ML17348B221
| ML17348B221 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/31/1991 |
| From: | Lainas G Office of Nuclear Reactor Regulation |
| To: | Goldberg J FLORIDA POWER & LIGHT CO. |
| References | |
| TAC-M81961, NUDOCS 9111190292 | |
| Download: ML17348B221 (7) | |
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Syyy4 Docket Nos.
50-250 and 50-251 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 October 31, 1991 Mr. J.
H. Goldberg President - Nuclear Division Florida Power and Light Company P.O.
Box 14000 Juno Beach, Florida 33408-0420
Dear Mr. Goldberg:
SUBJECT:
TURKEY POINT UNITS 3 AND 4 NRR - TEMPORARY WAIVER OF COMPLIANCE RELATED TO POWER RANGE NEUTRON FLUX CHANNEL SURVEILLANCE TESTING (TAC NOS. 81961 AND 81962)
By letter dated October 29, 1991, as revised October 30, 1991, you requested a Temporary Waiver of Compliance (TMC) from Technical Specification (TS) 3.2.1, "Axial Flux Difference" (AFD), to Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant, Units 3 and 4, respectively.
Specifically, your, request will allow operation with the AFD outside of the required target band of +5%, but within the acceptable operation limits at power levels between 50%
and 90 of rated thermal power (RTP) for a time period not to exceed 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for the purpose of performing incore/excore calibration of the nuclear instrumentation system detectors.
Action Statement (b) of TS 3.2-1 currently allows 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of operation outside the reference AFD target band but limits the power level for the incore/excore calibration to less than 50%
of RTP.
This directly conflicts with TS Table 4.3-1, "Reactor Trip System Instrumentation Surveillance Requirements,"
Item 2.a "Power Range, Neutron Flux
- High Setpoint Channel Calibration,".which references footnote (6) and states that the incore/excor e calibration must he performed above 75K of RTP, unless sustained operation is below that power level.
In your letters, you have stated that, following calibration of the excore detectors at lOOX power at Turkey Point Unit 3, you discovered this inconsistency in the surveillance requirements between differeI.. sections of Turkey Point's new standard TS and that Unit 3 was unable to concurrently satisfy the requirements of both TS 3.2.1 and TS 3.3.1.
The new standard TS were issued on August 28, 1990, and are now in effect with the restart of Unit 3 and Unit 4 following completion o~ the dual-unit outage.
Your letter also states that Turkey Point can perform this calibration above 75% power with the AFD maintained within the
+5% target band.
However, Westinghouse has recoIINIended in the NRC-approved WCAP K648-P-A, "Excore Detector Recalibration Using Vtii190292 9iioai
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Mr. J.
H. Goldberg quarter-Core Flux Maps" that the initial conditions for the encore/excore calibration procedure be established such that the AFD TS limits of Figure 3.2-1 (less about 1% margin on positive and negative limits) be available.
An adequate AFD must be induced in order to minimize excore detector uncertainties.
Calibrations performed within a narrow AFD span will result in a higher uncertainty at AFD extremes than calibrations performed with a wider AFD swing. It is important that the calibration be performed with as wide a span as possible.
This is necessary because the excore AFD uncertainty has a
direct impact on the overpower and overtemperature delta-T penalty function.
In addition, your letter also states that, following management review of this
- issue, you concluded that the level of uncertainty associated with the setpoints obtained through performance of the surveillance within the +5% AFD target hand was not consistent with prudent plant operation or proper engineering judgement.
Turkey Point Unit 4 was scheduled to begin power escalation above 50K on October 31, l99l and a prompt action was requested to ensure that Unit 4 would be able to acheive full power operation.
In your evaluation of the safety significance and potential consequences, and per your discussions with appropriate
- vendors, you have determined that the AFD is a measure of axial power distribution as measured by the excore power range channels.
AFD is sensitive to control bank position, core power level, and burnup.
Calorimetric uncertainties below 50%
RTP can reduce confidence ini'he incore/excore calibration, and to minimize extrapolation errors it is recommended that the data acquired for AFD calibration purposes be taken at power levels equal to or greater than 75~ PTP.
Bank insertion and a
controlled xenon oscillation are mechanisms used to produce the change in the axial power distribution.
To perform a controlled xenon oscillation for incore/excore calibration, sufficient time must be available and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> is viewed to be an adequate time interval to allow data retrieval and avoid potential TS constraints.
Operation of up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> outside the AFD target
'band, but within the acceptable operation limit, is analyzed during the normal reload desiqn process.
Based on NRC staff evaluation and discussions with your staff concerning this request, the NRC staff agrees that the proposed request was justified and issuance of this temporary waiver does not place the plant in a condition that compromises the health and safety of plant personnel or the general public and does not involve irreversible environmental consequences.
On October 30, 1991, the temporary waiver of compliance (TMC) was verbally granted to your staff.
Specifically, this waiver allows operation with the AFD outside the +5'arget band without occurring penalty deviation time, solely for the calibration of excore detectors, provided the AFD is within the acceptable operation limits of TS Figure 3.2-I.
This waiver accomplishes this by referencing footnote "0" of TS 3.2-1 in the APPLICABILITY statement of the TS rather than in the ACTION statement of TS 3.2.1.b.2.
In addition, this footnote is modified to include that the surveillance testing will be performed below 90% of RTP.
This
October 31, 1991 Mr. J.
H. Goldberg temporary waiver will be in effect while we complete processing of an exigent license amendment which your staff submitted on October 31, 1991.
A copy of the appropriate TS page is enclosed.
Sincerely,
Enclosure:
1.
TS Unit 3 and 4 page 3/4 2-1 cc w/enclosure:
See next page Distribution NRC It Local PDRs PDI I-2 RF TMur1ey/FMirg 1 ia J. Partlow S.
Varga G. Lainas D. Miller R. Auluck H. Berkow M. Boyle OGC D. Hagan, MNBB-3206 G. Hill, (8) PI-37 Wanda Jones, t1NBB-7103 C. Grimes, 13-H-15 ACRS (10)
GPA/PA OC/LFMB E. tlerschoff, RII J. Lieberman, 7-H-5 tl. Sinkule, RII Signed by Eileen McKenna for Gus Lainas Gus C. Lainas, Assistant Director for Region II Reactors Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation LA 2
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Hr. J.
H. Goldberg Florida Power and Light Company Turkey Point Plant CC:
Harold F. Reis, Esquire Newman and Holtzinger, P.C.
1615 L Street, N.W.
Mashingtor.,
DC 20036 Jack Shreve, Public Counsel Office of the Public Counsel c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee, Florida 32399-1400 John T. Butler, Esquire
- Steel, Hector and Davis 4000 Southeast Financsal Center Miami, Florida 33131-2398 Hr. Thomas F. Plunkett, Site.
Vice President Turkey Point Nuclear Plaht Florida Power and Light Company P.O.
Box 029100 Miami, Florida 33102 Joaeuin Avino County Manager of Hetropolitan Dade County 111 NW 1st Street, 29th Floor Miami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Generating Station L'.S. Nuclear Regulatory Commission Post Office Box 1448 Homestead, Florida 33090 Mr. Jacob Daniel Nash Office of Radiation Control Departmentof, Health and Rehabilitative Services 1317 Winewood Blvd.
Tallahassee, Florida 32399-0700 Hr. Robert G. Nave, Director Emergency Management Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Administrator
'epartment of Environmental Regul ation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tall ahassee, Florida 32301 Regional Administrator, Region II U.S. Nuclear Regulatory Coaeission 101 Marietta Street, N.W. Suite?900 Atlanta, Georgia 30323 Attorrey General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Plant Manager Turkey Point Nucl'ear Plant Florida Power and Light Company P.O.
Box 029100 Miami, Florida 33102 Hr. R. E. Grazio Director, Nuclear Licensing Florida Power and Light Company P.O. Box'4000 Juno Beach, Florida 33408-0420
3/4. 2 POWER DISTRIBUTION LIMITS 3/4. 2. 1 AXIAL FLUX DIFFERENCE LIMITING CONDITION FOR OPERATION 3.2. 1 The indicated AXIAL FLUX DIFFERENCE (AFD) shall be maintained within a l: 5X target band (flux difference units) about the target flux difference.
The indicated AFO may deviate outside the above required target band at greater than or equal to 50X but less than 90X of RATED THERMAL POWER provided the indi-cated AFO is within the Acceptable Operation Limits of Figure 3.2-1 and the cumu-lative penalty deviation time does not exceed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The indicated AFD may deviate outside the above required target band at greater than 15X but less than 50X of RATED THERMAL POWER provided the cumulative penalty deviation time does not exceed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
APPLICABILITY:
MODE 1, above 15X of RATED THERMAL POWER. " >
ACTION:
a 0 b.
C.
With the indicated AFD outside of the above required target band and with THERMAL POWER greater than or equal to 90X of RATED THERMAL POWER, within 15 minutes either:
1.
Restore the indicated AFD to within the target band limits, or 2.
Reduce THERMAL POWER to less than 9OX of RATED THERMAL POWER.
With the indicated AFO outside of the above required target band for more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of cumulative penalty deviation time during the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or outside the Acceptable Operation Limits of Figure 3. 2-1 and with THERMAL POWER less than 90X but equal to or greater than SOX of RATED THERMAL POWER:
1.
Reduce THERMAL POWER to less than 50X of RATED THERMAL POWER within 30 minutes, and 2.
Reduce the Power Range Neutron Flux"
- High Trip Setpoints to less than or equal to 55X of RATED THERMAL POWER. within the next
... 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
With'the indicated AFD outside of the above required target band for more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of cumulative penalty deviation time during the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and with THERMAL POWER less than 50X but greater "See Special Test Exceptions Specification 3.10.2; Surveillance testing of the Power Range Neutron Flux Channels may be performed (below 90K of RATED THER!'.At. POWER) pursuant to Specification 4.3,l.l provided the indicated AFO is maintained within the Acceptable Operation Limits of Figure 3.2-l.
A total of l6 hours operation may-be accumulated 'with the AFD outside of the above required target band during testing without penalty deviation.
TURKEY POINT - UNITS 3 4 4 AMENDMENT NOS.
AND EFFECTI'JE DATE:
October 3'3, 1991