ML17228B031

Application for Amends to Licenses DPR-67 & NPF-16,deleting Refs to Automatic Tester for Containment Personnel Air Lock from TS 4.6.1.3

ML17228B031
Person / Time
Site:	Saint Lucie
Issue date:	02/22/1995
From:	Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17228B032	List: ML17228B031 ML17228B033
References
L-95-040, L-95-40, NUDOCS 9503010192
Download: ML17228B031 (10)

Text

PR.IC3R.I"O'Y' CCELERATED RIDS PROCESSING)

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9503010192 DOC.DATE: 95/02/22 NOTARIZED: YES 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 amends to licenses DPR-67 & NPF-16,deleting refs to automatic tester. for containment personnel air lock TITLE:

NOTES OR from TS 4.6.1.3.

DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR Submittal: General Distribution l ENCL L SIZE:

RECIPIENT COPIES COPIES ID CODE/NAME LTTR ENCL LTTR ENCL PD2-2 LA 1 1 1 1 NORRIS,J 1 1 INTERNAL: ACRS 6 6 ~FILE CENTER 0 > 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P!-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON"I'EED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 17 ENCL 16

Florida Power & Light Company, P.O. Box 128, Fort Pierce, FL 34854-0128 February 22, 1995 L-95-040 10 CFR 50.90 U. S. Nuclear Regulatory Commission 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 Containment Air Lock Automatic Tester Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requests to amend Facility Operating Licenses DPR-67 and NPF-16 for St. Lucie Unit 1 and Unit 2, respectively, by incorporating the attached Technical Specifications (TS) revisions. The proposed changes are administrative in nature in that reference to an "automatic" containment air lock tester will be deleted from TS 4.6.1.3. It is requested that the proposed amendments, approved, be issued by September 1, 1995, prior to the next if scheduled refueling outage for St. Lucie Unit 2.

Attachment 1 is an evaluation of the proposed changes. Attachment 2 is the "Determination of No Significant Hazards Consideration."

Attachments 3 and 4 contain copies 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 ccrc if there are any questions about this submittal.

Very truly yours, D. A. ger Vice r sident St. Lu e Plant DAS/RLD Attachments 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.

9505010192 950222 PDR ADDDK 05000555 an I-pL't1rdap~corrrpaf~y p PDR

St. Lucie Unit 1 and Unit 2 L-95-040 Docket Nos. 50-335 and 50-389 Page 2 Proposed License Amendments l Containment Air Lock Automatic Tester

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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.

A. ager STATE OF FLORIDA COUNTY OF 5( ~ LUA C The me foregoing instrument this ZZ<<~ day of by D.A. Sager, who is personally known I +~~,

was acknowledged 19 to before l5 me and who did take an oath.

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St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Containment Air Lock utomatic Tester ATTACHMENT 1 EVALUATION OP PROPOSED TS CHANGES

St. Lucie Unit 1 and Unit 2 L-95-040 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 1 of 2 Containment Air Lock Automatic Tester EVALUATION OP PROPOSED TS CHANGES Introduction Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating License DPR-67 for St. Lucie Unit 1 (PSL1) and NPF-16 for St. Lucie Unit 2 (PSL2) be revised to delete references to the automatic tester for the containment personnel air lock.

FPL has discontinued using the automatic leakage measurement systems and has no plans to use them in the future. The systems are not safety related and are scheduled for removal in accordance with approved plant procedures.

PSL1 and PSL2 Pro osed Technical S ecification TS Chan es TS 3/4.6.1.3 provides operability and surveillance requirements (SR) for the containment air locks and, in part, requires that seal leakage be determined by precision flow measurement when the volume between the door seals is pressurized to the specified pressure.

Specifically, SR 4.6.1.3.a.l states (PSL2 value in parenthesis):

"For the personnel air lock, greater than or equal to P 39.6 (41.8) psig for at least 15 minutes with the automatic tester."

if not tested For SR 4.6.1.3.a.1: Delete the words, "if not tested with the automatic tester" Back round Approved plant procedures are used to perform air lock testing and include specific instructions for the use of a portable local leak rate (LLRT) cart, or the automatic leak rate tester, to check the integrity of the seals for personnel air lock inner and outer doors. Either test method is capable of demonstrating operability pursuant to SR 4.6.1.3.a.l.

Each PSL unit has an automatic tester that is designed as a dedicated system to automatically initiate a test sequence upon door closure, or by manual switch actuation. The system function is to pressurize the intra-seal volume to a preset pressure and

St. Lucie Unit 1 and Unit 2 L-95-040 Docket Nos. 50-335 and 50-389 Attachment 1 Proposed License Amendments Page 2 of 2 Containment Air Lock Automatic Tester monitor the air flow necessary to maintain that pressure. All timing functions and calibration values for measuring leakage are user programmable. Leak test "trouble" alarms are actuated in the control room to annunciate a test failure and/or failure of the system to operate properly.

The same model automatic tester is installed at each PSL unit. The tester is not safety related, is not used to maintain air lock integrity, and the tubing installed to pressurize the intra-seal volume does not penetrate the containment atmosphere boundary.

Bases for the Pro osed Chan es Persistent difficulties have been experienced with operation of the automatic testing systems for the containment personnel air locks for both St. Lucie Units 1 and 2. These operational difficulties include initiation of distracting "nuisance alarms" in the control rooms and, as a result, the systems are no longer used. FPL has no plans to use the automatic testers in the future, and has scheduled them for removal using approved, plant configuration control procedures.

TS 3/4.6.1.3 specifies Limiting Conditions for Operation (LCO) for the Containment Air Locks. Surveillance testing of air lock seals provides assurance that the overall air lock leakage will not become excessive due to seal damage during the intervals between leakage tests. The required test intervals, test pressure, and leakage acceptance criteria are not being changed by the proposed license amendment. The containment personnel air lock automatic leak rate tester is only one method of verifying seal leakage.

Automatic testing is not required to demonstrate operability of the air locks, or otherwise required to comply with the specifications of the LCO.

Conclusion The proposed TS revision does not alter the operability requirements for the containment air locks; rather, only the reference to an automatic tester (which is not required for compliance with the test criteria) will be deleted. Therefore, FPL considers the proposed change to be administrative in nature.

St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Containment Air Lock Automatic Tester ATTACHMENT 2 DETERMINATION OF NO SIGNIFICANT HMARDS CONSIDERATION

St. Lucie Unit 1 and Unit 2 L-95-040 Docket Nos. 50-335 and 50-389 Attachment 2 Proposed License Amendments Page 1 of 2 Containment Air Lock Automatic Tester DETERMZNATZON OP NO SZGNZPZCANT HAZARDS CONSZDERATZON 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 consequences of an accident previously evaluated.

The proposed amendment is administrative in nature in that the revision will eliminate the wording associated with optional use of the personnel airlock automatic leakage tester. The requirement for testing the personnel airlock at a pressure greater than or equal to P, for at least 15 minutes remains unchanged. The acceptance criteria of personnel airlock seal leakage less than 0.01 L, is also unchanged. The automatic leakage tester 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 proposal does not involve any changes to the configuration or method of operation of any plant equipment that is used to mitigate the consequences of an accident, nor does it alter any assumptions or conditions in the plant safety 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.

(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 to remove the reference to the personnel airlock automatic tester from the technical specifications will not introduce any new failure modes or system interactions, nor will it

St. Lucie Unit 1 and Unit 2 L-95-040 Docket Nos. 50-335 and 50-389 Attachment 2 Proposed License Amendments Page 2 of 2 Containment Air Lock Automatic Tester require the installation of any new or modified equipment. The requirement to leak test the personnel air locks will not be changed. Thus, 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 proposed amendment would not involve a significant reduction in a margin of safety.

The proposed amendment is administrative in nature in that eliminates the reference to the personnel airlock automatic leakage it tester but does not alter the surveillance and acceptance criteria for such testing. Seal leakage testing is performed in accordance with an approved plant procedure which allows use of either an automatic tester or a portable testing cart. The automatic leakage tester is not used to actuate safety related equipment, provide interlocks, or perform plant control functions. The conditions evaluated -in the plant accident and transient analyses do not involve this tester. The proposed change does 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 does 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.