ML18227C717
| ML18227C717 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/26/1976 |
| From: | Robert E. Uhrig Florida Power & Light Co |
| To: | Stello V Office of Nuclear Reactor Regulation |
| References | |
| L-76-133 | |
| Download: ML18227C717 (34) | |
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U.'S. NUCLEAR REGULATORY COMMIS"'
NRC FOIIM 195 I2-76 I I1
"'+IRC"DISTRIBUTIONFon PART 50 DOCKET MATERIAL DOCKET NUMBER 51 FILE NUMBER TO:Mr.'. Stello
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FROM: Florida Power & Light Co.
MiaIni, Fla, 33101
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R.ED Uhrig, DATE OF DOCUMENT 3>>26-76 DATE RECEIVED 4-3<<76" FBLETTER 2IIEIOAIGINAL OCOr Y XENOTORIZED 2I59UNCLASSIFIED PROP INPUT FORM NUMBER OF COPIES RECEIVED "
3 signed 37 CC DEscRII TIoN Ltr notarized 4-1-76 request for amdt of App. A of Lic, DPR-31 & DPR-41 in re to surveillance testing
& trans...the following:
ENcLosURE Revised
& addi pages to Proposed Tech Sphcs for Turkey Pt, Units 3 & 4 ~ ~, ~"
(40 cys encl rec'd)
- PLANT NAME: Turkey Pt. Units'-3 & 4 Mq~oel@K~
"<<~~~4l11161 i %0 f1~ii, SAFETY ASSXGNED AD.
BRANCH CHXEF:
FOR ACTION/INFORMATION ASSIGNED AD:
BRANCH CHIEF:
ENVIRO DHL 4 7 76 PROJECT kfANAGER:
LICE SST
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PROJECT hfANAGER LIC ASST GFL I
NRC PDR a I &E E D INTERNALDISTR I BUTION E "S F
BENAROYA E NST AL RD SPANGLER GOSSXCK & STAFF ASE PROJECT MANAGEMENT BOYD P.
COLLINS HOUSTOil PETERSON MELTZ HELTEMES SKOVHOLT LPDR 4 TIC NS ENG NEER N
KNIGHT SIWEIL PAVLICKI REACTOR SAFETY ROSS NOVAK ROSZTOCZY CHECK AT & I SALTZMAN RUTBERG EXTERNAL ISTR IBUTION NATL LAB REG. V-IE LA PDR IPPOLITO OPERATING REACTORS STELLO~
OPERATING TECH EISENHUT SHAO.
BAER SCHWENCER GRIMES SITE 'SAFETY & ENV R ANALYSIS DENTON & MUI.LER BROOKIiAVEN NATL LAB ULRIKSON(ORNL)
SITE TECH GAKfILL STEPP HULMN SITE ANALYSIS VOLLEYfER BUNCH J.
COLLINS KREGER CONTROL MSER ASLB SEb CONS ULTANTS g
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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. Stello:
FLORIDA POWER & LIGHT COMPANY March 26, 1976 Ne~gulatory Docket fiio eggtp~
co "~sscv
~~Iss~
I~I Re:
Turkey Point Un'-ts 3 and 4
Docket Nos.
and 50-251 Proposed Amendment to Facility 0 eratin Licenses DPR-31 and DPR-41 In accordance with 10 CFR 50.30, Florida Power and Light Company submits herewith three (3) signed originals and forty,(40) con-formed copies of a request to amend Appendix A of Facility Operating Licenses DPR-31 and'DPR-41.
This submittal proposes Technical Specification changes to permit waiver of certain surveillance test'ing requirements during cold shutdown or refueling shutdown conditions and supplements our previous proposals of September 19-20, 1974.
The proposed changes are as described below and as shown on the accompanying Technical Specification pages bearing the date of this letter in the lower right hand corner.
Pa e 4.1-1 Technical Specification 4.0 is expanded to include a general discussion of surveillance tests which are not applicable during cold shutdown or refueling shutdown conditions.
Table 4.1-1, Sheets 2 and 3
A footnote, applicable to items 17A and 17B, is added to modify the surveillance requirements for these items during cold or refueling shutdowns.
Table 4.1-2, Sheets 1 and 2
Footnotes, applicable to items 2, 4, 10, 14 and 17, are added to modify the surveillance requirements for these items during cold or refueling shutdowns.
8348 HELPING BUILD FLORIDA
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Director of Nuclear Reactor Regulation Attention:
Mr. Victor Stello, Director Page Two March 26, 1976 Pa e 4.5-2 Technical Specification 4.5.2.a.2 is revised such that the acceptance criteria is satisfied if the safety injection pumps reach the required head for "normal" as well as for "recircula-tion" flow.
During cold or refueling shutdown conditions, the RHR pumps are normally operated to remove decay heat, in which case it would be necessary to, check head vs. normal flow rather than recirculation flow.
Footnotes, applicable to Technical Specifications 4.5.2.b.l, 4.5.2.b.2, and 4.5.2.b.4 are added to modify the surveillance requirements for cycling the boron injection tank isolation valves and the containment recirculation sump suction valves and the RNST outlet valves during cold or refueling shutdowns.
Pa e 4.6-2 A footnote, applicable to Technical Specification 4.6.2, is added to modify the surveillance requirements for starting the containment spray pumps and the emergency containment cooling fans during cold or refueling shutdowns.
Pa e 4.7-1 A footnote, applicable to Technical Specification 4.7.1.1, is added to modify the surveillance requirement for conducting emergency containment filtering system tests during cold or refueling shutdowns.
Pa e 4.10-1 A footnote, applicable to Technical Specification 4.10, is added to modify the surveillance requirements for conducting periodic tests of the auxiliary feedwater system during cold or refueling shutdowns.
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Director of Nuclear Reactor Regulation Attention:
Mr. Victor Stello, Director Page Three March 26, 1976 The proposed amendment has been review'ed and the conclusion reached that it does not involve a significant hazards 'considera-tion, therefore, prenoticing pursuant to 10 CFR 2.105 should not be required.
A written safety evaluation.is attached.
Very truly yours, Robert E. Uhrig Vice President REU/MAS/cpc Attachment cc:
Mr. Norman C. Moseley Jack R.
Newman, Esquire
STATE OF FLORIDA
)
)
SS COUNTY OF DADE
)
Robert E. Uhrig, being first duly sworn, deposes and says:
That he is a Vice President of Florida Power 6 Li.'ght Company, the Licensee herein; That he has executed the foregoing document; that the statements 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. Uhrxg Subscribed and sworn to before me this day of 1976 Nota Publi
, xn and County of Dade, State My Commission expires for the of Florida NOQARY PUBS!C S/ATE OF FLORIOA at LARGE MY COMMISSION EXPIRES AVGUSY 22, ti3 BONOEO YHRU VAYttARO BOttOIHIE AGENCY
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4.0 SURVEILLANCE RE UIREMENTS 4.0.,1 Specified intervals may be adjusted plus/g or minus 25% to accommodate normal test schedules.
4.0.2 When the reactor is in a shutdown condition, some of the surveillance requirements discussed in this section are not required to be satisfied provided that the safety limits or limiting conditions for operation for the shutdown status are satisfied.
When a surveillance activity is not completed because the reactor is shutdown and the surveillance is not re-
- quired, the surveillance requirement shall be met prior to the time indicated in the applicable footnote.
4.1 OPERATIONAL SAFETY REVIEW limiting conditions for operation.
~Ob 'ective:
To specify the minimum frequency and type of surveillance to be applied to equipment and conditions.
Calibration, testing, and checking of analog channels and testing of logic channels shall be performed as specified in Table 4.1-1.
Equipment and sampling tests shall be conducted as spec-ified in Table 4.1-2.
4.1-1 3/26/76
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TABLE 4.1-1 SHEET 2
. --.Ch'annel Descri ti'on Check Calibrate
- Test, Remarks 10.
Rod Position Bank Counters ll.
Steam Generator Level 12.
Charging Flow 13.
Residual Heat Removal Pump Flow 14.
Boric Acid Tank Level N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
'Hath analog Rod Position 15.
16.
Refueling Water Storage Rank 3.evel Wt Uolume Control Tank Level N.A.
R.
N.A.
N.A.
17B. Containment Pressure 17A. Containment Pressure N't W
Mjt M
Wide Range Narrow Range 18A. Process Radiation 18B. Area Radiation 19.
Boric Acid Control 20.
Containment Sump Level N.A.
N.A.
A N.A.
N.A.
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M 21.
Accumulator Level and Pressure St N.A.
22.
Steam Line Pressure St"
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TABLE 4.1-1 SHEET 3
Channel Descri tion Check Calibrate Test Remarks 23.
Environmental Radiological Monitors N.A.
A(1)
M(1)
(1) Flow 24.
J Logic Channels N.A.
N.A.
25.
Emer. Portable Survey instruments N.A.
- 26. i A*
Seismograph N.A.
N.A.
Using moveable in-core detector system.
Frequency only Effluent monitors only.
Calibration shall be as specified in 3.9.
Make trace Test battery (change semi-annually)
D B/W
-- <<,R A
N.A.
Each Shift Daily Weekly Every Two Weeks Monthly Quarterly Prior to each startup if not done previous week Each Refueling Shutdown Annually Not applicable N.A, during cold or refueling shutdowns.
The specified tests, however, shall be performed within one surveillance interval prior to startup.
N.A. during cold or refueling shutdowns.
The specified tests, however, shall be performed within one surveillance interval prior to.zeatup above
- 200F,
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Reactor Coolant Samples 2.
Refueling Water Stoxage Tank Water Sample MINIMUMFREQUENCIES FOR EQUIPMENT AND SAPLING TESTS Check
~&re cene Radiochem.
(T<>30 Min)
Monthly Cl
& 02 5/Week Tritium Activity Weekly Gross G,y Acrivity (pCi/cc g 5/Veek Boron Concentrat ion 2/Week (E) Determination Semi-annually Boxon Concentration Weekly 0 Max. Time Between Tests 45 Days 3
10 3
5 30Wks.
10 3 ~
Boric Acid Tank 4 ~
Boron Injection Tank 5 ~
Control Rods Boron Concentration Boron Concentration Rod drop times of all full length rods Par tial movements of-full length rods 2/Week Monthly t Each refueling shut-NA down and following maintenance Biweekly while 20 critical 6.
Pressurizer Safety Valves Set point Each refueling shutdown NA 7.
Main Steam Safety Valves Set point Each refueling shutdown NA 8.
Containment Isolation Trip Functioning Each refueling shutdown NA 9 ~
Refueling System Interlocks 10.
Accumulator 11 ~
Reactor Coolant System Leakage Functioning Boron Concentration Evaluate Prior to each re-fueling shutdown Q
Monthly t Daily NA NA 12.
Diesel Fuel Supply 13.
Spent Fuel Pit 14.
Secondary Coolant 15'ent Gas
& Particulates Fuel inventory Boron Concentration I-131 Concentration I-131
& Particulate Activity Weekly 10 Weekly
- tt'eekly 10 10 Prior to refueling NA 16.
Fixe Protection Pump Power Supply Operable Monthly 17 ~
Turbine Stop and Contxol
- Valves, Reheater Stop and Intercept Valves Closure Monthly >>>>
18.
LP Turbine Rotor Inspection (w/o rotor disassembly)
V, MT, PT Every 5 Years 6 years 5/>6/y6
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TABLE 4.1-2 SHEET 2
t~ N.A. during cold or refueling shutdowns.
The specified tests,
- however,
~shall be performed prior to heatup above 200 P.
O'I' N.A. when reactor power is less than 2 percent during and after a cold or refueling shutdown.
The sampling surveillance shall commence within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after sustained operation above 2 percent power.
<< When activity exceeds 10% of spec, frequency shall be changed to Daily.
- ~ N.A. during cold or refueling shutdowns, or at hot shutdown, when all main steam isolation valves are shut.
The specified tests,
- however, shall be performed within one surveillance period prior to starting the turbine.
3/26/76 I
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Pumps shall start and reach required head for normal or recirculation flow, whichever is applicable to the operating condition; the instruments and visual observations shall indicate proper functioning.
Test operation shall be for a least 15 minutes.
b.
Valves 1.
The boron injection tank isolation valves receiving a Safety Injection signal shall be cycled monthly.tt 2.
The containment recirculation sump suction valves shall be cycled monthly.t 3.
Accumulator check valves shall be checked for operability during each refueling shut-downs 4.
The refueling water storage tank outlet valves shall be tested in performing the respective pump tests.T l
t N.A. during cold or refueling shutdowns.
The specified tests,
- however, shall be performed within one surveillance interval prior to reactor startup.
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tt N.A. during cold or refueling shutdowns.'The specified tests,
- however, shall be performed within one surveillance in,terval prior to heatup above 200 P.
4.5-2 3/26/76 1
'2.
> COMPONENT TESTS Pum s and Fans The containment spray pumps. and the Emergency Contain-ment Cooling fans shall be started at intervals not greater than one (1) month. tf Acceptable levels of performance shall be that the pumps reach their rated shut off heads, the fan motors reach their nominal operating current for the containment at-
! mosphere during the test, and both operate for at least fifteen minutes.
Valves
~ The systems motor operated isolation valves will be tested for operation during system tests.
O' N.A. during cold or refueling shutdowns.
The specified tests,
- however, sha3.1 be performed within one survei13,ance interva3. prior to heatup above 200 F.
'4. 6-2 3/26/76
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4.7 EMERGENCY. CONTAIN>
'FILTERING AND POST ACCIDENT AINMENT VENT SYSTEMS Applies to the Emergency Containment Filtering and the Post Accident Containment Vent System components.
To verify that these systems and components will be able to perform their design functions.
Specification:
4.7.1 EMERGENCY CONTAINMENT FILTERING SYSTEM 1.
OPERATING TESTS System tests shall be performed at approximately quarterly intervals.tf These tests shall consist of visual inspection and pressure drop measurements across each filter bank.
Visual inspection shall include inspection of general condition for evidence of:
water, oil, or other foreign material; gasket deterioration adhesive deterioration in the HEPA units; excessive dust cake on the demisters; and unusual or excessive noise or vibration when the fan motor is running.
Pressure drop across any filter bank shall not exceed two times the pressure drop when new and shall not be less than the pressure drop when new.
2..
PERFO&fANCE TESTS During each refueling operation, "in-place" DOP and freon tests shall be conducted at design flow on each unit (a11 flow paths).
99.9%
DOP removal and 99.5% freon removal shall constitute acceptable performance.
>1'1 - N.A. during cold or refueling shutdowns.
The specified tests,
- however, shall be performed within one surveillance interval prior to heatup above 200 F.
4.7-1 3/26/76
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4elo AUXILLARYFEEDWATER SYSTEN Applies to periodic testing requirements of the auxiliary feedwater system.t
~Ob'ective:
To verify the operability of the auxiliary feedwater system and its ability to respond properly when required.
S ecifications:
1.
Each turbine-driven auxiliary feedwater pump shall be started at intervals not greater than one month; run for 15 minutes and a flow rate of 600 gpm es-tablished to the steam generators.
2.
The auxiliary feedwater discharge valves shall be tested by operator action during pump tests.
3.
Steam supply and,turbine pressure valves shall be tested during pump tests.
4.
These tests shall be considered satisfactory if control panel indication and visual observation of the equipment demonstrate that all components have operated properly.
t-N.A. during cold or refueling shutdowns (only for the Unit at cold or refueling shutdown).
The specified tests, however, shall be performed within one surveillance interval prior to starting the turbine.
4.10-1 3/26/76
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SAFETY EVALUATION INTRODUCTION The limiting conditions for operation of the Technical Specifica-tions describe the instrumentation and equipment, required for specific plant conditions.
They also describe the remedial action necessary to place the reactor in a safe condition should a
limiting condition for. operation not be met.
The bases for the various limiting conditions for operation and safety limits are included in the Technical Specifications.
This submittal proposes Technical Specification changes to permit waiver of surveillance testing requirements during cold or refueling shutdown conditions.
The specific changes are discussed below.
The changes do not eliminate any test, but simply permit delaying certain tests until such time as the associated limiting condition for operation is applicable.
DISCUSSION l.
Table 4.1-1, Items 17A 6 178:
The containment pressure channels are needed to initiate signals for LOCA or steam break accidents in the containment and to indicate containment pressure during operation.
They have no safety function when the reactor is cooled below 200'F and the waiver of the testing, presents no hazard.
2.
Table 4.1-2, Items 2, 4, 10:
The boron concentration specification for the Refueling Water Storage Tank (RWST), Boron Injection Tank (BIT), and the Accumulators has been provided to ensure adequate boron is available to insert negative reactivity into the core in the event of a steam break or LOCA accident.
At cold or refueling shutdown conditions, these accidents cannot occur and the requirement to sample these tanks may be waived.
The tanks will be verified to be at the required boron concentration prior to heating up the unit above 200'F.
3.
Table 4.1-2, Item 14:
The sampling of secondary coolant for I-131 is to insure, in the event of a load rejection accident during operation, that, the I-131 released to the atmosphere via the steam generator safety valves does not pose a hazard to the health and safety of the public.
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If the reactor is in a cold condition, no steam will be generated and no I-131 can be released.
It is therefore safe to waive this sampling requirement at cold or refueling shutdown.
Below 2 percent power, the reactor would not be maintaining any electrical load and therefore the load rejection accident could not occur.
The I-131 is also dependent upon reactor power for its creation; below 2 percent power no significant I-131 is created.
Even if there was a primary to steam generator secondary tube leak, only insignificant trace amounts of I-131 would be found.
4.
Table 4.1-2, Item 17:
The turbine stop and control valves and the reheater stop and intercept valves are provided with automatic closure devices to prevent turbine overspeed and missile accidents as described in the FSAR.
In a cold condition, no steam is being generated and there is no need to test the closure of these valves.
Also, with all main steam isolation valves
- closed, the turbine cannot be started.
5.
Item 4.5.2.a.2:
6.
The provision to allow the, acceptance criteria to be "required head at normal or recirculation flow," is in keeping with good engineering practice.
The test is to demonstrate that the pumping characteristics continue to be satisfactory.
Normally, at refueling or cold shutdowns the RHR pumps are operated to remove decay heat, and it is necessary to check head vs. normal flow and not recirculation flow.
I Item 4.5.2.b.l:
The boron injection tank (BIT) was provided to insure adequate poisoning of the core in the event of a steam line break accident.
At cold or refueling shutdown, it is not, required to have the BIT available to assure reactor safety because the reactor is already borated to a safe shutdown margin at that time and little if any reactivity will be inserted by temperature change after cooldown.
Therefore, it, is not necessary to test the BIT isolation valves during cold or refueling shutdowns.
7.
Item 4.5.2.b.2:
The containment recirculation sump suction valves are required to be opened when a
LOCA has occurred and recirculation from the containment floor is required.
When the reactor is in a cold or refueling shutdown condition, the RHR system is in operation to remove decay heat.
The sump suet'ion valves connect to the RHR system and it is not feasible to secure the RHR system in order to cycle these valves.
The probability
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Item 4. 5. 2. b. 2:
(Continued) that these valves would be required below 350'F is sufficiently remote to conclude that no hazard is "presented by delaying the surveillance test of these valves.
Item 4.5.2.b.4:
The refueling water storage tank outlet valves are normally left open during reactor operation to assure a ready suction supply to the low and high head safety injection pumps.
These valves are shut when shifting to the recirculation phase during a LOCA or when the refueling cavity has been flooded.
Testing the valves to assure they will operate when the plant is already in a cold or refueling condition does nothing to improve the assurance that the reactor is in a safe condition.
Item 4.6.2:
The containment spray pumps and emergency containment coolers are provided to reduce containment pressure in the event, of a
LOCA or steam break accident.
When the reactor is in a cold or refueling condition, these accidents cannot occur and pressurize the containment; therefore, increasing the test interval presents no safety hazard.
Item 4. 7. l.l:
The emergency containment filters are provided to remove radioactive airborne particles from the containment atmosphere in the event, of a LOCA.
At. cold or refueling shutdown the probability of a LOCA occurring and generating airborne activity is very remote; therefore,,no safety hazard is presented by waiving its surveillance testing interval.
Item 4.l0:
The auxiliary feedwater system has both individual unit and shared unit safety features.
At cold or refueling shutdown conditions, the affected unit's steam supply and feedwater control cannot be tested because the unit is cold and cannot generate steam.
The function of these systems is to help cool down a hot unit; since the unit is already cold no safety hazard is presented by not testing these features.
Also, unless the reactor is critical enough steam cannot be generated to run the auxiliary feed pumps long enough to verify the required 200 gpm per steam'enerator feed flow.
CONCLUSIONS Based on these considerations, (l) the proposed change does not increase the probability or consequences of accidents or mal-functions of equipment important to safety and does not reduce the margin of safety as defined in the basis for any technical specification, therefore, the change does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by, operation in the proposed
- manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
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