Text

Application for Amends to Licenses DPR-31 & DPR-41,modifying Section 3.0 & 4.0 of Tech Specs Per Generic Ltr 87-09 Re Applicability of Limiting Conditions for Operation & Surveillance Requirements.Fee Paid
	ML17345A430
Person / Time
Site:	Turkey Point
Issue date:	09/27/1988
From:	Conway W; FLORIDA POWER & LIGHT CO.
To:	; NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML17345A431	List: ML17345A430; ML17345A432;
References
	GL-87-09, GL-87-9, L-88-389, NUDOCS 8810070066
	Download: ML17345A430 (15)
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AQCESSION NBR:8810070066 DOC.DATE: 88/09/27 NOTARIZED: YES DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250

,50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION CONWAY,W.F. Florida Power 6 Light Co.

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

SUBJECT:

Application for amends to Licenses DPR-31 a DPR-41,modifying Section 3.0 6 4.0 of Tech Specs per Generic Ltr 87-09.

/~ I DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR t ENCL / SIZE:

TITLE: OR Submittal: General Distribution D NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAMF LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 0 PD2-2 PD 5 5 h EDISONiG 1 -

1 INTERNAL: ARM/DAF/LFMB 1 0 NRR/DEST/ADS 7E 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/MTB 9H NRR/DOE~SB NU -C ll RACT 1

1 1

1 NRR/DEST/RSB 8E NRR/PMAS/ILRB12 OGC/HDS2 1

1 1

0 REG FILE Ol 1 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 qy03 S

h TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 19

0 c P OX 14000, JUNO BEACH, FL 33408.0420 SEPTEMBER p "/ $ 988 L-88-389 U. S. Nuclear Regulatory Commi'ssion kI Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendment Sections 3.0 and 4.0 on the Applicability of Limiting Conditions for 0 eration and Surveillance Re irements In accordance with 10 CFR 50.90, Florida Power & Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-31 and DPR-41 be amended to modify Sections 3.0 and 4.0 of the Turkey Point Units 3 and 4 Technical Specifications in accordance with the guidance provided by Generic Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications and the Applicability of Limiting Conditions for Operation and Surveillance Requirements."

FPL has determined that the proposed amendment does not, involve a significant hazards consideration pursuant to 10 CFR 50.92. A description of the amendment request and the basis for a no significant hazards determination is provided in Attachment 1. The proposed revised technical specification changes are shown on the pages included in Attachment 2.

In accordance with '10 CFR 50.91(b)(1), a copy of this proposed license amendment is being forwarded to the State Designee for the State of Florida.

In accordance with 10 CFR 170.12(c), FPL Check No. 9303 for

"$ 150 is attached.

88i0070066 880927 PDR ADOCK 05000250 P PNU g quod TCGALCO.PLA an FPL Group company

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U. S. Nuclear Regulatory Commission L-88-389 Page two The proposed amendment has been reviewed by the Turkey Point, Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board.

Should there be any questions on this request, please contact us ~

Very truly yours, W. F. Con y Senior Vice President Nuclear WFC/TCG/gp Attachments cc: Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector,,USNRC, Turkey Point Plant Mr. Jacob Daniel Nash, Florida Department of Health and Rehabilitative Services TCGALCO.PLA

STATE OF FLORIDA )

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COUNTY OF PALM BEACH )

W. F. Conwa being first duly sworn, deposes and says:

That he is Senior Vice President. Nuclear, of Florida Power and 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.

W. F. n ay Subscribed and sw rn to before me this

~day of NOTARY PUBLIC, in and fo the County of Palm Beach, State of Florida

~gg,~ public, State of btoctcta EXPireS June ~, 1.

My Commi. sion e>:pires g goSSSmSSSion

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ATTACHMENT I DESCRIPTION OF AMENDMENT REQUEST AND BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TCG4/024/3

PLA-062

'gURKEY POINT UNITS 3 AND 4 PROPOSED LICENSE AMENDMENT TITLE. Generic Letter 87-09, Sections 3.0 and 4.0 of Technical Specification DESCRIPTION:

This proposed amendment to the Turkey Point Technical Specifications (TS) modifies sections 3.0 and 4.0 in accordance with the guidance provided by NRC Generic Letter (GL) 87-09. The guidance provided in the GL, addresses three (3) specific problems that have been encountered with the general requirements on the applicability of Limiting Conditions for Operation (LCO) and Surveillance Requirements in Sections 3.0 and 4.0 of the TS. The first problem is unnecessary restrictions on mode changes (TS 3.0.4). The second problem is unnecessary shutdowns caused by inadvertent surpassing of surveillance intervals, and the third problem is conflicts in surveillance requirements related to mode changes. The TS are revised as follows!

Paape 3.0-1 TS 3.0.1 and 3.0.3 are reordered and renumbered to be consistent with the Westinghouse Standardized Technical Specification (Draft Revision 5) organization.

TS 3.0.4 has been revised as per GL 87-09. TS 3.0.4 states that entry into mode or other specified condition shall not be made unless the LCO is metan'perational without reliance on the provisions of the Action Requirements. Its intent is to ensure that a higher mode of operation is not entered when equipment is inoperable or when parameters exceed their specified limits. This precludes a plant startup when actions are being taken to satisfy an LCO, which if not completed within the time limits of the Action Requirements would result in a plant shutdown to comply with the Action Requirements.

TS 3.0.4 also precludes entering a mode or specified condition if an LCO is not met, even if the Action Requirements would permIt continued operation of the facility for an unlimited period of time. Generally, the individual specifications that have Action Requirements which allow continued operation note that TS 3.0.4 does not apply.

However, exceptions to TS 3.0.4 have not been consistently applied and their bases are not well documented.

Therefore, TS 3.0.4 is being revised to allow entry into an operational mode with equipment inoperable as long as the ACTION statement for the respective equipment continued plant operation for an unlimited perio'd of time.

'llows Pa es 3.4-2 3.4-3 3.4-4 3.4-5 3.4-6 3.4-7 3.5-1 3.6-2 3.7-2 and 3.8-1 These pages are being revised to delete the statement that TS 3.0.1 applies. It is implicit in TS that if you have no ACTION statement, the shutdown TS applies (new 3.0.3). In addition, Specification 3.4.3, Emergency Containment Filters, Specification 3.4.6, Post Accident Containment Vent System, and Specification 3.4.7, Control Room Ventilation, are being modified to add MODES of applicability and ACTION statements in accordance with the guidance provided in the Westinghouse Standardized Technical Specifications (Draft Revision 5). These changes provide additional guidance and controls to facilitate use of these specifications.

"C PLA-062 TURKEY POINT UNITS 3 AND 4 PROPOSED LICENSE AMENDMENT

~Pa e 3.6-3 footnote for allowance oi'nly two operable boric acid transfer pumps is no

'he longer applicable, therefore it is being deleted.

PaaPe4. 0-1 Current TS 4.0.1 and 4.0.2 are being deleted and replaced by STS Sections 4.0.1, 4.0.2, 4.0.3 and 4.0.4. Current TS 4.0.3 is being renumbered to be TS 4.0.5.

The new TS 4.0.1 establishes the requirement that surveillances must be performed during the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirement. The purpose of this specification is to ensure that surveillances are performed to verify the operational status of systems and components and that parameters are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions for Operation are applicable.

The new TS 4.0.2 is similar to the previous TS 4.0.1 in that it establishes the conditions under which the specified time interval for surveillance requirements may be extended. One additional change is that there is a limit on the use of an extended surveillance interval. This is the 3.25 rule, or the combined time interval for any 3 consecutive surveillance intervals shall- not exceed 3.25 times the specified surveillance interval.

TS 4.0.3 establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specificatigon 4.0.2, as a condition that constitutes a failure to met the OPERABILITY requirements for a Limiting Condition for Operation.

Therefore, the affected equipment would be declared inoperable and the appropriate ACTION statements entered at the time the missed surveillance was discovered and not at the time that the allowed surveillance interval was exceeded. This TS has been modified to allow a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period to permit the completion of the surveillance before requiring the ACTION requirements of the LCO to be invoked when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the shutdown TS 3.0.3 is invoked.

However, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . extension is NOT to be construed that not performing a surveillance within its required interval is not a condition prohibited by TS. The failure to perform a surveillance within the allowable surveillance interval defined by TS 4.0.2 constitutes a reportable event under 10 CPR 50.73 (a)(2)(i)(b) because it is a condition prohibited by the plant's TS.

The new TS 4.0.4 prohibits entry into an operational mode or other specified condition when surveillance requirements have not been performed within the specified surveillance interval. A conflict with this requirement exists when a mode change is required as a consequence of ACTION requirements and when the surveillance requirements that became applicable have not been performed within the specified surveillance interval.

PLA-062 TURKEY POINT UNITS 3 AND 4 PROPOSED LICENSE AMENDMENT A second conflict could arise because, when Surveillance Requirements can only be completed after entry into a mode or specified condition for which the Surveillance Requirements apply, an exception to the requirements of Specification, 4.0.4 is allowed. 'owever, upon entry into this mode or condition, the requirements of Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowed surveillance interval. Therefore, along with the modification of Spec'ification 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the applicability of Action Requirements, Specification 4.0.4 has been clarified to allow passage through or to operational modes as required to comply with Action Requirements.

TS Section 4.0.5 is the same as the previous TS 4.0.3 with minor changes to reflect the new numbering of TS Section 4.0. TS 4.0.5 does not address inservice testing because the TS amendment for inservice testing has not been submitted to the NRC.

The inservice inspection revision to the TS.was amendments 119 and 113.

P es 4.2-1 4.4-3 4.12-1 B4.2-1 These pages were revised to reflect the new numbering of TS Section 4.0.

P es B3.0-1 thru B3.0-4 These pages were revised to reflect the updated bases sections for 3.0.1, 3.0.2, 3.0.3, and 3.0.4 as delineated in GL 87-09.

P es B4.0-1 thru B4.0-3 These pages were revised to reflect the updated bases sections for 4.0.1, 4.0.2, 4.0.3 and 4.0.4 as delineated in GL 87-09.

The current TS bases section for 4.0.3 has been renumbered to read 4.0.5.

BASIS FOR SIGNIFICANT HAZARDS CONSIDRRATION DRTRRMINATIONs The standards used to arrive at a proposed determination that the changes described above involve no significant hazards consideration are included in 10 CPR 50.92. The regulations state that if operation of the facility in accordance with the proposed amendment could 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, then a no significant hazards determination can be made.

Operation of Turkey Point Units 3 and 4 in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

For the changes intended to achieve consistency with the recommendations of Generic Letter 87-09 "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," the Staff has previously evaluated these changes in the generic letter and determined that the modifications will result in improved technical specifications.

Specification 3.0.4 unduly restricts facility operation when conformance to the ACTION requirements provides an acceptable level of safety for continued operation. For an LCO that has ACTION requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those ACTION requirements. This is consistent with the NRC's regulatory requirements for an LCO.

It is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed. A 24-hour time limit has been included in Specification 4.0.3 allowing a delay of the required actions to permit the performance of the missed surveillance. The NRC has concluded that the 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with ACTION requirements before the surveillance can be completed.

The NRC has concluded that the potential for a plant upset and challenge to safety systems is heightened if surveillances are performed during a shutdown to comply with ACTION requirements. Specification 4.0.4 has been modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with ACTION requirements.

For the changes intended to achieve consistency with the Westinghouse - Standard Technical Specifications (WSTS), Draft Revision 5, the intent of the Specifications will not be changed nor will operating limitations of the Technical Specifications be changed.

Therefore, the proposed changes will not significantly affect the probability or consequences of accidents previously analyzed.

BASIS FOR SIGNIFICA HAZARDS CONSIDERATION DET INATION: Continued (2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

The changes being proposed by FPL to achieve consistency with Generic Letter 8V-09 and the WSTS will not lead to material procedure changes or to physical modifications. Therefore, the proposed changes do not create the possibility of a new or different kind of accident.

(3) Involve a significant reduction in a margin of safety.

For the changes intended to achieve consistency with. the recommendations of Generic Letter 87-09 "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," the Staff has previously evaluated these changes in the generic letter and determined that the modifications will result in improved technical specifications.

Specification 3.0.4 unduly restricts facility operation when conformance to the ACTION requirements provides an acceptable level of safety for continued operation. For an LCO that has ACTION requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should- be permitted in accordance with those ACTION requirements. This is consistent with the NRC's regulatory requirements for an LCO.

It is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed. A 24-hour time limit has been included in Specification 4.0.3 allowing a delay of the required actions to permit the performance of the missed surveillance. The NRC has concluded that the 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with ACTION requirements before the surveillance can be completed.

l The NRC has concluded that the potential of a plant upset and challenge to safety systems is heightened if surveillances are performed during a shutdown to comply

'with ACTION requirements. Specification 4.0.4 has been modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with ACTION requirements.

For the changes intended to achieve consistency with the Westinghouse - Standard Technical Specifications (WSTS), Draft Revision 5, the intent of the Specifications will not be changed nor will operating limitations of the Technical Specifications be changed.

Therefore, use of the modified specification would not involve a significant reduction in the margin of safety.

Based on the above, we have determined that the amendment request does 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; and therefore does not involve a significant hazards consideration.

ATTACHMENT 2 PROPOSED REVISED TECHNICAL SPECIFICATION PAGES TCG4/024/7

ML17345A430

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SUBJECT:

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