ML17229A836
| ML17229A836 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/10/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17229A835 | List: |
| References | |
| NUDOCS 9808210139 | |
| Download: ML17229A836 (5) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20M54001 SAFE EVA T
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E E 0 NUCLEAR EACTO REG LATION RE ND E TNO 156 T LITYOP A
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LITYOPERA ING LICENSE 0 NPF-16 LO DA POWER AND L HT CO T LUCIE P U
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D OC ET NO AND 0-SIBODUI By letter dated June 3, 1998, Florida Power and Light (FPL or licensee) requested Technical Specification (TS) amendments for St. Lucie plant Units 1 and 2. The proposed amendments would change the TS Section 4.11.2.5.1 to add a reference to the Updated Safety Analysis Report (UFSAR) for supplemental surveillance requirements in the event that the explosive gas continuous monitors on the waste decay tanks become inoperable.
The licensee previously submitted TS amendment requests, which were granted by the U.S. Nuclear Regulatory Commission (NRC) and documented in an NRC Safety Evaluation dated August 20, 1996, to relocate the explosive gas monitoring instrumentation requirements from the TS to the UFSAR. Due to an inadequate licensee review of these submittals, TS Section 3.3.3.10, which discussed continuous monitoring of the waste decay tanks by 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> grab sampling, was moved to the UFSAR and the necessary reference from TS Section 4.11.2.5.1 to the UFSAR Table 13.7.1-5 was not provided. This proposed amendment would eliminate the conflict between TS Section 4.11.2.5.1 and the UFSAR Table 13.7.1-5.
ND Section 182a of the Atomic Energy Act (the Act) requires applicants for nuclear power plant operating licenses to include TS as part of the license.
The Commission's regulatory requirements related to the contents of the TS include items in five specific categories; (1) safety limits, limiting safety system settings and limiting control settings, (2) limiting conditions for operation, (3) surveillance requirements, (4) design features, and (5) administrative controls.
However, the regulation does not specify the particular requirements to be included in a plant's TS.
The Commission has provided guidance of the contents ofthe TS in its "Final Policy Statement of Technical Specification Improvements for Nuclear Power Reactors" (Final Policy Statement),
58 FR 39132 (July 22, 1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act. In particular, the Commission indicated that certain items could be relocated from the TS to licensee-controlled documents, consistent with 98082iOi39 9808iO PDR-ADOCK 05000835 PDR
the standard enunciated in Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated that "technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Consistent with this approach, the licensee had requested that TS Section 3.3.3.10 be relocated from the TS to the UFSAR, which was granted and documented in a NRC Safety Evaluation dated August 20, 1996.
It was during this relocation that the inconsistency between the TS and the UFSAR was created.
The relocated TS sections were added to the UFSAR as Sections 13.8.1.4 and 13.7.1.4 for Units 1 and 2, respectively.
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0 By letter dated June 3, 1998, FPL submitted a request for amendments to the St. Lucie TS. The requested amendments would change the current TS for Units 1 and 2 to add a footnote to TS Surveillance Requirements 4.11.2.5.1 that clarifies the available alternatives when continuous sampling of waste gases in the waste decay tanks is not available.
The current surveillance requirements in TS Section 4.11.2.5.1 read as follows:
The concentration of oxygen in the waste gas decay tank shall be determined to be within the above limits by continuously monitoring the waste gases in the on service waste gas decay tank.
The licensee proposed to modify this paragraph to add an asterisk after the word "continuously,"
which relates to a footnote added to the same page which would read:
When continuous monitoring capability is inoperable, waste gases shall be monitored in accordance with the actions specified for the Waste Gas Decay Tanks Explosive Gas Monitoring System in Chapter 13 of the Updated Final Safety Analysis Report.
UFSAR Section 13.7.1.5 describes the limiting conditions for operation and surveillance requirements for the explosive gas monitoring system.
The limiting condition for operation references Table 13.7.1-5 in the UFSAR when less than the minimum number of explosive gas monitoring instrumentation channels is operable.
Action 1 of Table 13.7.1-5 applies during waste gas system operation and reads as follows:
With the number of channels OPERABLE on less than required by the Minimum Channels OPERABLE requirement, operation of this system may continue for up to 30 days provided samples of oxygen are analyzed by the lab gas partitioner at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The explosive gas monitoring instrumentation monitors the concentrations of potentially explosive gas mixtures in the Gaseous Radwaste System.
The explosive gas monitoring instrumentation requirements address detection of possible precursors to the failure of the waste gas system but.do not prevent or mitigate design basis accidents or transients which assume a
failure of or present a challenge to a fission product barrier. Acceptable concentrations of explosive gases are actually controlled by the limiting conditions for operation and surveillance requirements of TS 3.11.2.5, Explosive Gas Mixture.
These amendments do not involve a changes to the design or operation of the system, the levels of concentration of potentially explosive gases, or the actions that willbe taken in the event that continuous monitoring of the waste gas decay tanks becomes inoperable.
These proposed amendments provide clarification to the TS surveillance requirement as discussed previously, and are therefore administrative in nature.
4.0 ST F
CO CLUSI The staff concludes that the proposed amendments provide both clarification and a necessary reference to the UFSAR for St. Lucie Units 1 and 2. The requirements contained in the UFSAR, and referenced by these proposed amendments, were incorporated by NRC Safety Evaluation dated August 20, 1998. Therefore, the staff finds the proposed amendments acceptable.
5.0 STATE CON T
0 Based upon a letter dated March 8, 1991, from the State of Florida to Deborah A. Miller, NRC, the State of Florida has no comments.
6 0 ENVIR N
ENT C
ERATION The amendment changes administrative requirements and surveillance requirements.
The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (63 FR 35990). Accordingly, this amendment meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
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GOOUI The Commission has concluded, based on the considerations discussed above, that, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation, in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment willnot be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: William C. Gleaves Dated August-10, 1998
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