ML17222A316

Forwards Denial of Amend to License NPF-16 & Opportunity for Hearing Re 871222 Application to Change Tech Specs on Restoration of Inoperable Open Main Feedwater Isolation Valve.Disagreement Explained

ML17222A316
Person / Time
Site:	Saint Lucie
Issue date:	06/22/1988
From:	Berkow H Office of Nuclear Reactor Regulation
To:	Conway W FLORIDA POWER & LIGHT CO.
Shared Package
ML17222A317	List: ML17222A316 ML17222A318
References
TAC-66853, NUDOCS 8807050117
Download: ML17222A316 (3)

Text

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UNITED STATES 1

NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 June 22, 1988 Docket No.:

50-389 Mr.

W. F.

Conway Vice President-Nuclear Florida Power and Light Company Post Office Box 14000 Juno Beach, Florida 33408

SUBJECT:

PROPOSED AMENDMENT FOR CHANGING THE ACTION STATEHENT OF TECHNICAL SPECIFICATION SECTION 3.7. 1.6 FROM 4 TO 72 HOURS TO RESTORE INOPERABLE MFIV TO OPERABLE - ST.

LUCIE PLANT, UNIT 2 (TAC NO. 66853)

By letter dated December 22, 1987, the Florida Power and Light Company (FPL) proposed a change to the Technical Specifications (TS) for the St. Lucie Plant, Unit 2.

The proposed amendment would change the action statement of Limiting Condition for Operation (LCO) 3.7. 1.6 and Bases 3/4.7. 1.6 to allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore an inoperable open main feedwater isolation valve (MFIV) to operable.

The current requirement for return to operability is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

We have reviewed your request and supporting information contained in the attachments.

We do not agree with your assessment.

Due to removal of the main feedwater check valve from the plant design and its replacement with a second main feedwater isolation valve, the LCO for main feedwater line isolation

valves, LCO 3.7. 1.6, was incorporated in the TS to protect against the failure of one MFIV to close with the other MFIV in that line being inoperable (i.e.,

stuck open).

To preclude operation for extended periods with an MFIV known to be stuck in 'the open position, a 4-hour action time was incorporated in the LCO.

The staff does not expect this action time to represent a reasonable time to repair an inoperable HFIV, but rather to represent the importance the staff places on this HFIV function.

According to your accompanying Safety Evaluation, justification for the proposed change is based on (1) your estimate that in the event of a Design Basis Event (DBE) during either 4 or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation with an inoperable, open HFIV, the likelihood of occurrence of the sequence of events required to result in a failure to terminate feed flow is very low, and (2) your argument that an extension of the MFIV action time to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provides the same time to repair an inoperable MFIV as is allowed to repair other safeguards

systems, such as an inoperable Emergency Core Cooling System, Containment Core Spray System, Fan Coolers, Intake Cooling System, or Component Cooling Water System.

The staff does not accept either argument as justification for the proposed change.

88070501 1T 880622 PDR ADOCK 05000389 PDR~

Mr. H. F.

Conway June 22, 1988 pi Your estimate of the low likelihood of occurrence is based on generic estimates "o

,the MFIV fail open frequency and the main steam line break (MSLB) frequency.

Due to the uncertainties incorporated in the estimate and its questionable applicability to St. Lucie Plant, Unit 2, the staff does not accept it as a

basis for changing the LCO 3.7.1.6 action statement.

Furthermore, the staff considers comparison of the MFIV action statement with those of the above-mentioned safeguards systems inappropriate.

Since it is the staff's view that,'rom a functional point of view, the MFIV action statement should be compared with those of the main steam isolation valves.(MSIVs) and containment isolation valves, for which the action time is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the staff does not accept your comparison, although for containment isolation both MFIVs are not needed because this is a GDC-57 penetration.

It is the staff's view, however, that both valves are essentia'1 to assure mitigation of the consequences of a main feedwater line break (MFLB) or MSLB, especially to limit feedwater addition to a faulted steam generator in the event of an MSLB.

This issue was discussed with FPL during three telephone conferences in February and March 1988.

During those conferences the staff explained why the proposed amendment was unacceptable and pointed out that the staff would only consider plant-specific justifications for changing the action statement.

The staff suggested that FPL needed to identify unique MFIV design or configuration features and demonstrate that they justify the proposed change.

FPL has not provided a satisfactory justification.

For the reasons stated

above, the proposed changes to TS Section 3.7.1.6 and Bases 3/4.7.1.6 are denied.

The Commission has filed the enclosed Notice of Denial of Application for Amendment to Facility Operating License with the Office of the Federal Register for publication.

Sincerely,

/S/

Herbert N. Berkow, Director Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation

Enclosure:

Federal Register Notice cc w/enclosure:

See next page DISTRIBUTION 1

NRC-Loca-1 PDRs PD22 Rdg S. Varga,14/E/4 G. Lainas,14/H/3 H. Berkow J. Schiffgens E. Tourigny B. Grimes, 9/A/2 ACRS (10)

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Mr.

W. F, Conway Florida Power

& Light Company St. Lucie Plant CC Mr. Vack Shreve Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida 32304 Resident Inspector c/o U.S.

NRC 7585 S.

Hwy AIA Jensen Beach, Florida 34957 State Planning 5 Development Clearinghouse Office of Planning 5 Budget Executive Office of the Governor The Capitol Building Tallahassee, Florida 32301 Harold F. Reis, Esq.

Newman 8 Holtzinger 1615 L Street, N.W.

Washington, DC 20036 I,"ohn T. Butler, Esq.

Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Ta 1 lahassee, Florida 32301 Mr. Weldon B. Lewis, County Administrator St. Lucie County 2300 Virginia Avenue, Room 104 Fort Pierce, Florida 33450 Mr. Char les B. Brinkman, Manager Washington - Nuclear Operations Combustion Engineering, Inc.

7910 Woodmont Avenue

Bethesda, Maryland 20814 Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood B'Ivd.

Tallahassee, Florida 32399-0700 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323