ML17353A840
| ML17353A840 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/06/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17353A839 | List: |
| References | |
| NUDOCS 9608080141 | |
| Download: ML17353A840 (5) | |
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SAF UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001 A UATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 189 TO FACILITY OPERATING LICENSE NO.
DPR-31 AND AMENDMENT NO. 183 TO FACILITY OPERATING LICENSE NO.
DPR-41 FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNIT NOS.
3 AND 4 DOCKET NOS.
50-250 AND 50-251
- 1. 0 INTRODUCTION By letter dated April 18,
- 1996, and supplements dated May 10 and May 28,
- 1996, Florida Power and. Light (FPL or the licensee) proposed changes to the Technical Specification (TS) for Turkey Point Units 3 and 4.
The proposed changes would address, frequency extension for actions required on a periodic
- basis, delete the separate notification requirements for an inoperable startup transformer, and allow the operating Residual Heat Removal (RHR) loop to be removed from operation during refueling operations under certain conditions.
- 2. 0 DISCUSSION AND VALUATION
- 2. 1 Fre uenc Extension for Periodic Actions SR 4.0.2 permits a
25% extension of the interval specified in the Frequency.
This extension facilitates surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the surveillance (e.g., transient conditions or other ongoing surveillance or maintenance activities).
The existing TS did not specifically address allowing a
25% extension of the interval for surveillances required by action statements.
The licensee proposed to add the following statements to TS 4.0.2-Limiting Conditions for Operation and Surveillance Requirements:
k If an ACTION item requires periodic performance on a "once per..." basis, the above frequency extension applies to each performance after the initial performance.
Exceptions to this specification are stated in the individual Specifications.
The 25% extension does not significantly degrade the reliability that results from performing the surveillance at its specified frequency.
This is based on the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements (SRs).
960808014K 960806 PDR ADOCK 05000250 p
2.2 2
The proposed clarifications are acceptable since they incorporate staff understanding of the TS and make the TS more clear.
The staff stresses that the provisions of SR 4.0.2 are not intended to be used repeatedly, merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic completion time intervals beyond those specified.
The proposed changes are consistent with the standard TS.
There are cases where the 25X extension of the interval specified in the frequency does not apply.
These exceptions are stated in the individual specifications.
An example of where SR 4.0.2 does not apply is a
surveillance with a frequency of "in accordance with 10 CFR 50, Appendix J,
as modified by approved exemptions."
The requirements of regulations take precedence over the TS.
The TS cannot in and of themselves extend a test interval specified in the regulations:
Therefore, addition of the proposed wording identifying that there are exceptions to SR 4.0.2 in the TS is appropriate.
The staff position has been that the 25X extension does not apply to the initial portion of a periodic completion time that requires performance on a "once per..." basis.
The 25K extension applies to each performance after the initial performance.
The initial performance of, the required action, whether it is a particular surveillance or some other remedial action, is considered a single action with a single completion time.
One reason for not allowing the 25X extension to this completion time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.
Therefore, the proposed clarification to 4.0.2 identifying that the frequency extension applies to each performance after the initial performance is appropriate.
'f In summary, the proposed clarifications are acceptable since they incorporate staff understanding of the TS and make the TS more clear.
Notification Re uirements for an Ino erable Startu Transformer The licensee proposed to delete the requirement to notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of declaring a startup transformer inoperable.
r 10 CFR 50.72 and 50.73 adequately address the regulatory requirements for licensees to notify the NRC and report significant problems.
Therefore, this TS is 'unnecessary and the staff finds removal of this item acceptable.
In addition, the staff notes that this change is consistent with the standard TS, NUREG-1431.
2.3 RHR Re uirements Durin Refuel in 0 erations The licensee proposed to allow the required RHR loop to be removed from operation for up to I hour per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. period (while in Node 6, with water level at least 23 feet'bove the reactor vessel flange) provided
l" 1,
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4 no operations are permitted that would cause reduction of the Reactor Coolant Systems boron concentration.
The current TS only allows the temporary securing of RHR for core alterations.
Boron concentration reduction is prohibited because uniform concentration distribution cannot be ensured without forced circulation.
During this 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period with RHR secured, decay heat is removed by natural convection to the large mass of water in the refueling cavity.
The proposed change will allow temporary.suspension of RHR for activities such as core verification inspections.
The licensee stated that the previous requirement was initially foreseen to only affect core alterations near the reactor vessel hot leg nozzles that required the securing of RHR.
Since the analysis for temporary securing of RHR is independent of whether or not core alterations are being performed, this revision will clarify that activities other than core alterations can be performed while RHR is secured.
This change is acceptable since the RHR loop will remain available, decay heat will be removed by natural convection to the large mass of water in the refueling cavity, and uniform boron concentration will not be adversely affected by securing RHR flow for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.
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3.0 STATE CONSULTATION
Based upon the written notice of the pro'posed amendments, the Florida State official had no comments.
- 4. 0 ENVIRONMENTAL CONSIDERATION'hese amendments change a requirement with respect to installation or use of a facility component located within the restricted
- area, as defined in 10 CFR Part 20 and also change surveillance and administrative requirements.
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'adiation 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 (61 FR 34892).
Accordingly, these amendments meet the eligibility criteria for categorical exclu'sion 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.
- 5. 0 CONCLUSION The Commission has concluded, based on the considerations di'scussed
- 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.
Principle Contributor:
R. Croteau Date:
August 6, 1996
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