ML17241A343
| ML17241A343 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/24/1999 |
| From: | Stall J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17241A344 | List: |
| References | |
| L-99-099, L-99-99, NUDOCS 9906020092 | |
| Download: ML17241A343 (19) | |
Text
CATEGORY 1 REGULA Y INFORMATION DISTRIBUTIO1. SYSTEM (RIDS)
ACCESSION NBR:9906020092 FACIAL:50-389 DOC.DATE: 99/05/24 St. Lucie Plant, Unit 2, Florida Power NOTARIZED: YES 5: Light Co.
DOCKET I 05000389 QTA.'B.NAME AUTHOR AFFILIATION STALL,J.A. Florida Power & Light Co.
RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)
SUBJECT:
Application for amend to license NPf-16,revising Unit 2 TS 3/4.5.1, "Safety Injection Tanks," by clarifying nonconservative wording of Surveillance 4.5.1.1.d.1 to ali surveillance with intent 8 design bases requirements.
DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: General Distribution E
NOTES:
RECIPIENT COPIES COPIES ID CODE/NAME LTTR ENCL LTTR ENCL LPD2-2 LA 1 1 1 1 GLEAVES,W 1 1 INTERNAL: ACRS NRR/DE/EEIB 1 1~FILE=CENTER 0~~1 1 1 NRR/DE/EMCB 1 NRR/DE/EMEB 1 1 NRR/DSSA/SPLB 1 NRR/DSSA/SRXB 1 1 NRR/SPSB JUNG, I 1 NUDOCS-ABSTRACT 1 1 OGC/RP 1 EXTERNAL: NOAC NRC PDR D
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'O TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATIONr CONTACT LISTS THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 14
Florida Power 5 Light Company, 6351 S. Ocean Drive, Jensen Beach, FL 34957 L-99-099 May 24, 1999 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 RE: St. Lucie Unit 2 Docket No. 50-389 Proposed License Amendment SIT and SDC Isolation Interlock Surveillances On February 11, 1999, St. Lucie non-licensed personnel discovered discrepancies between the St. Lucie Unit 2 Technical Specification surveillance requirements for the safety injection tank (SIT) isolation valve and the shutdown cooling system (SDC) isolation valve interlocks and the plant procedures used to implement the surveillances.
Specifically, the interlocks were being tested conservatively with regard to Technical Specification requirements (current plant procedures calibrate and test the setpoints at less than 515 psia). Although past surveillances were not in verbatim compliance with the Technical Specification requirements, the intent of the surveillances were met. This event was determined reportable to the NRC pursuant to the requirements of 10 CFR 50.73 (a)(2)(i). As such, FPL submitted LER 1999-001, "Inadequate Technical Specification Surveillance Requirements for SIT and SDC Isolation Valves," via FPL letter, L-99-064, dated March 10, 1999.
Pursuant to 10 CFR 50.90, Florida Power 8 Light Company (FPL) requests to amend Facility Operating License NPF-16 for St. Lucie Unit 2 by incorporating the attached Technical Specifications (TS) revisions. The proposed amendment revises Unit 2 Technical Specification 3/4.5.1, "Safety Injection Tanks," (SIT) by clarifying the nonconservative wording of Surveillance 4.5.1.1.d.1 to align the surveillance with the intent and design bases requirements being verified. This proposed license amendment (PLA) also revises Unit 2 Technical Specification 3/4.5.2, "ECCS Subsystems Tavg Greater Than or Equal to 325'F," by clarifying the nonconservative wording of Surveillance 4.5.2.e.1 to align the surveillance with the intent and design bases requirements being verified. The current Technical Specification surveillance wording for Surveillances 4.5.1.1.d.1 and 4.5.2.e.1, if implemented using verbatim compliance, could result in a potentially nonconservative pressure value setting insufficient to assure plant safety.
The NRC has provided guidance for dispositioning of Technical Specifications that are insufficient or represent nonconservatism. NRC Administrative Letter 98-1 0, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety,"
dated December 29, 1998, provides guidance and due to the potential for an adverse impact on safe plant operation, requires prompt submittal of a license amendment request.
Attachment 1 is an evaluation of the proposed changes. Attachment 2 is the "Determination of No Significant Hazards Consideration." Attachment 3 contains copies of the affected Technical Specifications pages marked up to show the proposed changes.
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St. Lucie Unit 2 L-99-099 Docket Nos. 50-389 Page 2 Proposed License Amendment SIT and SDC Isolation Interlock Surveillances 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, J. A. Stall Vice President St. Lucie Plant JAS/E JW/KWF Attachments cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant Mr. W. A. Passetti, Florida Department of Health and Rehabilitative Services
6t. i ucle Unit 2 ~ L-99-099 Docket Nos. 50-389 Page 3 Proposed License Amendment SIT and SDC Isolation Interlock Surveillances STATE OF FLORIDA )
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COUNTY OF ST. LUCIE )
J. A. Stall being first duly sworn, deposes and says:
That he is Vice President, St. Lucie Plant, for the Nuclear Division of Florida Power 8 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.
J. A. Stall STATE OF FLORIDA COUNTY OF S1 L~
Sworn to and subscribed before me I
this ~t day of by J. A. Stall, who is personally known to me.
Signature of,Potary Public-State of Florida LeSIie J. WhiNTcii Iea:a': I MY COMMISSION CC646183 EXPIRES May 12, 2001
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Name of Notary Public(Print, Type, or Stamp)
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Docket No. 50-389 Attachment 1 Proposed License Amendment Page 1 of 8 SIT and SDC Interlock Surveillances Attachment 1 to FPL Letter L-99-099 EVALUATIONOF PROPOSED TS CHANGES
E' St. Lucie Unit 2 L-99-099 Docket No. 50-389 Attachment 1 Proposed License Amendment Page2of8 SIT and SDC Interlock Surveillances EVALUATIONOF PROPOSED TS CHANGES Introduction The proposed license amendment (PLA) to Facility Operating License NPF-16 for St. Lucie Unit 2 (PSL2) revises Unit 2 Technical Specification 3/4.5.1, "Safety Injection Tanks," (SIT) by clarifying the nonconservative wording of Surveillance 4.5.1.1.d.1 to align the surveillance with the intent and design bases requirements being verified. This PLA also revises Unit 2 Technical Specification 3/4.5.2, "ECCS Subsystems Tavg Greater Than or Equal to 325'F," by clarifying the nonconservative wording of Surveillance 4.5.2.e.1 to align the surveillance with the intent and design bases requirements being verified.
Verbatim compliance with current Technical Specification surveillance wording for Surveillances 4.5.1.1.d.1 and 4.5.2.e.1 could result in a potentially nonconservative pressure value setting insufficient to assure plant safety. The proposed changes, therefore, are considered administrative in that they explicitly align these surveillances with the intent and design bases requirements being verified.
The NRC has provided guidance for dispositioning of Technical Specifications that are insufficient or represent nonconservatism. NRC Administrative Letter 98-1 0, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety,"
dated December 29, 1998, provides guidance and due to the potential for an adverse impact on safe plant operation, requires prompt submittal of a license amendment request.
Background/Discussion Every 18 months, Technical Specification Surveillance 4.5.1.1.d.1 requires verification that each SIT isolation valve (V-3614, V-3624, V-3634, and V-3644) opens automatically when actual or simulated reactor coolant system (RCS) pressure exceeds 515 psia. Every 18 months, Technical Specification Surveillance 4.5.2.e.1 requires verification of the automatic isolation and interlock action of the SDC system (V-3480, V-3481, V-3651, and V-3652) from the RCS when RCS pressure (actual or simulated) is greater than or equal to 515 psia.
Plant Procedures 2-1400064P, "Installed Plant Instrumentation Calibration (Pressure),"
and 2-1200055, "Functional Calibration of the Automatic Isolation of the Shutdown Cooling System from the Reactor Coolant System," calibrate and test the automatic opening of the SIT isolation valves, and closing of the SDC system isolation valves at 500 psia. This proposed license amendment (PLA) addresses the concern between the Technical Specification requirement to test the SIT isolation valve opening and the SDC system isolation valve closing at 515 psia and the actual practice of testing at 500 psia. This activity does not apply to the SDC system isolation valve open interlock because it is calibrated and tested at the Technical Specification requirement of 276 psia.
St. Lucie Unit 2 Ddcket No. 50-389 Proposed License Amendment t L-99-099 Attachment 1 Page 3 of 8 SIT and SDC Interlock Surveillances On February 11, 1999, St. Lucie non-licensed personnel discovered discrepancies between the St. Lucie Unit 2 Technical Specification surveillance requirements for the safety injection tank (SIT) isolation valve and the shutdown cooling system (SDC) isolation valve interlocks and the plant procedures used to implement the surveillances.
Specifically, the interlocks were being tested conservatively with regard to Technical Specification requirements (current plant procedures calibrate and test the setpoints at less than 515 psia). Although past surveillances were not in verbatim compliance with the Technical Specification requirements, the intent of the surveillances were met. This event was determined reportable to the NRC pursuant to the requirements of 10 CFR 50.73 (a)(2)(i). As such, FPL submitted LER 1999-001, "Inadequate Technical Specification Surveillance Requirements for SIT and SDC Isolation Valves," via FPL letter, L-99-064, dated March 10, 1999.
SIT Descri tion The function of the SITs is to supply borated water to the reactor vessel during the blowdown phase of a loss of coolant accident (LOCA), to provide inventory to help accomplish the refill phase that follows thereafter, and to provide RCS makeup for a small break LOCA. The SITs are pressure vessels partially filled with borated water and pressurized to between 500 and 650 psig with nitrogen gas. During MODE 3 operation with pressurizer pressure less than 1750 psia, allowable SIT pressure is 235 to 650 psig.
For plant operation in MODE 3 heatup and cooldown evolutions, with the SIT discharge isolation valves open, the control room operators adjust SIT pressures to remain below RCS pressure to prevent inadvertent SIT discharge. The SITs are passive components since no operator or control action is required for them to perform their function. Internal tank pressure is sufficient to discharge the contents to the RCS, if RCS pressure decreases below the SIT pressure.
The SIT isolation valves are interlocked with pressurizer pressure instrumentation channels to ensure that the valves will automatically open as RCS pressure increases (currently set at 500 psia), and to prevent inadvertent closure prior to or during an accident. The valves also receive a safety injection actuation signal (SIAS) to open.
These features ensure that the valves meet the intent of Institute of Electrical and Electronic Engineers (IEEE) Standard 279-1971 for "operating bypasses" and the SITs will be available for injection without reliance on operator action. However, to satisfy single failure considerations, power to the SIT discharge isolation valves is removed once the valves are open. Periodic Technical Specification surveillances verify that power to the SIT discharge isolation valves is removed and that the valves are open.
SIT 0 erabilit Technical S ecification 3/4.5.1 Each RCS SIT shall be operable with:
- a. the isolation valve open,
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St: Lucie Unit 2 L-99-099 Docket No. 50-389 Attachment 1 Proposed License Amendment Page4of8 SIT and SDC Interlock Surveillances
- b. a contained borated water volume of between 1420 and 1556 cubic feet,
- d. a nitrogen cover-pressure of between 500 and 650 psig.
This is applicable in MODES 1, 2, 3*. The " 's applicable with pressurizer pressure greater than or equal to 1750 psia. In MODE 3 with the pressurizer pressure less than 1750 psia, at least three SITs shall be operable, each with a minimum pressure of 235 psig and a maximum pressure of 650 psig. The water volume becomes less restrictive when below 1750 psia (contained water volume of between 1250 and 1556 cubic feet). With all four SITs operable below 1750 psia, the water volume is even less restrictive (contained water volume of between 833 and 1556 cubic feet).
Operability of the SITs includes the requirement to verify that each SIT be demonstrated operable by verifying at least once per 18 months, that each SIT isolation valve opens automatically under each of the following conditions (TS requirement 4.5.1.1.d):
- 1. when an actual or simulated RCS pressure signal exceeds 515 psia, and
- 2. upon receipt of a safety injection test signaI.
Surveillance Requirement 4.5.1.1.d.1, as stated, allows a setpoint value of 515 psia or greater. This value is potentially nonconservative with the UFSAR design basis that describes the SITs as being available at 515 psia.
SDC S stem Descri tion The SDC system is designed to achieve and maintain a cold shutdown condition by removing residual energy from the RCS and decay heat from the reactor core. While the RCS has a design pressure of 2500 psia, the majority of the SDC system components have a design pressure of 500 psig (with selected portions of the suction piping designed for 350 psig). Since two piping systems of different design pressures are connected, suitable isolation capability must be provided when the RCS is being operated at higher pressures. As described within UFSAR Section 5.4.7.2.3, protection against overpressure in the SDC system is provided by relief valves and interlocks. The low temperature overpressure protection (LTOP) analysis and associated setpoints are not affected by this issue.
Since a number of pressurization sources exist within or are connected to the high pressure RCS, the low pressure SDC system must be protected against postulated pressurization transients when the systems are connected. To accomplish this, multiple relief valves are provided on each SDC system suction line to protect against overpressurization.
The overpressure protection of the SDC system, provided by SDC system relief valves, is based on those transients postulated to occur during normal SDC system operation (i.e.,
St: Lucie Unit 2 L-99-099 Docket No. 50-389 Attachment 1 Proposed License Amendment Page5of8 SIT and SDC Interlock Surveillances the inadvertent starting of two high pressure safety injection (HPSI) pumps, three charging pumps, isolation of letdown, and all pressurizer back-up heaters energized. These relief valves are not intended to protect the SDC system against overpressurization as a result of being inadvertently exposed to full RCS pressure during power operation; the SDC system isolation valves and open interlock permissive provide this function.
Per UFSAR Section 54.7.2.3, the SDC system isolation valves are interlocked with the pressurizer pressure instrumentation channels to prevent their opening with RCS pressure above 276 psia and ensure that the valves will automatically close as RCS pressure increases above 500 psia. The SDC system isolation valve automatic closing interlock (ACI) provides a close signal to the isolation valves when RCS pressure exceeds 500 psia.
Therefore, should these valves be inadvertently left open during RCS heatup and pressurization, the SDC system isolation valves would automatically close upon reaching this predetermined pressure setpoint. Likewise, while in a SDC alignment, should an RCS pressure transient occur resulting in pressurizer pressure above 500 psia, the SDC isolation valves would isolate and prevent potential loss of RCS inventory via the SDC system (multiple relief valves).
ECCS 0 erabilit Technical S ecification 3/4.5.2 includes SDC isolation valve interlock Unit 2 Technical Specification 3/4.5.2, "ECCS Subsystems Tavg Greater Than or Equal to 325'F," requires two independent emergency core cooling system (ECCS) subsystems to be operable with each subsystem comprised of:
- a. one operable high pressure safety injection pump,
- b. one operable low pressure safety injection pump, and
- c. an independent operable flow path capable of taking suction from the refueling water tank on a safety injection actuation signal and automatically transferring suction to the containment sump on a recirculation actuation signal, and
- d. one operable charging pump.
This is applicable in MODES 1, 2, and 3*. The """ is applicable with pressurizer pressure greater than or equal to 1750 psia.
Operability of each ECCS subsystem includes the requirement to verify the automatic isolation and interlock action of the SDC system. This surveillance is to be demonstrated operable by verifying, at least once per 18 months, that each SDC isolation valve closes automatically under the following conditions (Technical Specification Requirement 4.5.2.e.1):
"Verifying automatic isolation and interlock action of the shutdown cooling system from the Reactor Coolant System when RCS pressure (actual or simulated) is greater than or equal to 515 psia, and that the interlocks prevent opening the shutdown cooling system isolation valves when RCS pressure (actual or simulated) is greater than or equal to 276 psia."
St: Lucie Unit 2 L-99-099 Docket No. 50-389 Attachment 1 Proposed License Amendment Page 6 of 8 SlT and SDC Interlock Surveillances Unit 2 Technical Specification 3/4.5.3, "ECCS Subsystems Tavg Less Than 325'F,"
applicable in MODES 3 and 4, requires ECCS subsystem be demonstrated operable (Surveillance Requirement 4.5.3) per the applicable surveillance requirements of 4.5.2, and therefore, does not require any changes to the Technical Specification.
Proposed Changes: Description and Bases/Justification The affected TS pages, marked up to show the proposed changes, are included in .
Descri tion of Chan es This PLA revises Unit 2 Technical Specification 3/4.5.1, "Safety Injection Tanks" (SIT), by clarifying the nonconservative wording of Surveillance 4.5.1.1.d.1 to align the surveillance with the intent and design bases requirements being verified. This proposed change provides clarification for the specification statement, "When an actual or simulated RCS pressure signal exceeds 515 psia, and" by replacing the statement with the explicit wording "Prior to an actual or simulated RCS pressure signal exceeding 515 psia, and."
See Attachment 3 for the wording of proposed TS change. This proposed change will align the surveillance specification with the intent and design bases requirements intended to be verified.
This PLA also revises Unit 2 Technical Specification 3/4.5.2, "ECCS Subsystems Tavg Greater Than or Equal to 325'F," by clarifying the nonconservative wording of Surveillance 4.5.2.e.1 to align the surveillance with the intent and design bases requirements being verified. This proposed change provides clarification for the specification statement, "Verifying automatic isolation and interlock action of the shutdown cooling system from the reactor coolant system when RCS pressure (actual or simulated) is greater than or equal to 515 psia," by replacing "greater" with the explicit wording "less." See Attachment 3 for the wording of proposed TS change. This proposed change will align the surveillance specification with the intent and design bases requirements intended to be verified.
Bases/Justification of Pro osed Chan es The Technical Specification surveillances for the SIT and SDC system isolation valves are currently worded such that the applicable setpoints represent minimum floor values where initiation of the protective action occurs. Verbatim compliance with the Technical Specification surveillance requirements could lead to non-conservative operation of the unit and a loss of the protective action because the surveillances do not include an upper limit for the applicable setpoints. In actuality, these setpoints should establish an upper value at which the protective action occurs.
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St. Lucie Unit 2 L-99-099 Docket No. 50-389 Attachment 1 Proposed License Amendment Page7of8 SIT and SDC Interlock Surveillances In the case of the SIT isolation valve auto-open protective action, Surveillance Requirement 4.5.1.1.d.1 specifies a setpoint of greater than or equal to 515 psia. 515 psia represents the lowest SIT pressure supported by the safety analysis or the lowest pressure at which time the SITs should be automatically aligned to inject into the RCS.
Surveillance Requirement 4.5.2.e.1 for the SDC system isolation valve auto-close protective action, as stated, allows a setpoint value of 515 psia or greater. This value is potentially nonconservative with the UFSAR design basis to isolate the higher pressure RCS from the low pressure SDC system. The SDC isolation valves are described in the UFSAR as being isolated by 515 psia with the interlock action "to close" setpoint value of 500 psia (UFSAR Sections 5.4.7.2.3 and 7.6).
The SDC system isolation valve auto-close protective action is a backup feature designed to protect against RCS pressure transients and operator error during a plant start up. SDC system overpressure protection during plant start up evolutions is provided by the SDC relief valves. It is preferable that the SDC auto-closure interlock (ACI) feature be provided at a lower pressure than currently specified by the Technical Specifications. Therefore, a setpoint of 500 psia is conservative and preferable to the minimum value of 515 psia as required by the Technical Specifications.
The explicit wording (text) of the applicable Technical Specification surveillances is to ensure that the SIT and SDC isolation valves are repositioned at or above 515 psia. The issue, therefore, is that the explicit requirements of the Technical Specification surveillances do not coincide with the intent and design basis function and could result in a potentially nonconservative pressure value setting insufficient to assure plant safety. Low mode overpressure protection for the SDC system during plant start-up evolutions is provided by the SDC system relief valves, and the SDC system ACI feature is provided for protection against RCS pressure transients and operator error during a start up.
Environmental Consideration The proposed license amendment changes requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The proposed amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure. FPL has concluded that the proposed amendment involves no significant hazards consideration and meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and that, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.
St. Lucie Unit 2 L-99-099 Docket No. 50-389 Attachment 1 Proposed License Amendment Page 8 of 8 SIT and SDC Interlock Surveillances Conclusion Verbatim compliance with the current wording of Technical Specification Surveillances 4.5.1.1.d.1 and 4.5.2.e.1 could result in potentially nonconservative pressure value settings that would be insufficient to assure plant safety. Although the current plant procedures calibrate and test the setpoints at 500 psia, these settings are conservative with regards to the design bases functions being verified by surveillance. The proposed changes, therefore, are considered administrative in that they explicitly align these surveillances with the intent and design bases requirements being verified. The proposed surveillance clarifications provide explicit wording to align the surveillances with the design basis function, assuring safe plant operation and safety.
St. Lucie Unit 2 L-99-099, Docket No. 50-389 Attachment 2 Proposed License Amendment Page 1 of 3 SIT and SDC Interlock Surveillances Attachment 2 to FPL Letter L-99-099 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION
St: Lucie Unit 2 L-99-099
'ocket No. 50-389 Attachment 2 Proposed License Amendment Page2of3 SIT and SDC Interlock Surveillances DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Description of amendment request. The proposed license amendment (PLA) to Facility Operating License NPF-16 for St. Lucie Unit 2 (PSL2) revises Unit 2 Technical Specification 3/4.5.1, "Safety Injection Tanks," (SIT) by clarifying the nonconservative wording of Surveillance 4.5.1.1.d.1 to align the surveillance with the intent and design bases requirements being verified. This PLA also revises Unit 2 Technical Specification 3/4.5.2, "ECCS Subsystems Tavg Greater Than or Equal to 325'F," by clarifying the nonconservative wording of Surveillance 4.5.2.e.1 to align the surveillance with the intent and design bases requirements being verified. The current Technical Specification surveillance wording for Surveillances 4.5.1.1.d.1 and 4.5.2.e.1, if implemented using verbatim compliance, could result in a potentially nonconservative pressure value setting insufficient to assure plant safety. The proposed changes, therefore, are considered administrative in that they explicitly align these surveillances with the intent and design bases requirements being verified.
Pursuant to 10 CFR 50.92, 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; (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 does not involve an increase in the probability or consequences of any accident previously evaluated. There are no physical changes to plant equipment or changes in plant operation that could initiate an accident or adversely affect accident mitigation or consequences. This PLA provides a wording clarification of the Technical Specification Surveillance 4.5.1.1.d.1 requirements for verifying that each SIT isolation valve (V-3614, V-3624, V-3634, and V-3644) opens automatically prior to exceeding an actual or simulated RCS pressure of 515 psia, such that design bases functions and safety are assured. This PLA also provides a wording clarification (Surveillance 4.5.2.e.1) for the automatic isolation and interlock action of the SDC system (V-3480, V-3481, V-3651, and V-3652) from the RCS prior to exceeding an RCS pressure (actual or simulated) of 515 psia, such that design bases functions and safety are assured. These clarifications explicitly align the surveillance requirements with the intent and design basis functions for the valves being verified.
As such, this change is considered administrative.
0
, St. Lucie Unit2 L-99-099 Docket No. 50-389 Attachment 2 Proposed License Amendment Page 3 of 3 SIT and SDC Interlock Survelllances (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 create the possibility of a new or different kind of accident from any accident previously evaluated. There are no physical changes to plant equipment or changes in plant operation that could create a new or different kind of accident. This PLA does not result in any plant configuration changes or new failure modes. This PLA provides a wording clarification of the Technical Specification Surveillance 4.5.1.1.d.1 requirements for verifying that each SIT isolation valve (V-3614, V-3624, V-3634, and V-3644) opens automatically prior to exceeding an actual or simulated RCS pressure of 515 psia. This PLA also provides a wording clarification (Surveillance 4.5.2.e.1) for the automatic isolation and interlock action of the SDC system (V-3480, V-3481, V-3651, and V-3652) from the RCS prior to exceeding an RCS pressure (actual or simulated) of 515 psia. These clarifications explicitly align the surveillance requirements with the intent and design basis functions for the valves being verified. As such, this change is considered administrative.
(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 does not involve a reduction in the margin of safety. This administrative PLA clarifies the surveillance requirements of the subject Technical Specifications by aligning the surveillances with the intent and design bases functions for the valves being verified. This PLA does not result in any plant configuration changes. As such, the assumptions and conclusions of the accident analyses in the UFSAR remain valid and the associated safety limits will continue to be met.
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.