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Proposed TS 4.6.1.1.a.1, Containment Integrity Surveillance Requirements.
	ML17227A753
Person / Time
Site:	Saint Lucie
Issue date:	03/04/1993
From:	; FLORIDA POWER & LIGHT CO.
To:	;
Shared Package
ML17227A752	List: ML17227A751; ML17227A753;
References
	NUDOCS 9303080003
	Download: ML17227A753 (16)
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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment St. Lucie Unit 1 Containment Penetrations Surveillance Re uirement ATTACHMENT 1 ST ~ LUCIE UNIT 1 MARKED-UP TECHNICAL SPECIFICATION PAGE Page 3/4 6-1 Proposed Insert for Page 3/4 6-1 P ',

S303080003 S3030a PDR ADOCK 05000335 PDR

3 4.6 CONTAINMENT SYSTENS 3 4.6.1 AINENT VESSEL CONTAIWKNY VESSEL INTEGRITY LIHITING CONOITION FOR OPERATION 3.6.1.1 CONTAINMENT VESSEL INTEGRITY shall be maintained.

APPLICABILITY: HOOES 1, 2, 3 and 4.

ACTION:

Mithout CONTAINENT VESSEL INTEGRITY, restore CONTAINMENT VESSEL INTEGRITY within one hour or be in at least HOT STANOBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLO SHUTMNN within the following 30 hours.

SURVEILLANCE RE UIRENENTS 4.6.1.1 CONTAINENT VESSEL INTEGRITY shall be demonstrated:

a. At least once per 31 days by verifying that:

1. All contaiasent vessel penetrations" not capable of being closed by OPERABLE contaireent autltic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated autoiatic valves secured in their positions, except as provided in Table 3.6-2 of Specification 3.6.3.1, and All contaireent vessel equipment hatches are closed and sealed.

b;" Q verifying that each containnent vessel air lock is OPERABLE per Specification 3.6.1.3.

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CONTAIlOKNT SYSTEMS CONTA I%%IT LEAKAGE LIHI NG CGND TION FOR OPERATION 3.6.1.2 Contaiwent leakage rates shall be limited to:

a. An overall integrated leakage rate of:

l. < La, 0.50 percent by weight of the containment afr per Z4 hours at Pa, (39.6 ps1g), or

2. < Lt, 0.32 percent by weight of the containment air per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at a reduced prcssure of Pt, (19.8 psfg).

b. A combined leakage rate of << 0.60 La for all penetratfons and valves subject to Type B ar8 C tests as ident1fted in Table 3.6-1 when pressurized to P .

C. A combined leakage rate of << 0.27 La for all penetratfons identified fn Table 3.6-1 as secondary contafreent bypass leakage paths when pressurized to Pa.

APPLICABILITY: HODES 1, 2, 3 and 4.

ACTION:

With either (a) the measured overall integrated containment leakage rate exceeding 0.75 La or 0.75 Lt, as applicable, or {b) with the measured combined leakage rate for all penetratfons and valves subject to Types B and C tests exceedfng 0.60 La, or {c) with the ~fned bypass leakage rate exceeding 0@27 Lay restore the leakage rate(s) to w1thfn the limit{s) prfor to fncreasfng the Reactor Coolant Systew teaperature above 200'F.

SURVEI IRE%llTS 4.6.1.2 eetaf~t leakage rates shall be demonstrated at the followfng test schedule and shall be deterefned fn conforaance with the criteria specfffed fn Appendix J of 10 CFR 50:

a. Three Type A tests (Overall Integrated Contafrsent Lgkage Rate) shall be conducted at 40, + 10 month intervals during shutdown at: e'ither Pa~(39:6, psfg) or. at<Pt (l9~8 psfg). dur'fng each 10-year ST. LUCIE - UNIT 1 3/4 6-2 Aaendwent No. gg, 99 DEC Ia 8N

CONTAItNBIT SYSTEMS ItNNT LEAKAGE 'ONTA LIMITING CONDITION FOR OPERAT.3N 3.6.1.2 Contafrment leakage rates shall be lfmfted to;

a. An overall integrated leakage rate of:

1. < La, 0.50 percent by weight of the contafnment afr per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at Pa, (39.6 psig), or

2. < Lt, 0.32 percent by wefght of the contafneent afr pet 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at a r educed. pressure of Pt, (19.8 psfg).

b. A combined leakage rate of < 0.60 La for all penetratfons and valves subject to Type B ar8 C tests as fdentfffed fn Table 3.6-1 when pressurized to Pa.

c. combined leakage rate of ~ 0.27 La for all penetratfons fdentfffed fn Table 3.6-1 as secondary contafneent bypass leakage paths when pressurized to Pa.

APPLICABILITY: NODES 1, 2, 3 and 4.

ACTION:

fifth'either (a) the measured overall fntegrated contafneent leakage rate exceeding 0.75 La or 0.75 Lt, as applfcable, or (b) with the measured combfned leakage rate for all penetratfons and valves subject to Types 8 and C tests exceedfng 0.60 La, or (c) wfth the ~fned bypass leakage rate exceedfng 0.27 La> restore the leakage rate(s) to rfthfn the .

lfmft(s) prfor to fncreesfng the Reactor Coolant Systaa teeyorature above 200'F.

SURVEI IRK%NTS 4.6.1.2 aetaf (mant leakage rates shall be demonstrated at the followfny Ctst schedule and shall be deterNned fn conformance.rfth the crfterta specfffed fn Appendfx 0 of 10 CFR 50:

a. Three Type A tests (Overall Integrated Contafraant Wkage Rate) shall be conducted at 40 + 10 month intervals durfng shutdown at efther Pa '(39;6 psfg) or- at Pt, (19.$ psfg) durfng each 10-year ST. LUCIE - UNIT 1 3/4 6-2 Aaendatnt No. I, 99 DEC la ill

St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment St. Lucie Unit 1 Containment Penetrations Surveillance Re uirement PROPOSED INSERT FOR TS Pa e 3 4 6-1 Except valves, blind flanges, and deactivated automatic valves which are located inside the containment and are locked, sealed or otherwise secured in the closed position. These penetrations shall be verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days.

St. Lucie Unit 1 Docket, No. 50-335 Proposed License Amendment St. Lucie Unit 1 Containment Penetrations Surveillance Re uirement ATTACHMENT 2 SAFETY ANALYSIS

St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment St. Lucie Unit 1 Containment Penetrations Surveillance Re uirement SAFETY ANALYSIS Introduction Florida Power and Light Company (FPL) proposes to modify St. Lucie Unit 1 Technical Specification (TS) 4.6.1.1.a.l, Containment Integrity Surveillance Requirements, by excluding penetrations inside containment from the integrity verification that is required at least once per 31 days. The provision to exclude verification of penetrations inside containment. is necessary because some components are inaccessible during reactor operation or are located in areas of high radiation fields.

The proposed change to TS 4.6.1.1.a.1 reads like the corresponding TS approved for St. Lucie Unit 2.

Discussion In Modes 1,', 3, and 4, TS 4.6.1.1.a requires, in part, that Containment Vessel Integrity'hall be demonstrated at least once per 31 days by verifying that: " 1. All containment vessel penetrations not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Table 3.6-2 of Specification 3.6.3.1."

Some of these components inside containment are inaccessible or are in areas of high radiation fields. A TS change is necessary to avoid radiation dose to those employees who would be required to check these components inside containment. Accordingly, the proposed amendment will exclude valves, blind flanges, and deactivated automatic valves which are located inside containment and are locked, sealed or otherwise secured in their closed positions from the 31 day surveillance of containment penetrations.

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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment St. Lucie Unit 1 Containment.

Penetrations Surveillance Re uirement Safet Assessment Corrective actions for Unit 1 delineated in FPL's revised response (FPL letter L-93-046) to a Notice of Violation (Inspection Report 92-21) will be completed by the end of the 1993 Spring Refueling Outage. These actions include installation of locking devices and other measures, as appropriate, on penetration components inside containment to satisfy the condition of being secured in their proper positions.

During plant startup from cold shutdown, all containment vessel penetrations not capable of being closed by operable containment automatic isolation valves and required to be closed during accident conditions will be verified closed by valves, blind flanges, or deactivated automatic valves which are locked, sealed or otherwise secured in their proper positions prior to entry into Mode 4 where containment integrity is required. These conditions will be verified using approved system valve lineup procedures, local leak rate post. test valve lineups, and containment integrity surveillance valve lineups.

Containment access during reactor operation is restricted physically by locked hatches which are annunciated in the control room when any containment hatch is opened. Administrative controls restrict entries into Unit 1 containment to anomaly inspections, typically 2 per month, that inspect the accessible areas of containment for any unusual conditions. Work that may require containment access during unplanned, short notice outages is normally limited in scope. Since configuration control on all plant systems is achieved through approved plant procedures, the equipment clearance order procedure, and/or the locked valve deviation log, the anomaly inspections or the outage activities will not reduce the effectiveness of containment integrity.

Surveillance Requirement (SR) 4.6.1.1.a.l involves only verification, through a system walkdown, that applicable components are secured in their correct positions. Since access to the containment is typically restricted during modes 1, 2, 3, and 4 for ALARA reasons, FPL considers that the probability of misalignment of these components, once they have been verified to be in the proper position, is small.

For valves and blind flanges inside containment, the proposed verification frequency of "during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days" is considered appropriate since these valves and flanges are operated under administrative controls and the probability of their misalignment is low.

St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment St. Lucie Unit 1 Containment Penetrations Surveillance Re uirement The proposed amendment is identical to the provision that excludes verification of penetrations inside containment from the corresponding 31 day SR in the approved TS for St. Lucie Unit 2. This provision was found acceptable for Unit 2 as part of the licensing basis for that plant. The administrative controls and other factors contributing to the acceptability of the exclusion provision for Unit 2 are equally applicable to St. Lucie Unit l.

Based on the above discussions, FPL considers that the probability of misalignment of penetration components located inside containment, once they have been verified to be properly aligned, is small. Moreover, the proposed amendment and associated bases are consistent, with NUREG-1432, Rev. 0 (09/28/92), "Standard Technical Specifications for Combustion Engineering Plants". Therefore, FPL concludes that operation of St.

Lucie Unit 1 in accordance with the proposed amendment is acceptable.

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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment St. Lucie Unit 1 Containment Penetrations Surveillance Re uirement ATTACHMENT 3 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Pursuant to 10CFR50.92, a determination may be made that a proposed license amendment involves no significant hazards consideration operation of the facility in accordance with the proposed amendment if would not: (1) 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:

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

Strict control of containment entries, measures being taken to ensure that penetration components are locked, sealed or otherwise secured in their closed positions, and the administrative controls that assure a low probability of valve misalignments described in the supporting safety analysis for the proposed amendment provide assurance that containment integrity is preserved without performing the 31 day verification surveillance inside containment. Therefore, operation of the facility in accordance with the proposed amendment will not. involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

This amendment does not result in any change to the physical plant or in the mode of operation of the plant. Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment St. Lucie Unit 1 Containment Penetrations Surveillance Re uirement (3) Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

Penetration components inside containment are operated under administrative control and entries into containment. are restricted.

Certain penetration components, as appropriate, are locked, sealed or otherwise secured in their proper positions to assure containment integrity during Operating Modes 1, 2, 3, and 4. Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

Based on the discussion presented above and on the supporting safety analysis, FPL has concluded that this proposed license amendment involves no significant hazards consideration.

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ML17227A753

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