ML17347A265

Proposed Tech Specs Re Emergency Containment Filter Sys Surveillance Testing

ML17347A265
Person / Time
Site:	Turkey Point
Issue date:	02/04/1987
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17347A264	List: ML17347A263 ML17347A265
References
NUDOCS 8702120425
Download: ML17347A265 (9)

Text

ATTACHMENT I PROPOSED LICENSE AMENDMENT AMENDMENTNO.

FACILITY OPERATING LICENSE NO. DPR-3l DOCKET NO. 50-250 Revise Appendix A as follows:

~RP 4.7-I 4.7-2 Insert Pa es 4.7-I 4.7-2 S7Oii2'O425 87OZOO PDR'.,ADOCK 05000250 ll

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EMERGE lCY CONTAINMENT FILTER SYSTEM, POST ACCIDENT CONTAINMENT VENT

SYSTEM, AND CONTROL ROOM VENTILATION SYSTEM.

Applicabil ftg:

Applies to the Emergency Containment Filter Systan, the Post Accident Containment Vent System, and the Control Roan V ntilation System.

Qb ectives:

To verify that these systems and thei r components will be able to perform their design funct>ons.

In the event that painting, tire, or chemical release occurs such that tne filters are exposed to tn~

effluents of these

events, the systen will be teSted to verify its performance or design reatures.

Specification:

1.

EMERGENCY CONTAINMENT FILTER SYSTEM

/

1.

~0er~atin Tests System tests snal 1

be performed once per operating cycle or once per 1d months, wn>chevier ccmes rirst.

The tests snail consist of pressure drop and flow measurements across all filter banks in tne plenum.

Less tnan 6" of water pressure drop at design flow (37,500 ctm ~

10

) across the ccmbined HEPA filter and charcoal adsorbers shall constitute acceptaole performance.

Visual inspection snail include search for any foreign material and gasket deterioration of the HEPA filters and cnarcoal adsorbers.

The survei llence period may he extended for Unit 3 until the refueling outage for Cycle 11.

Amendments

Once per operating cycle, each unit ot'ne Emergency Containment Fi ltaring System s<<al I oe tested to aemonstrata automatic initiation upon receipt of a Safety Injection signal.

Eacn u>>it or the Emergency Contaianent Filtering Systen shal I

De operated monthly tor at l~ast 15 minutes on a staggered oasis to demonstrat~

operability.

2.

P rtormance T sts a.

A visual inspection snail be mad~ berore

~acn in-place air flow distribution test, OUP test or halogenated leak test.

At least onca per 18 months+or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> uf system operation, in-place OOP and nalogenated hydrOCarbun teStS at deSign rl OW (37,500 Ctm

+

ION) and carbon analysis for each Emergency Containment Filter plenum shall be pertormed.

In addition, carbon analysis and in-place

OOP, and halogenated hydrocarbOn teStS at design rlow (37,500 cfm + 10>>)

shal I be performed after (1) any structural maintenance on system hous ngs, which might have aftected rilter bank ef ici ency, (2) ar'ter complete or partial replacement of a filter bank, or (3) ar't~r operational exposure of the tilters to ~rriuents fran painting, tire, or chenical release.

Removal of

> 99",. OOP and

> 99>> halog~natad hydrocarbon shall constitute acceptable performance.

Fans shall op~rate at. design flow (37,5UO ci'm + IVX).

The charcoal surveillanc~

specimen tram one of the emergency containincnt filters shall snow

> 99.95 renoval erficiency for elemental iodine.

Samples will be takan in accordance with position C.6.b.ot Regulatory Guide 1.52.

Carbun analysis will be parrormad in accordance wi tn ANSI N5LU-1975.

Analysis shall v~rify the above removal erricency ror elemental iodine wi thin 45 days after ranoval ot ttie sample.

Failing tni s, the charcoal s<<aII be replaced wi tn charcoal which meets or excaeds the criteria ot'osition C.6.a of Regulatory Guide 1.52 (Revision 2).

b.

An air di StributiOn teSt Shall Oe.pertOrned at d sign tlow (37,500 ctm

+

10

) at least once arter maintenanca afracting r'low distribu ion.

c.

Flow rate should be verified tollowing maintanance to HEPA or charcoal nousing, or following painting or chemical release in its ventilation zone while the sgstani is operating, or once each 13 months.

• The surveillence period may be extended for Unit 3 until the i.efueling outage for Cycle 11.

4 7" 2, Amendments

ATTACHMENT 2 PROPOSED 'L'ICENSE'MENDMENT EMERGENCY CONTAINMENT FIL'TER SYSTEM SURVEILLANCE REQUIREMENTS Pur ose Descri tion and Basis For Emer enc The purpose of this amendment request is to extend the surveillance period in Technical Specification 4.7.I.I and 4.7.I.2.a until the upcoming refueling outage now scheduled to begin on March l5, l987. These specifications require operating and performance tests of the emergency containment filter system.

These tests were last performed for Unit 3 on April 4-5, l985.

This was during an extended outage on the unit which lasted until mid July l985.

There were also several unplanned outages during the cycle, which resulted in changes to the start date of the refueling outage.

The current IS month surveillance interval with the interval adjustment allowed by Technical Specification 4.0.l is not sufficient to allow performing the required tests during the refueling outage.

Due to the potential for significant neutron

dose, ALARA radiological considerations do not make performance of this test during power operations a

reasonable consideration.

FPL has reviewed the results of the previous tests of the system.

Charcoal absorber efficiencies for the three emergency containment filter units were as follows: 3A - 99.996%, 3B - 99.999%, 3C 99.999% (acceptance criteria is '>99.9%

removal efficency for elemental iodine).

The emergency containment filter units are operated monthly for the l5 minute operability test, and during ESF system testing to demonstrate automatic initiation upon receipt of a safety injection signal. Cumulative run times for each unit would be well below the 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> limit in the Technical Specifications.

Based on the review and the relatively brief extension period, we consider that the delay in the peformance of this test will not result in any safety concerns.

Further, we have reviewed a draft state-of-the-art radiological analysis regarding post LOCA iodine control for Turkey Point.

While this is not a final report, we are confident that the results regarding site boundary and low population zone show that a reduction in the filter efficiency or even total removal of the emergency containment filters would have minimal effect on the health and safety of the public.

FPL has reviewed IO CFR 50.9I(a)(5) regarding license applications involving emergency circumstances.

We are aware of the Commission's expectations for licensees to apply for license applications in a timely fashion.

In this case, because the shutdown of a nuclear power plant is involved, additional information is necessary to support the requested amendment.

As discussed above the situation occurred because the start of the refueling outage was delayed past the date required for the surveillance.

Action should have been taken by FPL in conjunction with these delays to request relief in a timely manner.

Although identified internally, a timely relief request was not submitted because of oversight which can be partially attributed to an abnormally high workload in the group responsible to take action. Although not timely, submittal of this request at this time does allow for the Commission to provide notice under IO CFR 9I(a)(5).

FPL did not delay this submittal in order to create tbe emergency, or to take advantage of tbe emergency amendment procedure.

As corrective action to address surveillance scheduling conflicts due to outage schedule

changes, the following action will be instituted.

A copy of the outage schedule letter prepared by FPL Fuels Department and Nuclear Energy will be sent to the Turkey Point Plant QC Department.

The scheduling of surveillances is TCG6/02 I /3

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addressed in Administrative Procedure OI90.16, Scheduling and Surveillance of Periodic Tests and Checks Required by Technical Specifications, and 0-OSP-200. I, Schedule of Plant Checks and Surveillances.

The QC Department, which is responsible for monitoring surveillance schedule dates, will notify the responsible department of the refueling date change.

The responsible department would then have ample time to prepare for the surveillance, or to request timely extension of the surveillance period.

On September 30, l986 FPL submitted a request to upgrade the Turkey Point Plant Technical Specifications.

The proposed surveillance period for testing the emergency containment filter system is once per each cycle to be performed during the refueling.

This surveillance period would preclude changes to the Technical Specifications due to a change in the outage schedule.

Basis for No Si nificant Hazards Consideration Determination The commission has provided standards for determining whether a significant hazards consideration exists (IO CFR 50.92(c)).

A proposed amendment to an operating license for the facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(I) 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.

Operation of Turkey Point Unit 3 in accordance with the proposed amendments would not:

(I) & (2)

Involve a significant increase in the probability or consequences of an accident previously evaluated, or create the possibility of a new or different kind of accident from any previously evaluated because this change does not involve a change in the operation or the physical design of the emergency containment filter system.

(3)

Involve a significant reduction in a margin of safety A one month deferral of the surveillance testing would not significantly increase the risk of unavailability of the system based on the long operating history of these components.

When the actual contribution to safety of the filters is considered in light of the recent draft analysis the reduction in the margin of safety associated with the delayed surveillance is negligible.

Based on the above discussion, 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, or create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.

Therefore, operation of the facility in accordance with the proposed amendment would pose no threat to the public health and safety, and would not involve a significant hazards consideration.

TCG6/02 I /4

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