ML17353A395

Application for Amend to License DPR-31 & DPR-41,modifying Plant TS Tables 3.3-1 & 3.3-2 Action Statements for Rps/Nis/ Esfas,Tables 4.3-1 & 4.3-2 SR for Rps/Nis/Esfas & Bases 3/4.3.1 & 3/4.3.2 for Rps/Nis/Esfas Instrumentations

ML17353A395
Person / Time
Site:	Turkey Point
Issue date:	10/04/1995
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17353A396	List: ML17353A395 ML17353A397
References
L-95-248, NUDOCS 9510110184
Download: ML17353A395 (8)

Text

PRIORITY 1 .

(ACCELERATED RZDS PROCESSING)

I jf','EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9510110184 DOC.DATE: 95/10/04 NOTARIZED: NO DOCKET g FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 P 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power & Light Co.

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

SUBJECT:

Application for amend to license DPR-31 & DPR-4l,modifying plant TS Tables 3.3-1 & 3.3-2 action statements for RPS/NIS/

ESFAS,Tables 4.3-1 & 4.3-2 SR for RPS/NIS/ESFAS & Bases 3/4.3.1 & 3/4.3.2 for RPS/NIS/ESFAS instrumentations.

DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution

! ENCL L SIZE:

I NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 CROTEAU,R 1 1 INTERNAL: Ec-GENRE 01 1 1 NRR/DE/EMCB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 D

EXTERNAL: NOAC 1 1 NRC PDR 1 ~ 1 N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D8 (415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DONtT NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 12 ENCL 11

OCT041995 L-95-248 10 CFR 550.36 10 CFR 550.90 U. S. Nuclear Regulatory Commission 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 Amendments Surveillance Interval Extensions for Reactor Protection System (RPS), Engineered Safety Features Actuation System (ESFAS), and Nuclear Instrumentation S stem NIS By letter L-95-181 dated July 26, 1995, Florida Power and Light Company (FPL) requested that Appendix A of Facility Operating Licenses DPR-31 and DPR-41 be amended to modify the Turkey Point Units 3 and 4 Technical Specifications (TS) Tables 3.3-1 and 3.3-2 ACTION statements for RPS/NIS/ESFAS Instrumentation, Tables 4.3-1 and 4.3-2 SURVEZLLANCE REQUIREMENTS for RPS/NIS/ESFAS Instrumentation, and BASES 3/4.3.1 and 3/4.3.2 for RPS/NIS/ESFAS Instrumentation.

As requested during recent conversations with the Staff, attached is FPL's response to the questions developed as a result of the Staff's review.

Should there be any questions on this submittal, please contact us.

Very truly yours, T. F. Plunkett Vice President Turkey Point Plant OIH Attachment CC: S. D. Ebneter, Regional Administrator, Region II, USNRC T. P. Johnson, Senior Resident Inspector, USNRC, Turkey Point W. A. Passetti, Florida Department of Health and Rehabilitative Services

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ATTACHMENT 1 TO L-95-248 RESPONSE TO UESTZONS ON PROPOSED LICENSE AMENDMENTS SURVEILLANCE INTERVAL EXTENSIONS FOR REACTOR PROTECTZON SYSTEM ENGINEERED SAFETY FEATURES ACTUATZON SYSTEM AND NUCLEAR ZNSTRUMENTATZON SYSTEM NRC QUESTION 1:

Do the digital signals feed into a solid state protection for ESFAS action 14 be system? If8 so, should the bypass time allowed 4 hours vs hours? See 1989 SER page A-14 *.

FPL RESPONSE:

Turkey Point does not utilize a solid state protection system for RPS/ESFAS. Although certain input signals are from digital equipment (i.e., Eagle 21), all RPS/ESFAS logic and actuation signals utilize conventional relays. Therefore, an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> bypass time is appropriate for ESFAS ACTION 14.

NRC QUESTION 2:

Submittal states that digital equipment is used (Eagle 21) for OPDT, OTDT and Pressurizer water level. The digital system and the NI System have bypass capability. RPS and ESFAS Hagan analog equipment do not have bypass capability. The submittal does not state Line isolation and Feedwater isolation have a bypass capability nor if Steam does it specify if they are digital or analog, yet an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> bypass is specified by actions 20 and 22. This is not applicable if there is no bypass and should be 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if it is a solid state system.

FPL RESPONSE Both the Steam Line isolation and Feedwater isolation instrumentation utilize Hagan analog equipment (i.e., comparators), which do not have bypass capability, therefoxe, there is no bypass time specified in the applicable ACTION statements. Please note that ACTION statements 20 and 22 are associated with the automatic actuation logic and actuation relays pertaining to Steam Line Isolation and Feedwater Isolation which aze part of ESFAS. At Turkey Point, the ESFAS automatic actuation logic and actuation relays have bypass capability, therefore, (as in question 1), an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> bypass time is appropriate for ACTION statements 20 and 22.

NRC QUESTION 3:

Confirm the applicability of WCAP 10271 Supplement 2, Revision 1. The submittal only states WCAP 10271, Supplement 2. See cover letter 2/22/89 SER item 1 and 4/30/90 SSER cover letter items.

to L-95-248 Page 2 PPL RESPONSE:

WCAP 10271 Supplement 2, Revision 1, is the correct reference.

"Revision 1" was inadvertently omitted.

NRC QUESTION 4:

Provide justification for extension of the surveillance interval for items 17a, b, c and d of the RTS table from monthly to refueling.

Confirm that the setpoint drift extension from 7 days to 31 days for Note (1) of the RTS surveillance table is properly accounted for in the licensees setpoint calculation methodology.

FPL RESPONSE The existing Turkey Point. Technical Specifications do not require an analog channel operational test (at MODE 1) for Functional Unit, Item 17.a, Intermediate Range Neutron Flux interlock P-6. In addition, for the following functions, the monthly analog channel operational test (at MODES 1 and/or 2) consists of verifying .that the interlock is in the required state by observing the permissive annunciator window:

Functional Unit, Item 17.b, Low Power Reactor Trip Block Interlock P-7 (includes P-10 input and Turbine First Stage Pressure) .

2) Functional Unit, Item 17.c, Power Range Neutron Flux Interlock P-8.

3) Functional Unit, Item 17.d, Power Range Neutron Flux Interlock P-10.

The NRC's SER for RPS, as supplemented by the discussion contained in the NRC's letter to the Westinghouse Owner's Group (WOG) dated July 24, 1985, recognized the need to consider the special surveillance requirements for those channels which are only operational during transitional modes of operation. The NRC concluded that since a valid operational test can not be performed on the following channels at power, the appropriate test frequency requirement is on a refueling basis, during start-up:

1) Power Range, Neutron Flux (Low Setpoint)

2) Intermediate Range, Neutron Flux

3) Source Range, Neutron Flux The surveillance requirement change to "refueling" was incorporated into Revision 1 of the "WOG Guidelines for Preparing Submittals Requesting Revision of the RPS Technical Specifications, (which is included in WCAP-10271, Revision 0) . The generic analyses provided in the Westinghouse topical reports WCAP-10271 dated May 1986, and WCAP-10271, Supplement 2, Revision 1, dated May 1989, in addition to FPL's confirmation of the applicability of the generic analyses, provide the basis for the above changes.

Attachmerit 1 to L-95-248 Page 3 The setpoint drift extension is conservatively accounted for in the setpoint calculation methodology. The original Westinghouse setpoint calculation methodology assumed a conservative value for drift (one month duration). The expected NIS drift, based on as-found versus as-left surveillance data, was determined for a drift duration of 3 months (bounding condition). The expected NIS drift was verified to be enveloped by the drift assumed in the current Westinghouse methodology.

Please note that "Note 9" was inadvertently deleted for Functional Unit, Item 4 Source Range, Neutron Flux. The revised marked-up Technical Specification page 3/4 3-8 is enclosed.

NRC {}UESTZON 5:

The 1990 SER, page 3, approved certain changes that are being requested in the submittal. Why was the 1990 SER not referenced'he conditions of the 1990 SER have not been met.

PPL RESPONSE:

Although the 1990 SER was not referenced in the submittal, the technical conditions imposed by the Supplemental Safety Evaluation Report have been addressed in the submittal. The enclosed revised Insert A for proposed Technical Specification BASES page B 3/4 3-1 adds the 1990 SER to the list of applicable NRC SERs. FPL confirms the applicability of the generic analyses of WCAP-10271, Supplement 2, Revision 1, to Turkey Point Units 3 and 4.

FPL confirms that any increase in instrument drift due to the extended surveillance test intervals is properly accounted for in the setpoint calculation methodology as discussed in Attachment 1 to L-95-181, Section 3, "Compliance with NRC Imposed Technical Conditions," Item 5.