ML18227B251

06/09/1977 Letter Proposed Amendment to Appendix a of Facility Operating Licenses, Concerning Air Filtration Systems

ML18227B251
Person / Time
Site:	Turkey Point
Issue date:	06/09/1977
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
Download: ML18227B251 (32)

Text

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t NRC FoRti 395>> U.S. NUCLEAR RFGULATORY COMI I )N DOCXET I2 7SI

'RC DISTRIBUTION FoR PART 60 DOCKET MATERIAL FILE NUMB TO: FROM: DATE OF DOCUMLNT Florida Power & Light Company 6/9/77 M"~ Victor Stello Miami, F1 a>> DATE'RECEIVE D Robert E Uhri 6/15/77 WLETTER 0 N O TO R IZ E D PROP INPUT FORM NUMBER OF COPIES RECEIVED C3ORIGINAL QCJ N C LASS IF I E D QiCOP Y DESCRIPTION ENCLOSU RE Amdt>> to OL/change to Appendix A tech specs>>>>>>notorized 6/10/77 ~ concerns the air filtration systems ~ ~ ~ ~

ACKNOV/LEDGERS DO NOX 3Zi>iOVZ (2>>P) (10-P)

PLANT NAME: Turkey Point Units 3 & 4 R JL 6/17/77 FOR ACTION/INFORMATION ENVIRHNhIENTAL XBS~' ASSIGNED AD: V, MOORE LTR

~ w BRANCH CHIEF ECT MANAGER: PROJECT hlANAGER:

I ENSING ASSISTANT: LICENSING ASSISTANT:

8>> .HARLESS INTERNAL D ISTRI BUTION SYSTFMS SAFETY PLANT SYSTEMS. SITE SAFETY &

HEINEMAN TEDESCO ENVIRON ANALYSIS 1R EDER 'BENAROYA DENTON & hIULLER ENGINEERING IPPOLITO ENVIRO TECH ERNST OPERATING REACTORS BALLARD NGBLOOD

'A QZ BUTLER GAhIIALL 2 0 /TOCZY GRIMER CHECK SITE ANALYSIS VOLLlIER AT I BUNCH AI TZK4% J>> COLLINS ITBFRG KREGER EXTERNAL DISTRIBUTION CONTROL NUMBER p>> ~ygy/

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O. BOX 0'l3100, MIAMI, FL 33101

+ llr FLORIDA POWER & LIGHT COMPANY June 9, 1977 L-77-174 AegUtatolg Docket Fffe Director of Nucl'ear Reactor Regulation Attention'. i~Ir. Victor Stello, Director Division of Operating Reactors U. S.,Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Stello:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed, Amendment to Facility 0 eratin Licenses DPR-31 and DPR-41 In accordance with 10 CFR 50.30,. Florida Power & Light Company submits herewith three (3) signed. originals and forty (40) copies of a request to amend: Appendix A of Facility Operating Licenses DPR-31 and DPR-41.

In response to telephone requests from members of your staff, we, have revised our proposal of May 3, 1976 on the subject of air fil'tration, systems,. The present proposal conforms as near as possible to the Standard Technical Specifications without our having to make hardware modifications. The proposed.

changes are described below and shown on the accompanying Technical Specification pages bearing the date of this letter in the lower right hand corner.

Pa es: 'i. and iii:

l I.

Table of Contents.

I'evised Pa e 3.4-4 Specification 3.4.3.b is revised. This specification concerns the limiting conditions for operation applicable

-to the Emergency Containment Fi.'ltering System during power operation.

Pa e 3.13-1 New specification 3.13 is added. This specification concerns the limiting conditions for operation applicable to the Control Room. Ventilation System and the Post Accident Containment Vent System.

'7'7i li000 PEOPLF... SERVING PEOPLE

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Director of Nuclear Reactor Regulation Page Two Pa es 4.7-1 through 4.7-3 The surveillance requirements of specifications 4.7..1 (Emergency Containment Filtering System) and 4.7.2 (Post Accident Containment Vent System) are revised. A new specification 4.7.3 (Control Room Ventilation System) is added.

Pa e B3.13-1 A new section B3.13-1 is added to provide bases for new specification 3.13.

Pa e B4.7-1 The bases for specification 4.7 are revised to include the Control Room Ventilation System.

The proposed amendment has been reviewed by the Turkey Point Plant Nuclear Safety Committee and the Florida Power & Light Company Nuclear Review Board and the conclusion reached that involve an unreviewed safety question.

it does not Very truly yours, Robert E. Uhrig E,

Vice President REU/MAS/cpc Attachment cc: Mr. Norman C. Moseley, Region lZ Robert Lowenstein, Esquire

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TJE OF CONTENTS (continued) '

Section Title ~?a- e 3.7 Electrical Systems 3. 7-1 3.8 Steam and Power Conversion Systems 3.'8-1 3.q Radioactive Materials Release 3. 9-1 Liquid 4astes 3.9-1 Gaseous Pastes 3. 9-2 Containerized Vastes 3. 9-3

3. 10 Refueling 3.10-1 3.11 Miscellaneous Radioactive Materials Sources 3.11-1 3.12 Cask Handling 3.12-1 3.13 Air Treatment Sysyems 3e13-1 tern 4

4.1 SURVEILLA iCE'EQUIREMENTS 4. l-l Operational Safety Review 4.1-1 4e2 Reactor Coolant System In Service Inspection 4.2-1 4.3 Re ac tor Coolant Sys Int egri ty 4.4 Contair ent Tests 4.4-1 Integrated Leakage Rate Test Post Operational 4.4-1 Lo"al Penetration Tests 4'. 4-1 Report of Test Results 4 Isolation Valves 4. 4-3 Residual Heat Removal System 4, 4-3 Tendon Surveillance 4.4-4 End Anchorage Concrete Surveillance 4.4-6 Liner Surveillance 4.4-7 4.5 Safety Injection 4.5-1 4.6 Emergency Containment Cooling Systems 4.6-1 4.7 Emergency Containment Filtering, Post Accident Containment Vent, and Control Room Ventilation Systems 4. 7-1 4e8 Emergency Power System Periodic Tests 4.8-1 4.9 Hain Steam Isolation Valves 4.9-1

4. 10 -

Auxiliary Feedwater System 4.10-1

4. 11 Reactivity Anomalies 4.3.1-1 4.12 -Environmental Radiation Survey 4. 12-1 13 Radioactive ~mterials Sources Suneillance 4.13-1 5 DESIGN FEATL~~S 5. 1-1 5.1 Site 5. 1-1 5 Reactor 5. 2-1 5.3 Containment 5. 3-1 5.4 Fuel Storage 5.4-1 6 PZ'MIF STFXTIVE COEEIROLS 6. 1-1 6.1 Responsibility 6-1 6.2 Or..an'zation . 6-1 6.3  :-a=il- ty Staff Qualifications 6-5 6.4 J T t'> 6-5 6.5 R= -'e'- "nd Audit 6-5 6.6 .-.a"."rtable Occurrence Action 6-14 5.7 5 a== tp. L imit Viola t ion 6-14 6.8 -.o=edures 6-14 6.9 P. -ort-ng Requirements 6-16 6/10/77

i~~~r. vr <UNTENXS (continued)

Saceion ~- ~Pa e 6-10 Record 6-27 6-11 Retention'Radiation Protection Program 6-29 Respiratori.; rotection Program 6-29 i- l3 High Radiatio" Ar a 6-33 B2;l Bases for Safety Limit, Reactor Core B2. 1-1 B2.2 Bases for Safety Limit, Reactor Coolant System Pressure B2. 2-3.

B2.3 Bases for Limiting Safety System Settings, Protective Instrumentation B2'-1 B3.1 Bases for Limiting Conditions for Operation, Reactor Coolant System B3 E-l B3.2 Bases for Limiting Conditions for Operation, Con-Rock and,Power Distribution Limits 'rol B3.2-1 B3.3 Bases fo" Limiting Conditions for Operation, Contai. ent a B3.3'-E B3.4 Bases for Limiting Conditions for Operation, Engineered Safety Peatures B3.4-1 B3.5 Bases fo" Limiting Conditions for Operation Ins tz J~~entation B3.5-1 B3.6 Bas es for LiUting Conditions for Operation

. Chancel and Volume Control System B3.6-1 B3.7 Bases or Limiting Condition for Operation, Electrical Systems B3 7-l B3. Bases for L:m ting Conditions for Operation, 8'3.9 Steam and Power Conversion Systems B3 S-E Bases for Limiting Conditions for Operation, Radioactive'Materia3.s Release B3.9-1 B3.10 Bases for Limiting Conditions for Operation, Refueling B3.10-1.

B3.11 Bas s for Limiting Conditions for Operation, ~

B3. 11-1 Hiscellaneous Radioactive Haterials Sources B3.12 Bases for Limiting Conditions for Operation, B3. 12-'1 Cask H,andling B3.13 Bases for Limiting Conditions for Operation, Air Treatment Systems B3.13-1 B4.1 Bas s for Operational Safety Review B4 1-1 B4 2 Bases for Reactor Coolant System In Service Inspection B4.2-1 B4' 3 Bases for R actor Coolant System Integtity B4. 3-l.

Bases for Containment Tests B4.4-1 B'.5 Bases for Safety Injection Tests B4 ~ 5-1.

B4.6 "ases for Emergency Containment Coolin g S ys t em Tests B4.6-1 B4.7 Bases for Emergency Containment Filtering, Post Accident Containment Vent, and Control Room Ventilation Systems Tests B4-7-1 r Emergency Power System Periodic Test B4.S-1 9  :-=..:-=s fo" .kain Steam Isolation Valve Tests B4.9-1 B4.10 for Auxiliary Feedwater System Tests 'B4.10-Z.

B4.ll -.or Reactivity Anomalies B4.11-1 B4.l.2 ==-:=s =or Environmental Radiation Survey B4 12-1 6/10/77

41

l. ONE emergency containment cooling unit may be. out of service.

for a period of 24. hours. Prior to initiating maintenance, the other TWO units shall be tested to demonstrate operability.

2. ONE containment spray pump, may be out of service provided it is restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The remaining containment spray pump shall be tested to demonstrate operability before initiating maintenance on the inoperable pump.

3. Any valve in the system may be inoperable provided repairs are completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Prior to initiating repairs, a11 valves that provide the duplicate function shall be tested to demonstrate operability.

3. EMERGENCY CONTAINaiNT FILTERING SYSTEM During, times when containment integrity is required:

a. The three Emergency Containment Filtering Units shall be operable at all times or the reactor shall be placed in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, with the following exception:

1) If one of the three emergency containment filtering trains is made or found to be inoperable for any reason, reactor operation is permissable only during the succeeding seven (7) days provided that all active components of the other two trains shall be demonstrated to be operable within two hours and daily thereafter.

b. Any valve in the system may be inoperable provided repairs are completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> except, as stated in 3.a.l above. Prior to initiating maintenance, all valves that provide the duplicate function shall be tested to demonstrate operability..

4. COMPONENT COOLING SYSTEM

a. The reactor shall not be made critical, except for low power physics tests, unless the following conditions are met.

3.4-4 6/10/7 7

3. 13 AIR TREATMENT SYSTEMS Ventilation System and the Post Accident Containment Vent.

System.

To define those limiting conditions for operation that are necessary:

1. To remove airborne activity from, the control room if detected.

2. To reduce containment hydrogen concentration and to reduce containment pressure during post-accident conditions.

S ecification: 1. CONTROL ROOM VENTILATION SYSTEM

a. The Control Room Ventilation (Emergency Internal Cleanup) System may be inoperable for a period of up to seven days. If the system cannot be made operable within seven days, both reactors shall be shut down.

2. POST ACCIDENT CONTAINMENT. VENT SYSTEM

a. The Post Accident Containment Vent'ystem may be inoperable for a period up to thirty days. If the system cannot be made operable within 30 days, both reactors shall be shutdown.

3el31 6/10/77

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~ 7 ~EPCEklCY CONTADMELZ FXLTER. SYSTEM, POST ACCXDELiT COVTAD~~L'iT VE.iT SYST~

AND CONTROL ROO~ii VENTXLATXOH,SYSTEf.

Applies to the Emergency Containment P'ilter '

System, the Post Accident Contaf ament Vent .System, the Control Poom Ventilation System.

To verify that these 'systems and their components Mill be able to perform. their desf.gn functions.

'n the event, that painting, fire, or chemical re1ease occurs such that the filters are exposed to 'th'e effluents oZ these

( .events,. the.~stem will.be..tested to verify, $ .ts performance

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of design features~

4.7.1 ~C:~ICY CONTAIN.fcNT PXLTERXFC SYST~

'l. O"era na Tests System tests shall be performed once per operatfng cy'cle or once per 18 months, whichever comes first.

The tests shall consist of pressure drop and'flow ueasureme ts across all filters in the plenum. Less than 6" of water pressure drop at design flow (+. 10%)

across the combined HEPA. filters and charcoal adsorbers shall.. cons-itute acceptable performance.

Once per operatf.ng cycle, the Emergency Containment Zi3.teria System shall be tested to demonstrate automatic initfation upon receipt of a safety injectfoa signal.

Tre- .-ex,geacy Containment Zilterino System shall be '

cpera ed monthly for at least 15 minutes to demonstrate c"erability.

4.7-1 6/10/77

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2. Performance Tests

a. At least once per 18 months or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, in-place DOP and halogenated hydrocarbon tests on each Emergency Containment Filter plenum shall be performed.

In addition, in-place DOP and halogenated hydrocarbon tests shall be performed after (1) any structural maintenance on system housings, (2) after any testing which might have affected filter bank efficiency, (3) after complete or partial replacement of a filter bank, or (4) after exposure of the filters to effluents from painting, fire, or chemical release. Removal of >99% DOP and >99% halogenated hydro-carbon shall constitute acceptable performance. Once per operating cycle, a charcoal surveillance specimen from one of the emergency containment filters shall be analyzed, for elemental iodine removal capability. The resul'ts of the laboratory carbon sample analysis shall show >99.9% removal efficiency. 'Failing this, the charcoal shall be replaced with charcoal which meets or exceeds original specifications.

b. An air distribution test shall be performed at least once, and thereafter only distribution if there is indication that the air has changed.

4.7.2 POST ACCIDENT CONTAINMENT VENT SYSTEM

l. 0 eratin Tests Operating tests shall be performed annually. The tests shall consist of visual inspection of the .system, operation of all valves, and pressure drop and air flow measurements. Visual inspection shall include search for any foreign materials and gasket deterioration in the HEPA filters and charcoal adsorbers.

Less than 6" of water pressure drop at 55 cfm flow shall con-stitute acceptable performance.

1

2. Performance Tests At least once per 18 months or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, in-place DOP and halogenated hydrocarbon tests on the Post Accident Containment Vent filters shall be performed. In addition, in-place DOP and halogenated hydrocarbon tests shall be performed after (1) any structural. maintenance on system housings, (2) after any testing which might have affected filter bank efficiency, (3) after complete or partial-replacement of a filter bank, or (4) after exposure of the filters to effluents from painting, fire or chemical release. Removal of >99%'OP and >99% halogenated hydrocarbon shall constitute acceptable performance.

The hydrogen concentration measurement instrument shall be calibrated with proper consideration for humidity.

4.7-2 6/10/77

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4. 7. 3 CONTROL ROOM VENTILATION EMERGENCY INTERNAL CLEARNUP) SYSTEM

l. 0 eratin Tests The Control Room Ventilation System shall be operated monthly for at least 15 minutes to demonstrate operability. Auto initiation of the systems operations shall be checked annually.

Pressure drop measurements across the filter bank shall be made annually. Less than 6" of water pressure drop at designed flow

(+10%) .across the combined HEPA filter and. charcoal adsorbers shall constitute acceptable performance.

2. Performance Tests At least once per 18'onths or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, in-place DOP and halogenated 'hydrocarbon tests on the filters shall be performed. In addition,. in-place DOP and halogenated hydrocarbon'ests shall be performed after (1) any structural maintenance on system housings, (2) after any testing which might have affected filter bank efficiency, (3) after complete or partial replacement of a filter bank, or (4) after exposure of the filters to effluents from painting, fire, or chemical release.

Removal of >99% DOP and >99% halogenated hydrocarbon shall con-stitute acceptable performance.

A charcoal surveillance specimen from one of the charcoal adsorbers shall be removed- and analyzed annually for methyl iodide removal capability., The results of,.the laboratory carbon sample analysis shall show >85% removal efficiency with >95%

relative humidity -and >130'C. Failing this, the charcoal shall be replaced with charcoal which meets or exceeds original speci-fications.

4.-7-3 6/10/77.

Oi 0 B3.13 BASES FOR LIMITING CONDITIONS FOR OPERATION~ AIR TREATMENT SYSTEMS The Control Room Ventilation (Emergency Internal Cleanup) System is designed to partially filter the Control Room atmosphere for recirculation during Control Room isolation, conditions. If the system is inoperable, there is no immediate 'threat to the Control Room and reactor operation may continue for a limited time while repairs are being made. If the system cannot be repaired within seven days, both reactors are shutdown in accordance with 10 CFR 50.36(c).

The Post Accident Containment Vent System is designed to facilitate controlled venting of either containment through HEPA and charcoal filters to reduce combustible gas concentration following a loss of coolant accident. If the system is inoperable, there is no significant threat caused by continued reactor operation because the system would only be used seven to ten days after an accident.

Reactor operation may, therefore, continue for up to thirty days while repairs are being made. If the system cannot be repaired in that time, both reactors are shutdown in accordance with 10 CFR 50.36(c).

33.13-1 6/10/77

~I BASES. FOR EMERGEN~ONTAINMENT FILTERING SYSTEM, ~T'CCIDENT CONTAIb~iiEVaZ VENT SYSTEM, CONTR~ROOM VENTILATION SYSTEM.

System components are not subject to rapid'eterioration, having lifetimes of many years, even under"continuous flow conditions. Visual inspection and operating tests provide assurance of system reliability and will insure early detection of conditions which could cause the system to fail or operate improperly. ,The .performance tests prove conclusively that filters have been properly installed, that no deterioration or damage has occurred, and that all components and subsystems operate properly.

The tests are performed in accordance with the methodology and intent of.

ANSI 410, 1975, and provide assurance that filter performance has not deteriorated below original speci'fication values due to aging, contamina-tion, or other -effects.

B4.7-1 6/>Ogre

4> i STATE OF FLORIDA '

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COUNTY OF DADE )

Robert E. Uhrig, being first duly sworn,. deposes and says:

That he is a Vice President of Florida Power 5 Light Company, the Licensee herein; That. he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best of his knowledge, information, and. belief, and that he is authorized to execute the document, on behalf of said Licensee.

Robert E. Uhrig Subscribed and sworn to before me this

/0 day of 19 77 NOTARY PUBLIC, in

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and for the County of Dade, State of Florida NOTARY PUC'O STAT- GF FLORIDA Ny commission expires:

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P. O. BOX 013100, MIAMI,'FL 33101 le~.~8 FLORIDA POWER & LIGHT COMPANY June 9, 1977 L-77-174 Director of Nuclear Reactor Regulation Attention: Mr. Victor,Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. '20555 Dear Mr.

Re:

Stello:

Turkey Point Units 3 and 4 l4$g ~ ggg~g leuM ISS 10N MJ ~~

Docket Nos. 50-250 and 50-251 Cy Proposed Amendment to Facility 0 eratin Licenses DPR-31 and DPR-41 In accordance with 10 CFR 50.30, Florida Power 6 Light Company submits herewith three (3) signed originals and forty (40) copies of a request to amend Appendix A of Facility Operating Licenses DPR-31 and DPR-41.

In response to telephone requests from members of your staff, we have revised our proposal of May 3, 1976 on the subject of air filtration systems. The present proposal conforms as near as possible to the Standard'echnical Specifications without our having to make hardware modifications. The proposed changes are described below and shown on the accompanying Technical Specification pages bearing the date of this letter in the lower right hand corner.

Pa es ii and iii Revised Table of Contents.

Specification 3.4.3.b is revised. This specification concerns the limiting conditions for operation applicable to. the Emergency Containment Filtering System during power operation.

Pa e 3.13-1 New specification 3.13 is added. This specification concerns the limiting, conditions for operation applicable to the Control Room Ventilation System and the Post Accident Containment Vent System..-

PEOPLE... SERVING PEOPLE

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Director of Nuclear Reactor Regulation Page Two Pa es 4.7-1 through 4.7-3 The surveillance requirements of specifications 4.7.1 (Emergency Containment Filtering System) and 4.7.2 (Post Accident Containment Vent System) are revised. A new specification 4.7.3 (Control Room Ventilation System) is.

added.

Page B3.13-1 A new section B3.13-1 is added to prove.d'e bases for new specification 3.13.

Pa e B4.7-1

The bases for specification 4.7,are revised to include the Control Room Ventilation System.

The proposed amendment has been reviewed by the Turkey Point Plant Nuclear Safety, Committee and the Florida Power & Light Company Nuclear Review Board and the conclusion reached that involve an unreviewed safety question.

it does not Very truly yours, Robert E. Uhrig Vice President REU/MAS/cpc Attachment cc: Mr. Norman C. Moseley, Region Robert Lowenstein, Esquire II

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