ML17228A466

Proposed Tech Specs,Reflecting Relocation of Tables of Instrument Response Time Limits,Per GL 93-08

ML17228A466
Person / Time
Site:	Saint Lucie
Issue date:	02/22/1994
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17228A465	List: ML17228A464 ML17228A466
References
GL-93-08, GL-93-8, NUDOCS 9403080323
Download: ML17228A466 (22)

Text

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Relocation of Tables of Instrument Res onse Time Limits GL 93-08 ATTACHMENT 1 ST. LUCIE UNIT 1 MARKED-UP TECHNICAL SPECIFICATION PAGES Page 3/4 3-1 Page 3/4 3-6 Page 3/4 3-9 Page 3/4 3-16 Page 3/4 3-17 9403080323 940222 PDR ADOCK 05000335 P. PDR

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3 4.3 INSTRUMENTATION 3/4.3.1 REACTOR PROTECTIVE INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.1.1 As a minimum, the reactor protective instrumentation channels and bypasses of Table 3.3-1 shall be OPERABLE, APPLICABILITY: As shown in Table 3.3-1.

ACTION:

As shown in Table 3.3-1.

SURVEILLANCE RE UIREMENTS 4.3.1.1.1 Each reactor protective instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CAI IBRATION and CHANNEL FUNCTIONAL TEST operations during the modes and at the frequencies shown in Table 4.3-1.

4.3.1.1.2 The logic for the bypasses shall be demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL TEST of channels affected by bypass operation, The total bypass function shall be demonstrated OPERABLE at least once per 18 months during CHANNEL CALIBRATION testing of each channel affected by bypass operation.

4.3.1.1.3 The REACTOR TRIP SYSTEM RESPONSE TIME of each reactor trip function 'shall be demonstrated to be within its limit at least onc'e per 18 months. Each test shall include at least one channel per function suc that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function as shown in the "Total No. of Channels" column of Table 3.3-1:

Neutron deteators are exempt from response time testing.

ST. LUG I E - UNIT 1 3/4 3-1

REACTOR PROTECTIVE INSTRUHENTATION RESPONSE T'IHES I

( FUNCTIONAL NIT RESPONSE TIHE (0

tl I

1. Hanual Reac r Trip Not Applicable

2. Power el - H> < 0.40 secon s*8"and < 8.0 seconds88

3. Reactor Cool an Flqw Low < 0.65 conds

4. Pressurizer Pressure - Hig .90 seconds 5.

6.

Containment Pressure Steam Generator Pressure High

- Low

< 1.40

.r seconds 0.90 seconds

7. Steam Generator Water Level - Low < 0.90 seconds

8. Local Power Density - High < 0.40 seconds*8 and < 8.0 seconds08 I

Hargin/Low Pressure

9. Thermal Turbine 0.90 seconds*g and < 8.0 seqondsIIII 9a. Steam Generator Pressure Differ ce -'High . < 0 seconds

'f

10. Loss of Hydraul Fluid Pressure - Low Not App cable

& ll. Wide Range Logari hmic Neutron Flux Honitor. Not Applicab C4 3

ID gg detector out Ct or -nput d f g tt t tg. t g of first electronic component in channe'l.

tt tttt 0 IIIRespons time es not include contribution of RTDs.

88RT respon time:only. 'This value is equivalent to the time interval required for the RTDs tput achieve 63.2X of its total change when sub)ected to a step change in RTO temperature.

INSTRUMENTATION 3/4.3. 2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.2.1 The Engineered Safety Feature Actuation System (ESFAS) instru-mentation channels and bypasses shown in Table 3.3-3 shall be OP'ERABLE with their trip setpoints set consistent i h v u s shown in the Trip Setpoint column of Table 3.3-4. 'E& NSC h own~lan vie~

APPLICABILITY: As shown in Table 3.3-3.

ACTION:

a. With an ESFAS instrumentation channel trip setpoint less conservative than the value shown in the Allowable Values column of Table 3.3-4, declare the channel inoperable and apply the applicable ACTION requirement of Table 3.3-3 until the charm'el is restored to OPERABLE status with the trip setpoint adjusted consistent with the Trip Setpoint value.

b. With an ESFAS instrumentation channel inoperable, take the ACTION shown in Table 3.3-3.

SURVEILLANCE REOUIREMENTS 4.3.2.1.1 Each ESFAS instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION" CHANNEL FUNCTIONAL TEST operations during the modes and at the

'nd frequencies shown in Table 4.3-2.

4.3.2.1.2 The logic for the bypasses shall be demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL'EST of channels affected by bypass operation. The total bypass function shall be demonstrated OPERABLE at least once per 18 months during CHANNEL CALIBRATION .testing of each channel affected by bypass operation; 4.3.2.1.3 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function shall be demonstrated to be within the limit at least once per 18 months. Each test shall include at least one channel per function such that all channels are tested at, least once every N times 18 months where N is the total number of redundant channels in a specific ESF function as shown in the "Total No. of Channels" Column of Table 313 3.

ST. LUCIE - UNIT 1 3/4 3-9

TABLE 3.3-5 ENGINEERED SAFETY FEATURES RESPONSE TIMES I TIATING SIGNAL AND FUNCTION RESPONSE TIME IN S ONDS

l. ual

a. IAS Sa ty Injection (ECCS) Not Ap icable Contai gent Fan Coolers Not Applicable Feedwater solation ot Applicable Containment olation Not Applicable

b. CSAS Containment Spray Not Applicable

c. CIS Containment Isolation. Not Applicable Shield Building Ventilation stem Not Applicable

d. RAS Containment Sump Reci culation Not Applicable

e. MSIS Main Steam Isol tion Not Applicable Feedwater Is lation Not Applicable AFAS Auxil ry Feedwater Actuation Not pl icabl e

2. Pressu zer Pressure-Low

a. afety Injection (ECCS) < 30.0"/19. **

Containment Isolation *** < 30.5*/20.5"

c. Containment Fan Coolers < 30.%/17.0**

d. Feedwater Isolation < 60.0 ST. LUCIE - UNIT 1 3/4 3-16 Amendment No. J7,87,M.

m tace, wi4 QELeQEO

TABLE 3.3-5 Continued ENGINEERED SAFETY FEATURES RESPONSE TIMES INIYtIATING SIGNAL.AND FUNCTION RESPONSE TIMES IN ECOND

3. Con ainment Pressure-Hi h

a. S~a ety Injection (ECCS) 3Q Q*/ 5**

b. Conta 'nment Isolation*** < 30. /20.5**

c. Shield B ilding Ventilation System Q Q*/1 4 Q**

d. Containment an Cool ers 3Q 0*/1 7 0**

e. Feedwater Isol tion < 60.0

4. Containment Pressure ~- Hi h-Hi h

a. Containment Spray 3Q Q*/1 8 5**

5. Containment Radiation-Hi h

a. Containment Isolation*** < 3G'.5*/20.5**

b. Shield Building Ventilatiop S tern 3Q Q*/14 Q**

6. Steam Generator Pressure-Low/

a. Hain Steam Isolation 6.9

b. Feedwater Isolation < 60.0

7. Refuelin Mater Stora e Tank-Low

a. Containment Sump Recirculation < 91.5

8. Steam Generat r Level-Low

a. Auxil ry Feedwater > 205 *, < 305

• TABLE NOTATION

• O'esel generator starting and sequence loading delays included.

• iesel generator starting and sequence loading delays not included.

Offsite power available.

• • "Not applicable to containment isolat'ion valve I-MV-18-1.

ST. LUCIE - UNIT 1 3/4 3-17 Amendment No. 17,37,89,ll'5s 1 5, r scc~A DeLeTED

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Relocation of Tables of Instrument Res onse Time Limits GL 93-08 ATTACHMENT 2 ST. LUCIE UNIT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES Page 3/4 3-1 Page 3/4 3-6 Page 3/4 3-7 Page 3/4 3-11 Page 3/4 3-19 Page 3/4 3-20 Page 3/4 3-21

3/4. 3 INSTRUMENTATION 3/4. 3. 1 REACTOR PROTECTIVE INSTRUMENTATION LIMITING CONDITION FOR OPERATION the reactor protective instrumentation channels and 3.3.

b T~

1 asses As a minimum, of Table 3.3-1 shall be OPERABLE, .~ ~ ow~

APPLICABILITY: As shown in Table 3.3-1.

ACTION:

'As shown in Table 3.3-1.

SURVEILLANCE RE UIREMENTS 4.'3. l. 1 Each reactor protective instrumentation channel shal.l be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3"l.

4.3. 1.2 The logic for the bypasses shall be demonstrated OPERABLE prior to each reactor startup unless performed during the preceding 92 days. The total bypass function shall be demonstrated OPERABLE at least once per 18 months during CHANNEL CALIBRATION testing of each channel affected by bypass operation.

4.3. 1.3 The REACTOR TRIP SYSTEM RESPONSE TIME of each reactor trip function shall be demonstrated to be within its limit at least once per 18 months.

Each test shall include at least one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific reactor 'tr ip function as shown in the "Total No. of Channels" column of Table 3.3-1.

Meutron detectors are exempt from response time testing.

ST. LUCIE " UNIT 2 3/4 3-~

P TABLE 3. 3-2 REACTOR PROTECTIVE INSTRUMENTATION RESPONSE 3 ES FONCTIONAL UNIT f SPONSE TIME

1. Manual Reactor Trip Hot Applicable

2. Variable Power Level - Nigh < 0.40 second"'""

3. Pressurizer Pressure - Iligh < 1.15 seconds

4. Thermal Margin/Low Pressure < 0.90 second""

5. Contaipment Pressure - Ill h < l,l5 seconds

6. Steam Generator Pr ure - Low < 1.15 seconds

7. Steam Genera r Pressure Oifference - Nigh 5 seconds Steam enerator Level - Low < 1.15 se ds ocal Power Oensity - Nigh < 0.40 second"'"

I O

Ai

3.3-2 (Continued)

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C UNIT'ABLE REACTOR PROTECTIVE INSTRUMENTATION RESPONSE TIMES m FUNCTIONAL RESPONSE TIME C: 10. Loss of Component Cool,ing ter to Reactor Coolant Pumps Not Appl le ll. Reactor Protection System Logic Not Applicable

12. Reactor Trip Breakers Not Applicable

13. Wide Range Logarithmic Neutron Flux Monitor Not Applicable

14. Reactor Coolant Flow - Low 0.65 second I

15. Loss of Load (Turbine Hydraulic F uid Pressure - Low) Not Applicable Neutron detectors are empt from response time testing. Response time of the n +on flux signal portion of the channel shal be measured from detector output or input of first electronic c~ onent in channel.

Based on where

~ esistance

.he RTD

.temperature detector response time is equivalent to the (RTO) response time of less than or equal to 14.0 time interval required for the RTD output to ac conds ve 63 of its total change when subjected to a step change in RTO temperature.

INSTRUMENTATION 3/4.3.2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.2 The Engineered Safety Features Actuation System (ESFAS) instrumentation channels and bypasses shown in Table 3.3-3 shall be OPERABLE with their trip shtpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-4.

APPLICABILITY: As shown in Table 3.3-3.

ACTION:

With an ESFAS instrumentation channel trip setpoint less conservative than the value shown in the Allowable Values column of Table 3.3-4, declare the channel inoperable and apply the applicable ACTION requirement of Table 3.3-3 until the channel is restored to OPERABLE status with the trip setpoint adjusted consistent with the Trip Setpoint value.

b. With an ESFAS instrumentation channel inoperable, iake the ACTION shown in Table 3.'3-3.

SURVEILLANCE RE UIREMENTS

4. 3.2. 1 Each ESFAS instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-2.

4.3;2.2 The logic for the bypasses shall be demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL TEST of channels affected by bypass operation.

The total bypass function shall be demonstrated OPERABLE at least once per 18 months during CHANNEL CALIBRATION testing of each channel affected by bypass operation.

4.3.2.3 The ENGINEERED SAFETY FEATURES RESPONSE TIME of each ESFAS function shall be. demonstrated to be within the limit at least once per -18 test shall include at least one channel per function such that all channels months'ach are tested at least once every N times 18 months where N is the total number of redundant channels in a specific ESFAS function as shown in the "Total No.

of Channels" Column of Table 3.3-3.

ST. LUCIE - UNIT 2 3/4 3-11

TABLE 3.3"5 ENGINEERED SAFETY FEATURES RESPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN CONDS

1. Manua

a. SIA+

Safety EInjection (ECCS) N Applicable containmsast Isolation ot Applicable Shield Buil ng Ventilation System Not Applicable Containment Purge Valve Isolation Not Applicable Containment Fan Coolers Not Applicable

b. CSAS Containment Spray Not Applicable Iodine Removal Not Applicable C. CIAS Containment Isolati+o Not Applicable Shield Building Vgftilation System Not Applicable Containment Pu ge Valve Isolation Not Applicable

d. MSIS Main Ste m Isolation Not Applicable Feedw er Isolation N App1 i cabl e e.

Containment Sump Recirculation Not App cable AFAS Auxiliary Feedwater Actuation Not Applicable Feedwater Isolation Not Applicable ST. LUCIE " UNIT 2 3/4 3-19

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TABLE 3. 3-5 Continued ENGINEERED SAFETY FEATURES RESPONSE TIMES INITIA. NG SIGNAL ANO FUNCTION RESPONSE TIME IN SECO OS

10. Steam enerator Level-Low

a. Aux'liary Feedwater < 305"/<30

• TABLE NOTATION Oiesel gene ator starting and sequence loading delays include Response time limiJ~includes movement of valves and attainment of pump o blower dischar C pressure.

Oiesej generator starting and sequence loadingDELETEDdelays not included. Offsite pow 8 available. Response time limit includes movement of valves an at ainment of pump or blower discharge pressure.

(1) ontainment Isolation response time is applicable to the valves specific in Specification 3.6.3.

Jg/et~ ~~ ~

ST. LUCIE - UNIT 2 3/4 3"21 Amendment No.

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Relocation of Tables of Instrument Res onse Time Limits QL 93-08 ATTACHMENT 3 EVALUATION OF PROPOSED TS CHANGES

St. Lucie Unit 1 and Unit 2 L-94-031 Docket Nos. 50-335 and 50-389 Attachment 3 Proposed License Amendments Page 1 of 3 Relocation of Tables of Instrument Res onse Time Limits GL 93-08 EVALUATION OF PROPOSED TS CHANGES Introduction Florida Power and Light Company (FPL) proposes to change the St.

Lucie Unit 1 and Unit 2 Technical Specifications (TS) by deleting the tables of response time limits for instrumentation of the Reactor Protective System (RPS) and the Engineered Safety Features Actuation System (ESFAS). The tables will be relocated to the Unit 1 and Unit 2 Updated Final Safety Analysis Report (UFSAR) in accordance with the guidance provided in USNRC Generic Letter 93-08 (GL 93-08). Neither the requirements to perform response time testing nor the specified limits are changed by this proposal.

Following approval of the changes, the RPS and ESFAS response time limits will be included in the next update of the UFSAR for each unit pursuant to 10 CFR 50.71(e).

Description of TS Changes for St. Lucie Units 1 and 2 TS 3.3.1.1 Unit 1 and 3.3.1 Unit 2  : Delete the words, "with RESPONSE TIMES as shown in Table 3.3-2."

TS 4.3.1.1.3 Unit 1 and 4.3.1.3 Unit 2 : Insert the words "Neutron detectors are exempt from response time testing" as shown in Attachments 1 and 2 of this submittal.

Table 3.3-2: This table is deleted in its entirety.

TS 3.3.2.1 Unit 1 and 3.3.2 Unit 2 : Delete the words, "with RESPONSE TIMES as shown in Table 3.3-5."

Table 3.3-5: This table is deleted in its entirety.

Bases for the Proposed Changes Limiting Conditions for Operation (LCOs) for RPS and ESFAS instrumentation presently require these systems to be operable with response times as specified in the applicable TS tables.

St. Lucie Unit 1 and Unit 2 L-94-031 Docket Nos. 50-335 and 50-389 Attachment 3 Proposed License Amendments Page 2 of 3 Relocation of Tables of Instrument Res onse Time Limits GL 93-08 Surveillances must be performed prior to entering an operational mode for which the associated LCO is applicable. The existing RPS and ESFAS Surveillance Requirements (SR) specify that the response time of each function shall be demonstrated to be within its limit at least once per 18 months. Relocating Tables 3.3-2 and 3.3-5 from the TS to the UFSAR will not alter these SR. Therefore, deleting the LCO references to response times and the corresponding TS tables will not change the functional capability or performance levels of the RPS or ESFAS systems. The proposed changes to TS 3.3.1.1 (Unit 1) and 3.3.1 (Unit 2) are compatible with relocating the referenced tables and are consistent with the guidance provided in GL 93-08.

A footnote (*) in the table of response time limits for the RPS (Table 3.3-2) states that, "Neutron detectors are exempt from response time testing." To retain this exemption, the proposed amendments incorporate the footnote into the text of SR 4.3.1.1.3 (Unit 1) and 4.3.1.3 (Unit 2) as shown in Attachments 1 and 2, respectively, to this submittal. This revision is consistent with the guidance provided by Enclosures 1 and 2 of GL 93-08.

Tables 3.3-2 and 3.3-5 will be incorporated into the UFSARs for St.

Lucie Units 1 and 2. This includes the footnotes which provide clarification of response time limits in the tables to describe how those limits are applied. The proposed changes are simply revisions involving relocation and do not alter any of the specified limits, including those channels for which the time response limit is stated as "Not Applicable." Each UFSAR will thereby address the RPS and ESFAS instrumentation time response and changes to these limits will be controlled in accordance with 10 CFR 50.59. In addition, changes to these limits will be submitted to the NRC as part of the UFSAR updates provided pursuant to 10 CFR 50.71(e).

FPL has confirmed that the existing plant procedures for time response testing include acceptance criteria which reflect the RPS and ESFAS limits currently specified in TS Tables 3.3-2 and 3.3-5.

Changes to these plant procedures are subject to the provisions of Administrative Controls section 6.0 of each facility's TS.

Following approval of these proposed license amendments, the RPS and ESFAS instrumentation response time limits will be included in the next update to each UFSAR for St. Lucie Unit 1 and Unit 2.

St. Lucie Unit 1 and Unit 2 L-94-031 Docket Nos. 50-335 and 50-389 Attachment 3 Proposed License Amendments Page 3 of 3 Relocation of Tables of Instrument Res onse Time Limits GL 93-08 Conclusion The proposed amendments are line-item improvements which conform to the guidance given in Enclosures 1 and 2 of GL 93-08. As stated in GL 93-08, "The NRC has already implemented this line-item TS improvement for recently issued operating licenses and in the improved standard technical specifications." Therefore, FPL considers the proposed changes to the St. Lucie Unit 1 and Unit 2 TS to be acceptable.

4 St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Relocation of Tables of Instrument Res onse Time Limits GL 93-08 ATTACHMENT 4 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION

St. Lucie Unit 1 and Unit 2 L-94-031 Docket Nos. 50-335 and 50-389 Attachment 4 Proposed License Amendments Page 1 of 2 Relocation of Tables of Instrument Res onse Time Limits GL 93-08 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 if operation of the facility in accordance with the proposed amendment 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 consequences of an accident previously evaluated.

The proposed amendments for St. Lucie Units 1 and 2 simply relocate tables of response time limits for instrumentation of the Reactor Protective System (RPS) and Engineered Safety Features Actuation System (ESFAS) from the Technical Specifications (TS) to the Updated Safety Analysis Report (UFSAR). The proposed amendments conform to the guidance given in Enclosures 1 and 2 of USNRC Generic Letter 93-08 (GL 93-08). Neither the response time limits nor the surveillance requirements for performing response time testing will be altered by this submittal. The overall RPS and ESFAS system functional capabilities will not be changed and assurance that actions of the protective and engineered safety features systems are completed within the time limits assumed in the accident analyses is unaffected by the proposed TS changes.

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.

The proposed amendment will not change the physical plant or the modes of plant operation defined in the Facility License. The

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St. Lucie Unit 1 and Unit 2 L-94-031 Docket Nos-. 50-335 and 50-389 Attachment 4 Proposed License Amendments Page 2 of 2 Relocation of Tables of Instrument Res onse Time Limits QL 93-08 change does not involve the addition or modification of equipment nor does Therefore, itoperation alter the design or operation of plant systems.

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.

(3) Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The measurement of instrumentation response times at the frequencies specified in the TS provides assurance that actions associated with the protective and engineered safety features systems are accomplished within the time limits assumed in the St.

Lucie Units 1 and 2 accident analyses. The response time limits and the measurement frequencies remain unchanged by the proposed amendments. The proposed changes do not alter the basis for any other Technical Specification that is related to the establishment of or maintenance of a nuclear safety margin. 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 Evaluation of Proposed TS Changes, FPL has concluded that this proposed license amendment involves no significant hazards consideration.