3

3. 10 Refueling 3elo-1 3.11 Miscellaneous Radioactive Materials Sources 3.11-1 3e12. Cask Handling 3.12-1 3.13 Air Treatment Sysyems 3.13-1 4 SURVEILLANCE REQUIREMENTS 1-1 4el Operational Safety Review 4.1-1 4.2 Reactor Coolant System In Service Inspection 4. 2-1 4.3 Reactor Coolant System Integrity 4 3-1 4.4 Conta' ent Tests 4.4-1 Integrated Leakage Rate Test Post Operational 4.4-1 Lo al 'Penetration Tests 4.4-1 Report of Test Results a.4-2 Isolation Valves 4.4-3

=

Residual Heat Removal System 4.4-3 Tendon Surveillance 4.4-4 End Anchorage Concrete Surveillance 4.4-6 Liner Surveillance 4.4-7 4e5 Safety Injection 4.5-1 4.6 Emergency Containment Cooling Systems 4. 6-1 4.7 Emergency Containment Filtering, Post Accident Containment Vent, and Control Room Ventilation Systems 4.7-1 4.8 Emergency Power System Periodic Tests 4.8-1 4.9 k<ain Steam Isolation Valves 4.9-1

4. 10 Auxiliary Feedwater System 4.10-1 4.11 Reactivity Anomalies 4.11-1 4.12 Environmental Radiation Survey 4.12-1, 4.13 Radioactive ~w~ terials Sources Surveillance 4.13-1 5 DESIGN FEATURES 5.1-1 5.1 Site 5.1-1

,5 2 Reactor 5. 2-3.

5.3 Containment 5.3-1 5.4 Fuel Storage 5.4-1 6 PZiENISTRATIVE CONTROLS 6.1-1 6.1 Responsioility. 6-1 6.2 0 ganizztion 6-1 6.3  :-a=il-'ty Staff Qualifications 6-5 6.4 6-5 6.5 and Audit 6-5 6.6 ~-"."rtable Occurrence Action 6-14 6.7 Sa==t~ Limit Violation 6-14 6.8 -.o=edures 6-14 6.9 Pa"orting Requirements 6-16 6/10/77

~~i a vl vvnlLhN'l5 (continuect)

Section Title ~Pa e 6-10 Record Retention 6- 97 6-11 'Radiation Protection Program 6-29 11 Respiratori Protection Program 6-29

'-13 High Radiatio" Area 6-33.

B2;1 Bases for Safety. Limit', Reactor Core 32-1-1 32.2 Bases for Saf e ty Limit, Reactor Coolant Sys B2 2-3.

tem'ressure 32.3 Bases for Limiting Safety System Settings, Protective Instrumentation 32:3-1 B3.1 Bases for Limiting Conditions for Operation, Reactor Coolant System B3.1-1, 33.2 Bases for Limiting Conditions for Operation, Con-Rod and .Power Distribution Limits 'rol B3. 2-1 B3.3 Bases fo" Limiting Conditions for Operation, Cont? ie erat B3.3-'1 B3.4 Bases for Limiting Conditions for Operation, Eng-neered Safety Features 33.4-1 B3.5 Base- for Limiting Conditions for Operation Instr~ .."ation 33 5-1 B3.6 Bases for LiMting Conditions for Operation

. Cne-ical ard Volume Control System 33.6-1 33.7 Bases .or Limiting Condition for Operation, E'ectrical Systems B3. 7-1 B3e8 Bases for Limiting Conditions for Operation, Steam and Power Conversion Systems

• B3.8-1 33.9 Bases for Limiting Conditions for Operation, Radioactive Materials Release , B3.9-1 33.10 Bases for Limiting Conditions for Operation, Refueling 33.10-1 B3. 11 Bas s for Limiting Conditions for Operation, B3. 11-1 Niscell.aneous Radioactive Haterials Sources B3.12 Bases for Limiting Conditions for Operation, 33. 12-'3.

Cask Handling B3.13 Bases for Limiting Conditions for Operation, Air Treatment Sys tems 33e13-3.

34el Bases for OperzLional Safety Review B4.1-1 B4.2 for Reactor Coolant System ln Service

'ases Inspection 34.2-1 34e3 Bases for Reactor Coolant System Integtity" 34.3-1 34.4 Bases for Containment Tests B4 ~ 4-1 B4.5 Bases for Safety Injection Tests B4.5-1 34.6 "ases for Emergency Containment Cooling System Tests B4.6-1 B4.7 Bases for Emergency Containment Filtering, Post Accident Containme'nt Vent, and Control Room Vent ila tion Sys tems Tes t s 34.7-1 34.8 "or Emergency Power System Periodic Tests B4.8-Z.

9 Hain Steam Isolation Valve Tests B4.9-1 34elo -.or Auxiliary Feedwater System Tests '34.10-J.

34e11 "-=-=. s =or Reactivity Anomalies B4.11-1

34. 12 ==-'='s =or Environmental Radiation Survey B4.12-1

l. ONE emergency containment cooling unit may be out of service for a period of 24 hours. Prior to initiating maintenance, the other TWO units shall be tested to demonstrate operability.

2. ONE containment spray pump may be out of service provided it is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The remaining containment spray pump shall be tested to demonstrate operability before initiating maintenance on.

the inoperable pump.

3. Any valve in the system may be inoperable provided repairs are completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Prior to initiating repairs, all valves that provide the duplicate function shall be tested to demonstrate operability.

3. EMERGENCY CONTAINiiNT FILTERING SYSTEM During times when containment integrity is required:

a. The three Emergency Containment Filtering Units shall be operable at all times or the reactor shall be placed in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-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 />, with the following exception:

1) If one of the three emergency containment filtering trains is made or found to be inoperable for any reason, reactor operation is permissable only during the succeeding seven (7) days provided that all active components of the other two trains shall be demonstrated to be operable within two hours and daily thereafter.

b. Any valve in the system may be inoperable provided repairs are completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> except as stated in 3.a.l above. Prior to initiating maintenance, all valves that provide the duplicate function shall be tested to demonstrate operability.

4. COMPONENT COOLING SYSTEM

a. The reactor shall not be made critical, except for low power physics tests, unless the following conditions are met.

3.4-4 6/10/77

3.13 AIR TREATMENT SYSTEMS Ventilation System and the Post Accident Containment Vent System.

To define those limiting conditions for operation that are necessary:

1. To remove airborne activity from the control room if detected.

2. To reduce containment hydrogen concentration and to reduce containment pressure during post-accident conditions.

a. The Control Room Ventilation (Emergency Internal Cleanup) System may be inoperable for a period of up to seven days. If the system cannot be made operable within seven days, both reactors. shall be shut down.

2. POST ACCIDENT CONTAINMENT VENT SYSTEM

a. The Post Accident Containment Vent System may be inoperable for a period up to thirty days. If the system cannot be made operable within 30 days, both reactors shall be shutdown.

3 ~ 13 1 6/1,0/77

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PILTiR. SYSTBt,

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POST ACCIDEL'iT COtsTAI?ML'iT VEhZ SYSTEM 1;.7 WERC NCY CONTADMEHT AND CONTROL ROO~ii VEiiTILATIOHSYSTEM.

Post Accident Containment Vent System, the Control Poom

'I Ventilation System.

To verify that these 'systems and their components Mill be able to'erform, their design. functions.

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'u the event that painting, fire', or chemical release occurs

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such that the filters are exposed to the effluents of these /

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,( will.be..tested to verify, its

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.events,. the.~stem performance of design features~

4.7. 1 ~C:NCY CONTAIEPfc,hT FILTERING SYSTEM

'. 0"ezatinz Tests Syste~ tests shall be performed once per operating cycle or once per 18 months, whichever comes first.

The tests shall consist: of pressure drop and flow ueasureme ts across all filters in the plenum. T.ess

'than 6" of water 'pressure drop at design flow (+3.0%)

across the combined HEPA filters and charcoal adsorbers shall constitute acceptable performance.

Once per operating cycle, the Emergency Containment rilterin "System shall be tested to demonstrate automatic initiation upon receipt of a safety injection signaI.

Tne -erg ncy Containment 7ilterin~ System shall be cpera ed monthly for at least 15 minutes to demonstrate c" erability.

4. 7-1 6/10/77

a. At least once per 18 months or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, in-place DOP and halogenated hydrocarbon tests on each Emergency Containment Filter plenum sha11 be performed.

In addition, in-place DOP and halogenated hydrocarbon tests shall be performed after (1) any structural maintenance on system housings, (2) after any testing which might have affected filter bank efficiency, (3) after complete or partial replacement of a filter bank, or (4) after exposure of the filters to effluents from painting, fire, or chemical release. Removal of >99% DOP and >99% halogenated hydro-carbon shall constitute acceptable performance. Once per operating cycle, a charcoal surveillance specimen from one of the emergency containment filters shall be analyzed for elemental iodine removal capability. The -results of the laboratory carbon sample analysis shal1 show >99.9% removal efficiency. 'Failing this, the charcoa1 sha11 be replaced with charcoal which meets or exceeds origina1 specifications.

b. An air distribution test shall be performed at least once, and thereafter only if there is indication that the air distribution has changed.

4.7.2 POST ACCIDENTS CONTAINMENT VENT SYSTEM

l. 0 eratin Tests Operating tests shall be performed annually. The tests shall consist of visual inspection of the, system, operation of all valves, and pressure drop and air flow measurements.. Visual inspection shall include search for any foreign materials and gasket deterioration in the HEPA filters and charcoal adsorbers.

Less than 6" of water pressure drop at 55 cfm flow shall con-stitute acceptable performance.

P

2. Performance. Tests At least once per 18 months or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, in-place DOP and halogenated hydrocarbon tests on the Post Accident Containment Vent filters shall be performed. In addition, in-place DOP and halogenated hydrocarbon tests shall be performed after (1) any struct'ural.maintenance on system housings, (2) after any testing which might have affected filter bank efficiency, (3) after complete or partial replacement of a filter bank, or (4) after exposure of the filters to effluents from painting, fire or chemical release. Removal of >99%: BOP and >99% halogenated hydrocarbon shall constitute acceptable performance.

The hydrogen concentration measurement instrument shall be calibrated with proper consideration for humidity.

4.7-2

CONTROL ROOM VENTILATION (EMERGENCY INTERNAL CLEARNUP) SYSTEM

l. 0 eratin Tests The Control Room Ventilation System shall be operated monthly for at least 15 minutes to demonstrate operability. Auto initiation of the systems operations shall be checked annually.

Pressure drop measurements across the filter bank shall be made annually. Less than 6" of water pressure drop at'esigned flow

(+10/) across the combined HEPA filter and charcoal adsorbers shall constitute acceptable performance.

2. Performance Tests At least once per 18 months or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, in-place DOP and halogenated hydrocarbon tests on the filters shall be performed. In addition, in-place DOP and halogenated hydrocarbon tests shall be performed after (1) any structural maintenance on system housings, (2) after any testing which might have affected filter bank efficiency, (3) after complete or partial replacement of a filter bank, or (4) after exposure of the filters to effluents from painting, fire, or chemical release Removal of >99/ DOP and >99/ halogenated hydrocarbon shall con-stitute acceptable performance.

A charcoal surveillance specimen from one of the charcoal adsorbers shall be removed and analyzed annually for methyl iodide removal capability. The results of the laboratory carbon sample analysis shall show >85%%u removal efficiency with >95/

relative humidity and >130'C. Failing this, the charcoal shall be replaced with charcoal which meets or exceeds original speci-fications.

4.7-3 6/10/77

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B3.13 BASES FOR LIMITING CONDITIONS FOR OPERATION, AIR TREATMENT SYSTEMS The Control Room Ventilation (Emergency Internal Cleanup) System is designed to partially filter the Control Room atmosphere for recirculation during Control Room isolation conditions. If the system is inoperable, there is no immediate threat to the Control Room and reactor operation may continue for a limited time while repairs are being made. If the system cannot be repaired within seven days, both reactors are shutdown in accordance with 10 CFR 50.,36(c).

The Post Accident Containment Vent System is designed to facilitate .

controlled venting of either containment through HEPA and charcoal filters to reduce combustible gas concentration- following a loss of coolant accident. If the system is inoperable, there is no significant threat caused by continued reactor operation because the system would only be used seven to ten days after an accident.

Reactor operation may, therefore, continue for up to thirty days while repairs are being made. If the system cannot be repaired in that time, both reactors are shutdown in accordance with 10 CFR 50.36(c).

B3.13-1 '6/10/77

8 4.7 . BASES FOR EMERGEN~ONTAINlKNT FILTERING SYSTEM, VENT- SYSTEM, CONTRMROOM VENTILATION SYSTEM.

~T ACCIDENT CONTADPiiEVZ System components are not subject to rapid deterioration, hav ng lifetimes of many years,. even under continuous flow conditions. Visual inspection and operating tests provide assurance of system reliability and will insure early detection of conditions which could cause the system to fail or operate improperly. The performance tests prove conclusively that filters have been properly installed, that no deterioration or damage has occurred, and that all components and subsystems operate properly.

The tests are performed in accordance with the methodology and intent of ANSI 410, 1975, and provide assurance that filter performance has not deteriorated below original specification values due to aging, contamina-tion, or other effects.

B4.7-1 6/10/77

0 STATE OF FLORIDA )

)

COUNTY OP DADE )

Robert E. Uhrig, being first duly sworn, deposes and says:

That he is a Vice President of Florida Power 6 Light Company, the Licensee herein; That. he has executed the foregoing document; .that the state-ments made in this said document are true and correct, to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

Robert E. Uhrig Subscribed and sworn to before me this Qt day of g uw~ 19 F7 NOTARY PUBLIC, in and for the County of Dade, State of Florida

<OTAAY PUOLLC SeAT- QF FLOR)QA o~ LAO@

Ny commission expires-