ML17228A572

Application for Amends to Licenses DPR-67 & NPF-16, Relocating Seismic Monitoring Instrumentation LCOs for Operation,Srs & Associated Tables in TS 3.3.3.3,4.3.3.3.1 & 4.3.3.3.2 to Updated Fsar,Per NUREG-1432

ML17228A572
Person / Time
Site:	Saint Lucie
Issue date:	05/23/1994
From:	Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17228A573	List: ML17228A572 ML17228A574
References
RTR-NUREG-1432 L-94-101, NUDOCS 9406010172
Download: ML17228A572 (21)

Text

, ACCELERATED DEMONSTRATION SYSTEM

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DILUTION REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9406010172 DOC.DATE: 94/05/23 NOTARIZED: NO DOCKET 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 SAGER,D.A. Florida Power & Light Co.

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

SUBJECT:

Application for amend to license DPR-67 & NPF-16,relocating seismic monitoring instrumentation LCO,SR & assoc tables D TITLE: OR in TS 3.3.3.3,4.3.3.3.1 & 4.4.4.2 to UFSAR.

DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR Submittal: General Distribution I ENCL / SIZE: '2 NOTES C

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-2 LA 1 1 PD2-2 PD 1 1 NORRIS,J 2 2. D INTERNAL: ACRS 6 6 NRR/DE/EELB 1 1 NRR/DORS/ONDD 1 1 NRR/DRCH/HICB 1 1 NRR/DRPW 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA SRXB 1 1 NUDOCS-ABSTRACT 1 1 OC/-L GB 1 0 OGC/HDS3 1 0 REG FILE 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 20

Florida Power & Light Company, P.O. Box 128, Fort Pierce, FL 34954-0128 May 23, 1994 L-94-101 10 CFR 50.90 U. S. Nuclear Regulatory ComLLssion Attn: Document Control Desk Washington, D. C. 20555 RE: St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Pursuant to 10 CFR 50.90, Florida Power E Light Company (FPL) requests to amend Facility Operating Licenses DPR-67 and NPF-16 for St. Lucie Unit 1 and Unit 2, respectively. The proposed amendments will relocate the seismic monitoring instrumentation Limiting Conditions for Operation, Surveillance Requirements, and the associated tables contained in Technical Specifications 3.3.3.3, 4.3.3.3.1 and 4.3.3.3.2 to the Updated Final Safety Analysis Report. The basis for this request 3.s consistent with NUREG-1432, "Standard Technical Specifications, Combustion Engineering Plants" and with the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," published in the Federal Register (58 FR 39132) dated July 22, 1993.

It issued is requested that the proposed amendments, by January 1, 1995.

if approved, be Attachment 1 is an evaluation of the proposed changes. Attachment 2 is the "Determination of No Sicpufzcant Hazards Consideration."

Attachments 3 and 4 contain cop3.es of the appropriate technical specifications pages marked up to show the proposed changes.

The proposed amendments have been reviewed by the St. Lucie Facility Review Group and the FPL Company Nuclear Review Board. In accordance with 10 CFR 50.91 (b) (1), copies of the proposed amendments are being forwarded to the State Designee for the State of Florida.

Please contact us if there are any questions about this submittal.

Very truly yours, D. A.

p ger Vice sident St. L e Plant 03.4'3 t'2 /

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' aDOt:g 0SOO 00033 an FPL Gronp company PDR. ,

'c St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-335 and 50-389 Page 2 Proposed License Amendments DAS/RLD/RG/kw DAS/PSL g1124-94 Attachments cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC.

Senior Resident Inspector, USNRC, St. Lucie Plant.

Mr. W.A. Passetti, Florida Department of Health and Rehabilitative Services.

St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-538 and 50-389 Page 3 Proposed License Smendments STATE OF FLORIDA )

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COUZIY OF ST. LUCIE )

D. A. Sager being first duly sworn, deposes and says:

That he is Vice President, St. Lucie Plant for the Nuclear Division of Florida Power &. Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this 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.

/ r D. . ager STATE OF FLORIDA COUPIY OF Q7 . LUC 6 L The foregoing instrument was acknowledged before me this Z3 day of , i9'lg by D.A. Bager, who is persona y own to me and who did take an oath.

KM'57 Name of Notary Public

-;~ 4+;.= My cyuesSW KAREN WEST S CuS9926EXPIRES Aprm 18, 1998

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BONOEO THRU TROY fNN NSURANCE INC Ny Ccnmission expires.

Commission No. ~B ~VV Z. ~

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments EVALUATION OF PROPOSED TS CHMQES

St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 1 of 5 Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-67 and NPF-16 for St. Lucie Unit 1 and Unit 2, respectively, be amended to remove the Limiting Conditions for Operation (LCO), Surveillance Requirements (SR), and associated Bases for Seismic Instrumentation from the Technical Specifications (TS) . The applicable requirements of TS 3.3.3.3, 4.3.3.3.1, and 4.3.3.3.2 will be relocated to the Unit 1 (PSL1) Updated Final Safety Analysis Report (UFSAR) . The Unit 2 (PSL2) UFSAR will be updated to incorporate the requirements by reference. Relocating these requirements to the UFSARs will allow FPL to administratively control changes to the seismic monitoring instrumentation pursuant to 10 CFR 50.59 without the need to process a license amendment.

The proposed amendments are consistent with the NRC "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" that was published in the Federal Register (58 FR 39132) dated July 22, 1993. The policy statement provides specific criteria to determine which operating restrictions should be included in technical specifications as well as those which may be proposed for relocation to other documents. This proposal also conforms with NUREG-1432, "Standard Technical Specifications, Combustion Engineering Plants" dated September, 1992, in that the requirements for seismic instrumentation have been deleted from the standard TS.

Delete "Seismic Instrumentation" Delete "SEISMIC INSTRUMENTATION" and "SEISMIC MONITORING INSTRUIKSTATION SURVEILLANCE REQUIREMENTS".

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Remove from TS.

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St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 2 of 5

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Delete the text of paragraph 3/4 3.3.3.

Pursuant to 10 CFR 100, Appendix A, suitable instrumentation is installed at St. Lucie Unit 1 so that the seismic response of features important to safety can be recorded during an earthquake. The recorded data would permit comparison of the seismic re'sponse with that used as the design basis for the facility. Such a comparison would be used to decide whether the plant can continue to operate safely and to permit such timely action as may be appropriate. The instrumentation is not used to automatically shut down the plant when a seismic disturbance occurs. Since St. Lucie is a multi-unit site and the Unit 2 structural designs are essentially the same as PSL1, additional seismic instrumentation is not installed at PSL2.

The Seismic Instruments include Strong Notion Triaxial Accelerographs, Peak Recording Accelerographs, Peak Shock Recorders, Earthquake Force Monitor, and a Seismic Switch. The instruments are installed at design locations within the PSL1 Reactor Containment Building (RCB), Reactor Auxiliary Building, and the Control Room. Annunciation is provided in both the PSL1 and PSL2 Control Rooms to inform operators when the seismic instruments are first triggered and again when an acceleration intensity equivalent to 90% of the Operating Basis Earthquake is achieved. The instruments do not provide safety-related. interlocks, equipment actuations, or other control functions.

The NRC's "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" provides four criteria which delineate the constraints on design and operation of nuclear power plants that belong in the technical specifications. In addition, the policy encourages technical specification line-item improvements such as: "LCOs which do not meet any of the criteria may be proposed for removal from the technical specifications and relocated to other licensee-controlled documents, such as the FSAR." A review of the four criteria as they relate to the St. Lucie Plant Seismic Instrumentation follows-

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'St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 3 of 5 indicate in the control lid' room, a reactor coolant pressure boundary.

tt'l 'dt significant I dt,d abnormal degradation of the

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instrumentation program to record any seismic disturbance at the St.

Lucie plant site. These instruments are not installed for, nor are they capable of, detecting reactor coolant leakage. Therefore, the seismic I,

instrumentation system is not used to detect a significant abnormal degradation of the reactor coolant pressure boundary.

g hl, d g g g restriction that is an, initial condition of a Design Basis Accident or Transient analysis that either assumes the'ailure of, or presents a challenge to the integrity of a fission product barrier.

gh t !I 'g d d d selected information from a seismic disturbance as Parameters measured by the instruments do not represent process it actually occurs.

variables indicative of plant performance and which are controlled during power operation to ensure that process values remain within the analysis bounds. The seismic monitoring system contains no active design features, nor does it recure any operating restrictions, for the purpose of precluding unanalyzed accidents and transients. Therefore, initial conditions assumed in the Design Basis Accident and Transient Analyses evaluated in the PSL1 and PSL2 UFSARs do not involve the A,

seismic instrumentation system.

primary success path and gt, ~ t which functions or actuates I

Design Basis Accident or Transient analysis 'that either assumes the failure of or presents a challenge to the integrity of a fission product I

to mitigate a h

barrier.

haauaaum: g a seismic event d 'h in order to subsequently evaluate the response of plant g 'td features that are important to safety. Recording the vibration data permits comparison of the measured response of selected seismic Class I structures to data used in the design basis for the facility. The seismic monitoring system does not contain any structures, sub-systems, or components that would be needed to function or actuate for the

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St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 4 of 5 purpose of mitigating the consequences of a Design Basis Accident.

Therefore, this instrument system is not part of a primary success path for the St. Lucie plant response to an accident.

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experience or probabilistic safety assessment significant to public health and safety.

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t h monitors ensure that sufficient capability is available to record and subsequently evaluate, in part, the results of a seismic event, should it occur. The instruments cannot be used to predict, prevent, or mitigate the consequences of such an event. Consequently, the seismic instrumentation system would not be included among the structures, systems, and components typically evaluated in a probabilistic safety assessment to determine constraints of prime importance in limiting the likelihood or the severity of accident sequences that are comnonly found to dominate risk. For these reasons, the seismic instrumentation TS requirements proposed for relocation to the UFSARs are considered not significant to the protection of public health and safety.

The seismic instrumentation program is described in'Section 3.7.4 of the St. Lucie Unit 1 UFSAR. To support the proposed amendments, this section will be revised to include the Limiting Conditions for Operation, Surveillance Requirements, and Bases for TS 3/4 3.3.3 during the next scheduled UFSAR update. Since plant operating experience has shown that the capability to complete a calibration of all the instruments listed in Table 3.3-7 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is highly unlikely, the UFSAR will adopt SR 4.3.3.3.2 from the existing PSL2 TS, which requires the calibration (following a seismic event) to be performed within 5 days. The St. Lucie Unit 2 UFSAR will be updated to incorporate these same requirements by reference.

The TS requirements for operation and surveillance of seismic instrumentation are presently reflected in St. Lucie plant procedures.

Changes to these procedures are governed by the administrative controls prescribed in TS Section 6.0. Following approval of the proposed amendments, the PSL1 and PSL2 procedures will be revised, as appropriate,'o indicate the relocation of seismic 'instrumentation operability requirements.

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St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 5 of 5 The LCO for seismic monitoring instrumentation at the St. Lucie Plant does not meet any of the criteria that has been established by the NRC for the purpose of delineating constraints on design and operation of nuclear power plants that should be included and/or retained in the Technical Specifications. Removing this LCO from the facility TS is therefore consistent with the NRC Final Policy Statement on TS Improvements as well as the Standard Technical Specifications for Combustion Engineering Plants (NUREG-1432).

The proposal is essentially administrative in nature and does not change the functional capability or required performance level of the seismic instrumentation system. The UFSAR for each St. Lucie unit will incorporate the provisions of TS 3/4.3.3.3. Revisions are made to the UFSAR and are reported to the NRC in accordance with 10 CFR 50.71(e);

and any changes to the seismic instrumentation system will be controlled pursuant to 10 CFR 50.59. In addition, plant procedures that are used to implement the operability and surveillance requirements of the seismic monitors reflect the existing TS requirements and changes to these procedures are governed by the administrative controls of TS Section 6.0.

For the reasons stated above, FPL considers the proposed amendment to relocate the seismic monitoring instrumentation specifications to the Updated Final Safety Analysis Report to be acceptable.

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments D ION OF NO SIGNIFICMT EiAZABDS CONSIDERATION

St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-335 and 50-389 Attachment 2 Proposed License Amendments Page 1 of 2 DEXXZMZHATIONOF NO SIGNIFICANT HAKhRDS 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 mnenchnent would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes are administrative in nature in that the specifications for operation and surveillance of the Seismic Monitoring Instrumentation system will be relocated from Appendix A of the facility operating license to the Updated Final Safety Analysis Report for St.

Lucie Unit 1 and Unit 2. Changes to the system will be controlled by 10 CFR 50.59 and the safety analysis report is required to be updated pursuant to 10 CFR 50.71(e) . Relocation of these requirements to the UFSAR is consistent with the NRC "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" published in the Federal Register (58 FR 39132) dated July 22, 1993.

Seismic monitoring instrumentation is not an accident initiator nor a part of the success path(s) which function to mitigate accidents evaluated in the plant safety analyses. The proposed technical specification change does not involve any change to the configuration or method of operation of any plant equipment that is used to mitigate the consequences of an accident, nor do the changes alter any assumptions or conditions in any of the plant accident analyses. Therefore, 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.

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St. Lucie Unit 1 and Unit 2 L-94-101 Docket Nos. 50-335 and 50-389 Attac2m~nt 2 Proposed License Amendments Page 2 of 2 (2) Operation of the facility in accordance with the proposed aaenchent would not create the possibility of a new or different kind of accident fram any accident previously evaluated..

The proposed amendment to relocate the existing Technical Specification requirements for Seismic Monitoring Instrumentation to the Updated Final Safety Analysis Report will not change the physical plant or the modes of plant operation defined in the Facility License. The change does not involve the addition or modification of equipment nor does it alter the design or operation of plant systems. 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.

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

The proposed changes are administrative in nature in that operating and surveillance requirements for the Seismic Monitoring Instrumentation system will be relocated from Appendix A of the facility license to the Updated Final Safety Analysis Report for St. Lucie Unit 1 and Unit 2.

Seismic monitoring instruments are not used to actuate safety-related equipment, provide interlocks, or otherwise perform plant control functions. The instruments are used to record the magnitude of a seismic event, should it occur. Conditions evaluated in plant accident and transient analyses do not involve seismic instruments. The proposed changes do not alter the basis for any technical specification that is related to the establishment of, or the 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 above discussion and the supporting Evaluation of Technical Specification changes, FPL has determined that the proposed license amendment involves no significant hazards consideration.

St. Lucie Unit j. and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments ST. LUCIE UNIT 1 16&KED-UP TECHNICAL SPECIFICATION PAGES Page IV Page 3/4 3-27 Page 3/4 3-28 Page 3/4 3-29 Page B 3/4 3-2