ML17346A923
| ML17346A923 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/15/1985 |
| From: | Bemis P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Thompson H Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17346A922 | List: |
| References | |
| NUDOCS 8504020366 | |
| Download: ML17346A923 (4) | |
Text
s
~
i
\\
'1
>swi~
MEMORANDUM FOR:
FROM:
~
~ ~ ~
i
~
t4U< Lll n Rl. Gi>L/.i(>i.v c().'.'l.'.:s'Cii.
F;l C':>'. ll 10 i I.'<>.ll 1 1/ Ll (sj f 1. liJi S 11 Ati'TC.. Cil A~iGIj 503.:.
ViAf'
" I"'Bg Hugh L. Thompson, Director Division of Licensing Nuclear Reactor Regulation Paul R. Bemis, Director Division of Reactor Safety ZÃCMSURE l
SUBJECT:
TURKEY POINT LICENSE AMENDMENTS FOR SPENT FUEL POOL MODIFICATIONS License Amendments Nos.
111 and 105 to Turkey Point Operating Licenses Nos.
DPR-31 and DPR-41, respectively, were issued November 21,.1984.
These allowed the reracking of the spent fuel pool's.
However, the Senior Resident Inspector (SRI) has recently raised the following comments relating to Standard Technical Specification (STS) requirements:
Minimum Spent Fuel Pool (SFP) water level with irradiated fuel stored SFP ventilation'operability Oo Continuous radiation monitorino of SFP area with irradiated fuel stored The associated STS guidance would have required a minimum SFP water level of 23 feet above irradiated fuel (STS 3/4.9.11); continuous operation of the SFP ventilation system (STS 3/4.9.12) in addition to operation required during refueling by current Turkey Point Technical Specification (TS) 4.7.2; and continuous radiation monitoring of SFP area (STS 3/4.3.3)'n addition to monitoring required during refueling by TS 3.10.
In addition to the STS issues, several significant technical assumptions or analysis bases were discussed in the licensee's submitted Safety Analysis supporting the amendment
- request, the NRC Safety Evaluation Report, or the Environmental Assessment, but were not addressed in the TS or license amendment to assure continuing validity.
The most significant examples follow:
The licensee's Safety Analysis submitted March 14, 1984, assumes a
longer delay between shutdown and fuel off-load than the present TS requires.
The Safety Analysis assumes a 150-hour delay and present TS 3.10.9 requires only a 100-hour delay.
CONTACTS:
S. Elrod FTS 242-5536 r'e" g]ji G. Nejfelt FTS 242-3288 8504020366 850325 PDR ADOCK 05000250 P
4 I
Lh~ '1
The water level (25 feet} assumed in the licensee's Safety Analysis would overflow the spent fuel pool.
The Safety Evaluation Report issued with the amendment assumes a level of 23 feet.
In this case, NRR should confirm that the licensee's Safety Analysis actually used a
realistic water level.
The Safety Evaluation Report issued with the amendment assumed that a
specific surveillance program concerning the corrosion and performance of the poison material exists throughout the life of the racks.
This program is not addressed in the license or TS.
The licensee's Safety Analysis assumes a maximum spent fuel pool water temperature of approximately 140'F prior to core off-load.
The Safety Evaluation Report assumes that spent fuel pool temperature will not exceed 140'F during normal conditions during reload.
Neither the license nor TS requires the licensee to confirm an appropriate starting temperature prior to off-load.
This temperature should be specified.
Spent Fuel Pool heat exchanger temperature and flow, on both component cooling water and fuel pool sides, were assumed to be of certain valu~
in the licensee's Safety Analysis.
Current operational values are not known and flow does not appear to have been previously measured t con irm values used in the Safety Analysis.
The license does not f
0 require the licensee to confirm flow values used in the Safety Analysis.
The Environmental Assessment identified only a minor increase in radio-activity in the Spent Fuel Pool due to the capabilities of the Clean Up System.
With Spent Fuel Pool water level lowered eight feet during rerack, as allowed, the Clean Up System is not functional.
The Envir~nmental Assessment assumes that a Spent Fuel Pool leakage detection and collection system collects leakage and returns it to the waste system.
Neither the Unit 3 nor the Unit 4 leakage detection and collection systems are currently operational.
Both are severely degraded.
Neither the license nor TS requires this system to be functional.
It is our understanding that these amendments are to be the subject of upcoming hearings; therefore, we are formally bringing to the attention of NRR the con-cerns of the SRI at Turkey Point.
We request that these concerns be considered by NPR in preparation for those hearings.
These matters have been previously staff.
discussed with your Licensing Project Manager and cognizant members of yo rs o
your r
~
It is the position of Region II that Turkey Point's SFP TS should upgraded to the level of the 'current STS.
The issued amendments extended the use of SFP beyond the original design when the plant was licensed.
Therefore jt is appropriate that additional requirements be placed in the TS to en(urn that assumptions of the Safety Analysis are not exceeded.
Hugh L, Thompson h',',f
) t, )
~ ~;
Region II supports the concerns noted above by our SRI and requests that you reconsider the appropriateness of these issued amendments.
Inspection Reports 50-250184-35 and 50-25I/84-36 document these concerns and summarize the corre-spondence involved with the licensing action.
We request that you respond to us with an evaluation of these concerns prior to March 30, I985.
If you need further information, please contact us.
Paul R
Bem'