ML17341A844

Advises of Intent to Conduct Hot Functional Test on or About 820206,subj to Interpretations Stated in Encl Safety Evaluation.Tech Spec Requirements That May Be Waived Listed

ML17341A844
Person / Time
Site:	Turkey Point
Issue date:	01/27/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
L-82-30, NUDOCS 8202020343
Download: ML17341A844 (10)

Text

REGULATORY FORMA'TION DISTRIBUTION 'SY, M

(R IDS)

ACCESSION NBR:8202020343 DOC ~ DATE: 82/01/27.

NOTARI'ZED:

NO DOCKET

¹'ACIL:50"250 Tur key Point <<Planti "Unit 3i Flor ida IPower.:and Light 'C 05000250

,'50-251 Tur key Point Pl anti 'Uni t 4i Florida!Power and Light C

05000251 AUTH INANE AUTHOR A F F II.I ATION UHRIGi R ~ E ~

Florida 'Power 8 Li'ght Co.

RBC IP ~ NAME RECIPIENT AFFILIATION EI SENHUTi D. G.

D i v-i s i on o f Li,censing

SUBJECT:

Advises of intent to conduct hot,functiona'.1.'test on or -about 820206isubJ

~to iqtrepretations stated in Sencl ssafety evaluation. Tech 'Spec requirements that may be waived listed.

DISTRIBUTION.CODE: 'AOOIS COPIES >RECEIVED:LTR ENCL

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TITLE: General Distribution for after Issuance of.Operating License NOTES:

RECI:PIENT ID CODE/NAME ACTION; ORB ¹1 BC 01 1COP IES LT'TR ENCL 13 13

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1 TOTAL NUMBER OF:COPIES REQUIRED; LRTTR 35

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Illa'ffice of Nuclea, ation Attention:

Mr. Darr

isenhut, Director Division of Licensing U.S.

Nuclear Regulatory Commission Washington, D.C. 20555 yQll/g~

i/tavvN FLORIDAPOWER & LIGHTCOMPANY January 27, 1982 L-82-30

Dear Mr. Eisenhut:

Re:

Turkey Point Units 3 5 4 Docket No. 50-250 8 50-251 Hot Functional Testing As part of the Steam Generator Repair Program for Turkey Point Unit 3, we are planning to conduct a hot functional test in early February 1982.

To conduct the test the Reactor Coolant System (RCS) is heated and pressurized to approximate normal operation conditions.

Normally certain Technical Specifications would have to be met to raise the RCS to these conditions of temperature and pressure.

However, because the fuel has been removed from the

core, we have concluded that for the purposes of this test, certai n limiting conditions of operation and surveillance requirements are not applicable to protect the health and safety of the public.

This conclusion will also be applicable to Turkey Point Unit 4 under the same steam generator repair condition.

We have attached our evaluation which cites the specific sections of the Technical Specifications that are affected.

Based on our review we have determined that it is not necessary to apply the sections of the Technical Specifications discussed in the attachments during the hot functional test.

Please be advised that it is our present intent to conduct the hot functional test on or about February 6, 1982, subject to the herein stated interpretations.

A listing of Technical Specification requi rements that may be waived for hot functional testing is added, and has been reviewed by the Turkey Point Plant Nuclear Safety Committee and the Florida Power and Light Company Nuclear Review Board.

Following the successful completion of this test, we will again resume our normal compliance with these Technical Specification requirements.

REU/PLP/cab Attachments 8202020343 820i27 PDR ADQCK 05000250

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-;PDR E. Uhrig Vice Pr esident Advanced Systems and Technology pn(

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PEOPLE... SERVING PEOPLE

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II

SAFETY EVALUATION

,Re:

Turkey Point Units 3 8 4 Docket No. 50-250, 50-251

,Hot Functional Testi n I.

Introduction This evaluation supports our Tech.

Spec. interpretation when the fuel has been removed from the core and for the purpose of performing a "Hot Functional Test".

This interpretation basically consists of expressing inapplicability of the "Limited Condition for Operation" and "Surveillance Requirements" of certain systems and/or components which are neither used nor needed when the reactor fuel has been removed.

II.

Evaluation (See Attached)

III.

Conclusion We have concluded, based on the considerations discussed above, that:

(1) this interpretation does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in safety margin, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed

manner, and (3) such activities will be conducted in compliance with the commission's regulations and the concurrence to this interpretation will not be inimical to the common defense and security or to the health and safety of the public.

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EVALUATION For the purpose of performing a Hot Functional Test (HFT) with the fuel removed from the core, the following interpretations of our Technical Speci:-f icati on wi 1 1

be made:

A.

LIMITING CONOITIONS FOR OPERATIONS 3.3 Conta i nment Since the fuel will be unloaded from the reactor core throughout tne course of the HFT, the requi rement to have containment integrity at other than cold shutdown conditions becomes unnecessary.

3.5 Instrumentation for the purpose of the HFT, the requirements to maintain the minimum instrumentation operation conditions as described in Tables 3.5-1 through 3.5-5 are not needed.

For this reason and under the conditions stipulated

above, TS 3.0. l,does not apply to Tables 3.5-1 through 3.5-5.

Also, the requirement to be in a condition with an average coolant temperature less than 350'F within 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> when outside the minimum channel operable requi rements of Table 3.5-5 is not applicable.

The surveillance requi rements associated with the i nstrumentation listed in Tables 3.5-1 through 3.5-5 are also not applicable, although it is our intent to maintain pertinent test parameter instrumentation operability (i.e., pressurizer

level, RCS

pressure, and RCS temperature).

B.

SURVEILLANCE REQUIREMENTS 4.1

~0 erational Saf~et review Tables 4.1-1 Items 17A and 17B and Table 4.1-2 Items 2, 4, 10 and 14 are not applicable and need not be performed prior to heatup above 200'F.

4.5 Safety Injection The system and component tests requirements prior to heatup above 200'F are considered not applicable for the purpose of performing a

HFT with the fuel unloaded from the core since SI is not needed under these conditions.

4.6 Emergenc~

Containment Cooling Systems Similarly to TS 4.5 above, the requirements to perform system and component test prior to heatup above 200'F do not apply.

TESTING FOLLOllING STEAM GENERATOR REPAIR For the purpose of conducting a hot functional test as required by the Steam Generator Repair Report, the Technical Specifications may be waived as follows:

A.

Limiting Conditions for O~erations 3.3.1.a.

Containment Integri'ot applicable with fuel removed from the core.

3.5 Instrumentation pertinent test parameter instrumentation will be maintained operable)

B.

Surveillance Requi.rements 4.1

~0 erational Safety Review Table 4. 1-1 (items 17A and 17B)

Table 4. 1-2 (items 2, 4, 10 and 14) 4.5 Safety Injection 4.6 Emergent Contai'nment Cooling Systems

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