ML17221A571

Forwards NSHC & Administrative Corrections to Tech Specs Re Pump & Valve Testing Program to Support 871116 Application to Amend Licenses DPR-67 & NPF-16

ML17221A571
Person / Time
Site:	Saint Lucie
Issue date:	12/30/1987
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-87-541, NUDOCS 8801070344
Download: ML17221A571 (19)

Text

AC CELZRA7ED IHSFRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRXBUTION SYSTEM (RIDS)

ACCESSION NBR: 8801070344 DOC. DATE: 87/12/30 NOTARIZED: NO DOCKET g FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION WOODY,C.O. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document, Control Branch (Document Control Desk)

SUBJECT:

Forwards NSHC & revised Tech Specs re pump & valve testing program,per 871116 request.

DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR t ENCL t SIZE:

TITLE: OR Submittal: Inservice Inspection/Testing NOTES:

RECIPIENT COPXES RECIPIENT COPIES S ID CODE/NAME LTTR ENCL XD CODE/NAME LTTR ENCL PD2-2 LA 1 0 PD2-2 PD 5 5 1' TOURXGNY,E 1 1 INTERNAL: AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 ARM/DAF/LFMB 1 0 NRR/DEST/MEB 1 1 NRR/DEST/MTB 1 1 N S ILRB 1 1 D OGC/HDS2 1 0 EG F 01 1 1 RES/DE/EXB 1 1 EXTERNAL: LPDR 1 1 NRC PDR NSIC 1 1 A

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 16

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1. ~ P. O. BO 00, JUNO BEACH, FL 33408-0420 OEGEMBER 3 0 1987 L-87-541 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: St. Lucie Unit 1 Docket Nos. 50-335 and 50-389 Proposed License Amendment Pum and Valve Testin Pro ram Technical S ecifications By letter L-87-469, dated November 16, 1987, Florida Power &

Light Company (FPL) proposed to revise various Technical Specifications with respect to the St. Lucie 1 Pump and Valve Program.

The proposed amendment was discussed with the NRC Staff in a conference call on December 22, 1987. During the conference call, it was requested that FPL amplify the no significant hazards consideration submitted in FPL's November 16, 1987 letter. Also, various administrative corrections were discussed with respect to the same letter. The attached no significant hazards consideration and the administrative correction replace Attachments 2 and 3 of FPL letter L-87-469 dated November 16, 1987.

If additional please contact us.

information is required about this submittal, Very truly yours,

~un C. 0. Woo Executiv ice President COW/EJW/gp Attachments cc: Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Mr. Lyle Jerrett, Florida Department of Health and Rehabilitative Services Senior Resident Inspector, USNRC, St. Lucie Plant EJW/021.PLA

.'8801070344 871230 05000335 PDR P,...,..., ..

ADOCK

.... 989-PbR.

an FPL Group company

ATTACHMENT2 EVALUATION As required by IO CFR 50.55a(g), FPL updated the Inservice Inspection (ISI) and lnservice Testing (IST) programs, together with proposed Technical Specification amendments for St. Lucie Unit I, to the requirements of the l974 Edition through Summer l975 Addenda of the ASME Boiler and Pressure Vessel Code. The ISI and IST programs were submitted to the NRC in July and September of l977. On December 20, I 977, the NRC granted relief, on an interim basis, pending completion of a detailed review of the programs. On April 2, l985, the NRC issued a safety evaluation on the St. Lucie Unit I IST Program, and, in particular, the requests for relief from regulatory requirements applicable to the program.

The proposed amendments which were submitted in l 977, removed reference to a specific Edition and Addenda of Section XI of the ASME Boiler and Pressure Vessel Code for inservice testing and, instead, proposed a new Specification 4.0.5 addressing Surveillance Requirements for inservice inspection and testing.

The subject revised amendment maintains a similar format as was originally submitted. Differences which exist between the original l 977 submittals and the revised submittals are a result of using a more recent revision of the Combustion Engineering - Standard Technical Specifications (CE-STS).

The following Specifications are either added, revised, or deleted with respect to the St. Lucie Unit I Pump and Valve Testing Program:

S ecification Revison 4.0.5 New Specification 4.0.5 is added to specify the pump and valve test requirements. This addition reflects wording in the CE-STS.

4.I.2.l.a.l Boration Systems - Shutdown Flow Paths: The surveillance activity for testing each power operated or automatic valve in the flow path required for boron injection has been removed from the technical specifications. This activity is included in the St. Lucie Unit I Pump and Valve Program.

4.I.2.2.a.l Boration Systems - Operation Flow Paths: The surveillance activity for testing each power operated or automatic valve in the flow path required for boron injection has been removed from the technical specifications. This activity is included in the St.Lucie Unit I Pump and Valve Program.

4.I.2.2.c.l Boration Systems - Operating Flow Paths: The I 8 month surveillance activity for cycling each power operated valve in the flow path that is not testable during plant operation has been removed from the technical specifications. This activity is included in St. Lucie Unit I Pump and Valve Program.

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S ecification Revison (con't) 4.1.2.3 Boration Systems - Charging Pumps (shutdown): The surveillance activities of starting the pump and verifying pump operation for at least 15 minutes have been removed from the technical specifications. This activity is included in St. Lucie Unit I Pump and Valve Program. Also, the surveillance activity of verifying electrical power form an OPERABLE emergency bus has been removed. The operability requirement in Modes 5 and 6 for electrical power sources are m'aintained as required in the Electrical Power System portion of the St. Lucie Unit I Technical Specifications. The new Surveillance Requirements refer to testing pursuant to Specification 4.0.5 (ASME Pump and Valve test requirements).

4.1.2.4 Boration Systems - Charging 'umps (operating): The surveillance activities of starting the pump and verifying pump operation for at least 15 minutes have been removed from the technical specifications. These activities are included in the St.

Lucie Unit I Pump and Valve Program. The new Surveillance Requirements refer to testing pursuant to Specification 4.0.5 (ASME Pump and Valve test requirements).

4.1.2.5 Bo ration Systems - Boric Acid Pumps (shutdown): The surveillance activities of starting the pump and verifying pump operation for at least 15 minutes have been removed from the Technical Specifications. These activities are included in the St. Lucie Unit I Pump and Valve Program. The new Surveil lance Requirement refers to testing pursuant to Specification 4.0.5 (ASME Pump and Valve test requirements).

4.1.2.6 Boration Systems - Boric Acid Pumps (operating): The surveillance activities of starting the pump and verifying pump operation for at least 15 minutes have been removed from the Technical Specifications. These activities are included in the St. Lucie Unit I Pump and Valve Program. The new Surveillance Requirement refers to testing pursuant to Specification 4.0.5 (ASME Pump and Valve test requirements).

4.4.2 Reactor Coolant System - Safety Valves (shutdown): The reference to Surveillance Requirement 4.4.3 (Surveillance Requirement for Safety Valves-Operating) has been removed.

The safety valves will be demonstrated OPERABLE in accordance with Section XI of the ASME Boiler and Pressure Vessel Code as referenced in new Specification 4.0.5. This activity is included in the St. Lucie Unit I Pump and Valve Program.

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S ecification Revison (con't) 4.4.3 Reactor Coolant System - Safety Valves (operating): Reference to a specific Edition and Addenda of the ASME Code has been removed. The safety valves will be demonstrated OPERABLE in accordance with Section XI of the ASME Boiler and Pressure Vessel Code as referenced in new Specification 4.0.5. This activity is included in the St. Lucie Unit I Pump and Valve Program.

4.5.2 Emergency Core Cooling Systems - ECCS Subsystems Tavg + 325 F: The surveillance activities of starting both the HPSI and LPSI pumps and verifying pump operation for at least l5 minutes have been removed. These activities are included in the St. Lucie Unit I Pump and Valve Program.

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The surveillance activities of cycling each testable, power operated valve in the flow path and cycling each valve in the flow path that is not testable during plant operation have been removed. These activities are included in the St. Lucie Unit I Pump and Valve Program.

The surveillance activity of verifying electrical power*from an OPERABLE emergency bus has been removed. The operability requirements for electrical power sources are maintained as required in the Electrical Power System portion of the St. Lucie Unit I Technical Specifications.

The surveillance activity of verifying that the containment sump isolation valves open upon a recirculation actuation signal has been changed from a 3 I day surveillance (4.5.2.b.3) to a new I 8 month surveillance (4.5.2.e.3). The containment sump isolation valves are tested in accordance with the St. Lucie Unit I Valve Program and will continue to be tested on a frequency consistent with the approved Edition and Addenda of the ASME Code. The basis for verifying these valves open on a recirculation isolation signal every 3 I days has not been determined. Therefore, it is proposed to perform this surveillance activity on an l8-month interval, consistent with the CE-STS, St. Lucie Unit 2 Technical Specifications and the periodic integrated test of the Engineered Safety Features.

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ATTACHMENT3 NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the Commission's regulations, 10 CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (I) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated or (3) involve a significant reduction in a margin of safety. Each standard is discussed as follows:

(I) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The addition to Technical Specification Section 4.0, Surveillance Requirements, is a change to achieve consistency between the St. Lucie Unit I Technical Specifications and the St. Lucie Unit 2 Technical Specifications. The intent of the Specifications has not been changed.

The change incorporates the format/wording of the Combustion Engineering - Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications which have been previously approved by the staf f.

Reference to Surveillance Requirements of a specific Edition and Addenda of Section XI of the ASME Boiler and Pressure Vessel Code have been removed. A new Specification 4.0.5 has been added to provide Surveillance Requirements for Inservice Testing (IST) of ASME Code Class I, 2 and 3 Components in accordance with Section XI of the Code and applicable addenda as required by IO CFR 50.55a(g). The addition of a new Specification 4.0.5 will establish the relationship between the Technical Specification and the Code of Federal Regulations that deal with IST and the ASME Code. The pump and valve surveillance activities which have been removed from the Technical Specifications are contained in Section XI of the ASME Code and, therefore, are included in the St.

Lucie Unit I Pump and Valve Program. The IST program will remain in effect as a licensee-controlled document referenced in the Technical Specifications instead of the program itself being a Technical Specif ication.

Requirements of the ASME Section XI Inservice Testing Program and, therefore, the St. Lucie Unit I Inservice Testing Program, provide for measurement and evaluation of pump mechanical characteristics as well as additional measurement and evaluation of pump hydraulic characteristics. These activities are performed to determine pump operational readiness. Also, requirements of the ASME Section XI Testing Program provide for additional measurement and evaluation for determining valve operational readiness. The St. Lucie Unit I lnservice Testing Program provides a level of quality in testing of pumps and valves consistent with recent versions of the ASME Section XI Code and, MSDI/036/IO

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therefore, the removal of certain pump and valve surveillance activities from the -Technical Specifications does not involve a reduction in the level of quality in testing of pumps and valves at St. Lucie Unit I.

The surveillance activity of verifying electrical power from an operable bus has been removed from individual specifications in that the 'mergency operability requirements for electrical power sources are maintained as required for the Electrical Power System portion of the St. Lucie Unit I Technical Specifications.

The surveillance activity of verifying that the containment sump isolation valves open upon a Recirculation Actuation Signal has been changed from a 3l-day surveillance activity to an IS-month surveillance activity. This change is being made to achieve consistency with the Combustion Engineering-Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications. As required by the St. Lucie Unit I Technical Specifications, the manual recirculation actuation signal feature is tested on an l8 month frequency as are the other manual engineered safety features. Also, as required by the ASME Valve Program the containment sump isolation valves are tested on a quarterly basis. A review of the surveillance activity sheets for verifying that the containment sump isolation valves open upon a recirculation actuation signal has been completed for an IS month period from May l986 to October, l987 and no failures were observed. The containment sump isolations valves on St. Lucie Unit areI similar to the valves on St. Lucie Unit 2 in that they are 24 inch valves manufactured by Henry Pratt.

An addition to the Turbine Cycle-Safety Valves action statement has been made to show that the provisions of Specification 3.0.4 are not applicable for'entry, into an OPERATIONAL MODE.,This change is being made to achieve consistency with the Combustion Engineering-Standard Technical Specifications. This is consistent with the Technical Specifications, in that Startup and/or Power Operation is allowable with safety valves inoperable within the limitations of the ACTION requirements.

Therefore, based on the above, the changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Use of the modified specification would not create the possibility of a new or different kind of accident from any accident previously evaluated.

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The change incorporates the format/wording of the Combustion Engineering - Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications which have been previously approved by the staf f.

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-Reference to Surveillance Requirements of a specific Edition and Addenda of Section XI of the ASME Boiler and Pressure Vessel Code have been removed. A new Specification 4.0.5 has been added to provide Surveillance Requirements for lnservice Testing of ASME Code Class I, 2 and 3 Components in accordance with Section XI of the Code and applicable addenda as required by IO CFR 50.55a(g). The pump and valve surveillance activities which have been removed from the Technical Specifications are contained in Section XI of the ASME Code and, therefore, are included in the St. Lucie Unit I Pump and Valve Program.

The IST program will still be governed by the Commission's rules and regulations.

Requirements of the ASME Section XI lnservice Testing Program and, therefore, the St. Lucie Unit I Inservice Testing Program, provide for measurement and evaluation of pump mechanical characteristics as'ell as additional measurement and evaluation of pump hydraulic characteristics. These activities are performed to determine pump operational readiness. Also, requirements of the ASME Section XI Testing Program provide for additional measurement and evaluation for determining valve operational readiness. The St. Lucie Unit I lnservice Testing Program provides a level of quality in testing of pumps and valves consistent with recent versions of the ASME Section XI Code and, therefore, the removal of certain pump and valve surveillance activities from the Technical Specifications does not involve a reduction in the level of quality in testing of pumps and valves at St. Lucie Unit I.

The surveillance activity of verifying electrical power from an operable emergency bus has been removed from individual specifications in that the operability requirements for electrical power sources are maintained as required for the Electrical Power System portion of the St. Lucie Unit I Technical Specifications.

The surveillance activity of verifying that the containment sump isolation valves open upon a Recirculation Actuation Signal has been changed from a 3l-day surveillance activity to an IS-month surveillance activity. This change is being made to achieve consistency with the Combustion Engineering-Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications. As required by the St. Lucie Unit I Technical Specifications, the manual recirculation actuation signal feature is tested on an IS month frequency as are the other manual engineered safety features. Also, as required by the ASME Valve Program the containment sump isolation valves are tested on a quarterly basis. A review of the surveillance activity sheets for verifying that the containment sump isolation valves open upon a recirculation actuation signal has been completed for an 18 month period from May 1986 to October, l987 and no failures were observed. The containment sump isolations valves on St. Lucie Unit I are similar to the valves on St. Lucie Unit 2 in that they are 24 inch valves manufactured by Henry Pratt.

An addition to the Turbine Cycle-Safety Valves action statement has been made to show that the provisions of Specification 3.0.4 are not applicable for entry into an OPERATIONAL MODE. This change is being made to achieve consistency with the Combustion Engineering-Standard Technical Specifications. This is consistent with the Technical Specifications, in MSDI/036/l2

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Therefore, based on the above, the changes would not create the possibility of a new or different kind of accident from any accident previously evaluated.

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The addition to Technical Specification Section 4.0, Surveillance Requirements, is a change to achieve consistency between the St. Lucie Unit I Technical Specifications and the St. Lucie Unit 2 Technical Specifications. The intent of the Specifications has not been changed.

The change incorporates the format/wording of the Combustion Engineering - Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications which have previously been approved by the staf f.

Reference to Surveillance Requirements of a specific Edition and Addenda of Section XI of the ASME Boiler and Pressure Vessel Code have been removed. A new Specification 4.0.5 has been added to provide Surveillance Requirements for lnservice Testing of ASME Code Class I, 2 and 3 Components in accordance with Section XI of the Code and applicable addenda as required by IO CFR 50.55a(g). The pump and valve surveillance activities which have been removed from the Technical Specifications are contained in Section XI of the ASME Code and, therefore, are included in the St. Lucie Unit I Pump and Valve Program.

Requirements of the ASME Section XI lnservice Testing Program and, therefore, the St. Lucie Unit I Inservice Testing Program, provide for measurement and evaluation of pump mechanical characteristics as well as additional measurement and evaluation of pump hydraulic characteristics. These activities are performed to determine pump operational readiness. Also, requirements of the ASME Section XI Testing Program provide for additional measurement and evaluation for determining valve operational readiness. The St. Lucie Unit I lnservice Testing Program provides a level of quality in testing of pumps and valves consistent with recent versions of the ASME Section XI Code and, therefore, the removal of certain pump and valve surveillance activities from the Technical Specifications does not involve a reduction in the level of quality in testing of pumps and valves at St. Lucie Unit I. The IST program wi I I remain in ef feet as a licensee-cont rol led document referenced in the Technical Specifications instead of the program itself being a Technical Specification.

The surveillance activity of verifying electrical power from an operable emergency bus has been removed from individual specifications in that the operability requirements for electrical power sources are maintained as required for the Electrical Power System portion of the St. Lucie Unit I Technical Specif ications.

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The surveillance activity of verifying that the containment sump isolation valves open upon a Recirculation Actuation Signal has been changed from a 31-day surveillance activity to an 18-month surveillance activity. This change is being made to achieve consistency with the Combustion Engineering-Standard Technical Specifications and the St. Lucie Unit 2 Technical Specifications. As required by the St. Lucie Unit Technical 1

Specifications, the manual recirculation actuation signal feature is tested on an 18 month frequency as are the other manual engineered safety features. Also, as required by the ASME Valve Program the containment sump isolation valves are tested on a quarterly basis. A review of the surveillance activity sheets for verifying that the containment sump isolation valves open upon a recirculation actuation signal has been completed for an 18 month period from May 1986 to October, 1987 and no failures were observed. The containment sump isolations valves on St. Lucie Unit are similar to the valves on St. Lucie Unit 2 in that they 1

are 24 inch valves manufactured by Henry Pratt.

An addition to the Turbine Cycle-Safety Valves action statement has been made to show that the provisions of Specification 3.0.4 are not applicable for entry into an OPERATlONAL MODE. This change is being made to achieve consistency with the Combustion Engineering-Standard Technical Specifications. This is consistent with the Technical Specifications, in that Startup and/or Power Operation is allowable with safety valves inoperable within the limitations of the ACTlON requirements.

Therefore, based on the above, the changes do not involve a significant reduction in a margin of safety.

ln conclusion, we have determined that the amendment request does not (I) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore does not involve a significant hazards consideration.

MSD1/036/14

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