ML17353A343
| ML17353A343 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/24/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17353A342 | List: |
| References | |
| NUDOCS 9508300273 | |
| Download: ML17353A343 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SA TY A U T ON BY TH OFF IC OF NUC A
RE C
OR REGULATION RELATED TO AMEND NT NO.
176 TO ACI ITY OP RATING CENSE NO.
DPR-31 AND AMENDMENT N0.170 TO FACILITY OPERATING LICENSE NO.
DPR-41 LORIDA POWER AND LIGHT COMPANY TU K POINT U I NOS.
3 AND 4 DOCKET NOS. 50-250 AND 50-251
- 1. ~N By [[letter::L-95-137, Application for Amends to Licenses DPR-31 & DPR-41.Amends Would Use Changed Setpoint Presentation Format for RPS & ESFAS Instrumentation Setpoints|letter dated May 23, 1995]], Florida Power and Light Company (FPL or the licensee) proposed a change to the Technical Specifications (TS) for Turkey Point Units 3 and 4.
The changes requested involved modifying TS 2.2, "Limiting Safety System Settings, Reactor Protection System Instrumentation Setpoints" and Technical Specification 3/4.3.2, "Engineered Safety Features Actuation System Instrumentation Limiting Condition for Operation" and their associated bases.
The proposed change would use a revised setpoint presentation format for the Reactor Protection System (RPS) and Engineered Safety Features Actuation System (ESFAS) instrumentation setpoints contained in Technical Specification Tables 2.2-1 and 3.3-3 while retaining the approved Westinghouse five-column instrument setpoint methodology currently being used for establishing those setpoints.
The licensee stated that the intent of the amendments is to eliminate the need for minor administrative license amendments to these tables that do not impact either the Trip Setpoints or the Safety Analysis Limits.
Controlled plant drawings contain, and will continue to
- contain, the necessary information concerning the calculation of each setpoint using the previously approved setpoint methodology.
Changes to the "Z", "S" and "TA" terms contained in the controlled plant drawings can only be changed under the formal controls of TS 6.8.
The change would result in a relocation of this information from the TS to controlled plant drawings and procedures;
- however, the information already exists in these documents.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state TS to be included as part of the license.
The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36.
That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
However, the regulation does not specify the particul.ar requirements to be included in a plant's TS.
9508300273 9S0824 PDR ADQCK 05000250 PDR l gy I II
, The Commission has provided guidance for the contents of TS in its "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors"
("Final Policy Statement" ),
58 Fed.
Reg.
39132 (July 22, 1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies 5182a of the Act.
In particular, the Commission indicated that certain items could be relocated from the TS to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co.
(Trojan Nuclear Plant),
ALAB-531, 9 NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated that "technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whether a particular matter is required to be included in the TS, as follows:
(1) installed instrumentation that is used to detect, and indicate in the control
- room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process
- variable, design
- feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure,
- system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and (4) a structure,
- system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety As a result, existing TS requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
3.0 EVALUATION The proposed amendment is intended to limit the TS changes required due to changes in plant instrumentation.
The values for S, Z,
and TA will be removed from the TS along with Equation 2.2-1, (Z+R+S<TA).
The values for S, Z,
and TA will be controlled administratively by the licensee through drawings and procedures.
The licensee intends to maintain the Westinghouse instrument setpoint methodology that was previously used with the 5 column format.
Equation ZwR+S<TA will continue to provide the licensee with an optional method
'The Commission recently adopted amendments to 10 CFR 50.36, pursuant to which the rule was revised to codify and incorporate these criteria.
See Final
- Rule, "Technical Specifications,"
60 Fed.
Reg.
36953 (July 19, 1995).
The Commission indicated that reactor core isolation cooling, isolation condenser, residual heat removal, standby liquid control, and recirculation pump are to be included in the TS under Criterion 4,
although it recognized that other structures, systems and components could also'eet this criterion.
60 Fed.
Reg.
at 36956.
for operability determination.
The bases of the TS will be revised to reflect the proposed
- changes, but will continue to reference the Westinghouse 5 column setpoint methodology (WCAP-12725 and 12201) including equation Z+R+SgTA.
No changes to setpoints are included in the licensee amendment.
Based on the fact that the licensee will continue to use the approved Westinghouse methodology, the staff finds the proposed licensee amendment acceptable.
The staff notes that the 2 column format.is consistent with the format of the improved standard TS.
The control of the relocated information is via the requirements of TS 6.8.
TS 6.8. 1 requires that written procedures shall be established, implemented, and maintained covering the items recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 (RG 1.33).
RG 1.33, Appendix A, specifies procedures for surveillance tests and calibrations for the Emergency Core Cooling and Reactor Protection Systems.
TS 6.8.2 requires that changes to these procedures shall be reviewed and approved prior to implementation in accordance with a formal program described in TS 6.5.3, including a
determination of whether or not an unreviewed safety question is involved.
The staff finds these controls on the relocated items to be adequate.
In addition, the staff notes that the licensee stated in their submittal that any changes to the "Z", "S", and "TA" terms would only be made following a 10 CFR 50.59 evaluation to determine if prior NRC approval is necessary.
The TS Bases were modified from those submitted on Hay 23, 1995, in order to clarify that the existing Westinghouse methodology would continue to be used by the licensee.
This commitment was made in the submittal, but not specifically mentioned in the proposed Bases.
The licensee agreed to the revised Bases in a conversation on June 28, 1995.
4.0
~CNC UEIONE The staff reviewed the proposed changes and determined that the removal of these details do not eliminate the requirements for the licensee to ensure that the system, structure, or component is capable of performing its safety function.
Although this information is removed from the TS and incorporated into the administratively controlled documents, the licensee must continue to evaluate any plant modifications that affect any of these components in accordance with TS 6.8.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to commitments and to take any remedial action that may be appropriate.
Based on this review, the staff concluded that 10 CFR 50.36 does.not require this information to be retained in the TS.
Requirements related to oper ability, applicability, and surveillance requirements, including performance of testing to ensure operability, are retained due to their importance in mitigating the consequences of an accident.
However, the staff determined that the inclusion of this information is an operational detail related to the licensee's safety analysis, which are adequately controlled by the requirements of TS 6.8.
Therefore, the continued processing of license amendments related to revisions of the affected tables would afford no significant benefit with regard to protecting the public health and safety.
The staff has concluded, therefore, that removal of this information is acceptable because (1) inclusion in the TS is not specifically required by 10 CFR 50.36 or other regulations, (2) the information has been incorpo} ated into the administratively controlled document, and (3) changes are adequately controlled by TS 6.8.
The Commission has concluded, based on the considerations discussed
- above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
5.0 STATE CONSU TAT ON Based upon the written notice of the proposed amendments, the Florida State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
These amendments involve a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no publiC comment on such finding (60 FR 32364).
Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
Principal Contributors:
C. Doutt, R. Croteau Date:
August 24, 1995