ML20012E671
| ML20012E671 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/26/1990 |
| From: | Saporito T NUCLEAR ENERGY ACCOUNTABILITY PROJECT |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-#290-10155 OLA-5, NUDOCS 9004060085 | |
| Download: ML20012E671 (23) | |
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RELATED CORRESPONDENCE j
NUCLEAR ENERGY ACCOUNTABILITY Prob 33468 0129 (407) 7b-0 Post Office Box 129 Jupiter, Florida Environmental Protection. Involvement. Litigation. Infortnation v'sm.,,
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'Mr. Stewart.Ebneter, Administrator March 26, 1990
'Mr. Oscar DeMiranda, SAC.
U.S. Nuclear Regulatory Commisc* ion 101 Marietta Street, N.W.,
Suite 2900 Atlanta, Georgia 30323 j
-OM d Re: Turkey Point Docket Nos: 50-250 and 50-251 The Nuclear-Energy Accountability Project (NEAP) is currently engaged in an Atomic Safety and Licensing Board Proceeding concerning the Turkey Point nuclear plant.
Your licensee has requested to amend their operating licenses to adopt a new set of technical specifications for the Turkey Point nuclear plant.
Although we agree with your licensee, that the revised technical specifications would be an improvement over the current technical specifications, we disagree with the j
extensive relaxations of certain safety margins which exist in the current technical specifications.
NEAP participated in oral argument in Miami, Florida before the ASLB of the NRC concerning the amendment proceedings.
l Because of new rulemaking by the Commissiori. the threshold for admission of a contention into an ALS3 procasding has been substantially elevated.
Additionally, because of the Board's u
demeanor at oral argument, Peticioners' oro ao status in these proceedings, and because Patitioners were denied adequate materials and preparation time for their filings in this proceeding, Petitioners Witndrew quite a few of their contentions from the proceeding.
Because wo bnlieva that sericue consequences could result if your licensee were permit *,ed to relax the numerous existing safety margins embraced in the Revised Technical Specifications, we have delineated our concerns, from those contentions which we have withdrawn from the ASLB proceedings, into a package for resolution by NRC Region II personnel.
Accordingly, the U.S.
NRC Region II is hereby officially notified of the following nuclear safety concerns germane to your licensee's Turkey Point nuclear plant as attached herein.
We request that these concerns be fully investigated by the region to ensure that public health and safety is not jeopardized in any manner as a direct or indirect result of the safety relaxations contained in the Revised Technical Specifications.
9004060085 900326 Sincerely, y/
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Saporito,, Jr.
cc: Service Sheet Thomas J.
Executive Director, NEAP
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l RELATED CORRESPONDENCE
@j"ffo UNITED STATES OF AMERICA 9 0 nre p g P 3 :4 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges
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l Peter B. Bloch, Chair Dr. George C. Anderson Elizabeth B. Johnson In the Matter of
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Docket Nos. 50-250-OLA-5
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50-251-OLA-5 FLORIDA POWER & LIGHT
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COMPANY
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Technical Specifications Turkey Point Plant
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Replacement (Unit Nos. 3 and 4)
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ASLBP No. 90-602-01-OLA-5 Facility Operating
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Licenses Nos. DPR-31, DPR-41 )
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CERTIFICATE OF SERVICE I hereby certify that copies of '" PETITIONERS PACKAGE TO THE NRC REGION II STAFF CONCURNING TURKEY POINT" in the above captioned proceeding, were served on the following by deposit in the United Staten mail, first class, properly stamped and addressed, on the data shown bolow.
Honorable Peter B. Bloch, Chair Janics E.. Moor +, Esq.
Atomic Safety and Licencing Boerc Patricia A Jehls, Esq.
U.S. Nuc10nr Regulatory Commission Office of General Counsel Weshington, D.C.
2CS55 Nuf.aa" Regulatory Comm, Washington, D.C. 20555 Honorable Dr. George C. Anderson
\\ tom 1C Bafety/ Licensing Atomic Safety and Licensing Board Appeal Board Panel
-450 Vists Chino, Apt. 2015 Nuclear Regulatory Comm.
Palm Springs, CA 92262 Washington, D.C. 2D555 Honorable Elizabeth B. Johnson Steven P.
Frantz, Esq.
Oak Ridge National Laboratory Newman & Holtzinger, P.C.
P.O. Box 2008 1615 L Street, N.W.
Bethel Valley Road, Bldg. 3500 Suite 1000 Mail Stop 6010 Washington, D.C. 20036 Oak Ridge, TN 37831 Richard J. Goddard Office of the Secretary Regional Counsel U.S. Nuclear Regulatory Commission U.S.NRC Region II Washington, D.C.
20555 101 Marietta St.NW, #2900 Atlanta, Georgia 30323 Attn. Chief Docketing / Service Sect, w.......
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Dated this 26th day of March, Thomas J. 56por#So, Jr37 1990 at Jupiter, Florida.
Executive Director, NEAP
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Withdrawn Contention 10: Revised Tech Soec. 3/4.0 The licensee's position as stated in the NSHE is that the proposed specification 3.0.4 will allow entry into an operational mode or other specified conditions with LCO reouirenents not fully established if conformance with action statements requirements permit continued nperation of the facility for an unlimited period of time.
NEAP asserts here that the CTS 3.0.4 states that entry into an operational mode or other specified condition shall not be made unless the LCO is met without reliance on the provisions of the action requirements.
Therefore, the CTS are more restrictive than the RTS and thus provide for an increased margin of safety.
The established LCOs are intended to provide the necessary requirement for safe plant operation.
Therefore, to permit operation of the plant to be authorized without full compliance with the LCO and to permit plant operation to be controlled by the action statements, would invite unsafe plant operation.
If plant operation were to be restricted to an action statement, why have the LCO requirements at all ?
The licensoe's position as stated in their NSHE is that the i
proposed specification 4.0.3 will allow a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> grace period to perform missed surveillances when the allowable outage times of the actio.n requirements are leso than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
When a surveilltnce is missed, it is primarily a question of operability that has not been verified, not necessarily the unavailability J>f 4 cystem or component to perform its design funct',on.
The allowable outage tima limits of some action raquiremeats do not provide apprcuriate time for performing a misteo surveillance before abutcown requiremente apply.
A technice.1 specification time limit that allows a 2a hour delay of action requirements tc, perform a missed surveillance is acceptable because it allows for adequate plant planning, availabi'ity of personnel and increased plant safety by reducing pressure on the plant staff to expeditiously complete the required surveillance so that the plant can return to normal operation.
NEAP disagrees with licensee's position because when a surveillance is missed, it is primarily a question of unavailability of a system or component to perform its design function.
It is reasonable to understand that all systems and components are presumed operable and in a state of readiness to perform their design function. If the contrary were true, the surveillance frequency would have to be significantly increased.
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NEAP also disagrees with licensee's position because the CTS do not allow a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> grace period to perform missed surveillances and require unit shutdown in the event that a surveillance is missed.
The CTS also provide for adjusting the specified intervals plub or minus 25%.
See CTS 4.0 at cane 4.1-1.
This allows for adequate plant planning, availability of personnel and increased plant safety by reducing pressure on the plant staff to expeditiously complete the required surveillance so that the plant can return to normal operation.
Furthermore, the RTS 4.0.3 state that the time limits of the action requirements are applicable at the time it is identified that a surveillance requirement has not been performed.
Therefore, the missed survaillance could have occurred over a much longer period of time without appropriate operatator action.
The licensee failed to analyize this senerio in their NSHE, therefore their NSHE is incomplete and should not be relied.
NEAP asserts here that the RTS provide a means and a method for unsafe plant operation through missed surveillanges because the NSHE is incomplete.
These factor weigh heavily towards the possibility of unsafe plant operation.
For all the foregoing reasons, the RTS 3/4.0 involves a significant increase in the probsbility of or consequences of an accident previously evalasted and involves a significent reduction in a margin of safety.
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Withdrawn Contention 15: Revised Tech Soec. 3/4.1.2.3 The CTS provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time for charging pumps.
The RTS provide 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time for charging pumps.
The CTS require placing the plant in Cold Shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if the charging pump is not returned to service within the initial time period.
The RTS require placing the plant in Hot Standby and borating to 1% delta k/k at 2000 F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and restoring the plant to operable status within the next 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of be in Cold Shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
The CTS employ a surveillance requirement to calibrate the charging pump flow channel.
The RTS delete the surveillance requirement to calibrate the charging pump flow channel.
For all the foregoing reasons, the RTS 3/4.1.2.3 involves a significant increase in the probability of or consequences of an accident previously evaluated and involves a significant reduction in a margin of scfety.
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k Withdrawn Contention 17: Revised Tech SDec. 3/4.1.2.5 The CTS require that a boron concentration surveillance be performed twice per week with a maximum tirae between tests of 5 days.
The RTS relax the BAT boron concentration surveillance from twice weekly to weekly.
l The CTS require that the primary water storage tank contains not less than 30,000 gallons of water.
The RTS delete the minimum volume requirement on the primary water storage tank.
The CTS do not allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the operable status of the Boric Acid Storage System.
The RTS permit 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the operable status of the Boric Acid Storage-System, then require placing the plant in hot standby and borating to 1% delta-k/k at 200 degrees (F) within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and requires restoring the Boric Acid Storage System to operable status within the next 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in cold shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
For all the foregoing reasons, the RTS 3/4.1.2.5 involves k significant increase in the probability of or consequencee el an e,ccident and invcives a significant reduction in a margin of l
aafety.
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b Withdrawn Contention 19: Revised Tech Soec. 3/4.1.3.1 The RTS delete the. requirement that limits the potential reactivity-insertion from inoperable control rods to 0.3%.
The RTS delete the requirement ot reduce the hi-flux trip setpoint when both rod and power range channel deviation alarms are inoperable.
The RTS change the requirement for logging rod position once per shift when the Power Range Channel Deviation Alarm is inoperable.to calculating the Quadrant Power Tilt Ratio once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The RTS relax surveillance intervals for determining i
operable control rods from 14 days to 31 days.
We believe that the safety margin relaxations delineated above are unacceptable and represent an increase in the probability for an accident.
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Withdrawn Contention 20: Revised Tech Soec. 3/4.1.3.2 The RTS would change the surveillance intervals for control rod position-indicators from 8_ hours to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The RTS delete the surveillance requirement for rod position indicators after >= 10% load changs.
We believe that the safety margin relaxations delineated above are unacceptable and represent an increase in the probability of'an accident.
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- .p Withdrawn Contention 24
- Revised Tech Soec. 3/4.2.4 The RTS would relax the-Mode Applicability to Mode 1, Power above 50%.
The RTS would relax a current requirement-to reduce the overtemperature and overpower delta-T (OTd-T and OPd-T) trip setpoints.
The RTS would relax another safety margin by deleting the
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We believe that the relaxation of the above safety margins is unacceptable and represents an increase in the possibility of an accident.
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,ithdrawn Contention 26: Revised Tech Soec. 3/4.3.2 W
The RTS would provide for a safety margin relaxation whereas in the' event that one-channel of manual-initiation of selected ESFAS functions is inoperable, a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed outage time is included for restoration of the channel to operable status before shutdown is required.
The RTS provides a'48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed outage time for restoration of the channel to operable status before following the action required by TS 3.7.1.5.
The CTS permit only.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> before initiating a plant status change.
The RTS would relax the trip channel actuation logic surveillance interval from monthly to bi-monthly on a staggered basis.
RTS 3/4 3.2 Pago 3/4 3-13, provides for ESFAS instrument set points per Table 3.3-3 Page 3/4 3-23.
No allowable values are provided.
We believe that the relaxation of-the safety margins described above is unacceptable-and represents an increase in-the probability of an accident.
Withdrawn Contention 27: Revised Tech Soec. 3/4.3.3.1 The.RTS would delete the surveillance requirement of the area radiation monitors.
The RTS relax the current requirements in that the applicability of the gaseous radiation monitors for the spent fuel pit is-changed from "at all times" to "at all times irradiated fuel is in the spent fuel pit".
We believe~that the above' described relaxation of safety margins is unacceptable and represents an increase in the probability of an accident, l
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Withdrawn Contention 28: Revised Tech Soec. 3/4.3.3.3 The RTS would delete.the current' monthly flow path verification of the Post Accident Sampling System.
The RTS relax the channel check of the Refueling Water Storage Tank level' instruments from weekly to monthly intervals.
We believe that the relaxation of safety margins discussed above is unacceptable and represents an increase in the probability of an accident.
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i j-Withdrawn Contention 34: Revised' Tech Soec. 3/4.4.2.2 The-RTS include an' Action statement which allows 15 minutes of' time-to:make an inoperable valve operable.
We find the above relaxation of a safety margin to be unacceptable as it represent an increase in the probability.of an accident.
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-Withdrawn Contention 36: Revised' Tech Soec. 3/4 4.6.1 1
~The RTS allow the radioactive monitoring system to be inoperable for 7 days and reduce the number of systems required to'be, operable ~during this time.
We find.the relaxation of the safety-margin ~ described-above to be unacceptable as it_provides for an increase in the 1
probability _of an accident.
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- ,-i, Withdrawn Contention 37: Revised Tech Soec. 3/4 4.6.2 The RTS relax safety margins by requiring that the Reactor Coolant System Leakage be determined every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> only if 1
during steady' state operation.
The RTS requires leak testing only on other valves in-the same line as the valve which exceeds its allowed limit.
The RTS relax leak testing requirements to be applicable only in Modes 1 through 4.
The above described relaxations of safety margins are unacceptable and represent an increase in the probability of an I
accident.
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5 Withdrawn ~ Contention 38: Resived Tech Soec. 3/4 4.8
'The RTS remove the current accumulative time reporting
- requirement for the iodine activity limit.
The RTS relax the current requirement to determine gross-radioactivity-5-times per week with not more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />' between samples, to a determination of the gross radioactivity
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every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The above described relaxation of safety margins is.
unacceptable and represents an increase in the probability of an accident.
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Withdrawn Contention 39: Revised Tech Soec. 3/4' 5.1 The RTS' delete the current requirement to perform Channel Checks on the accumulator level and pressure channels at least once per shift.
The RTS require reducing to only Mode 3 with the pressurizer pressure below 1000 psig.
j The above described relaxation.of safety margins is unacceptable and represents an increase in the probability of an accident.
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Withdrawn Contention 40: Revised Tech Soec. 3/4 5.2 The RTS relax to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> the time requirement that inoperable equipment be returned to operable status.
The CTS require that inoperable equipment be returned 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 RTS relax, to the period provided-at TS 4.0.5, the-requirement to cycle the Boron Injection tank Outlet Valves,-
Containment Sump Recirculation Valves and RWST Outlet Valves.
The CTS. employ the requirement to cycle the Boron Injection Tank Outlet Valves, Containment Sump Recirculation Valves and RWST Outlet once every 30 days.
The RTS relax, to the period provided at TS 4.0.5, the requirement to test the Safety Injection pumps.
The CTS employ the requirement to test the Safety Injection pumps once every 30 days.
The RTS relax the requirement to go to Cold Shutdown if the LCO is not restored within the Action time limit by permitting to go to Hot Shutdown if these conditions exist.
The CTS employ the requirement to go to Cold Shutdown if the LCO is not i
restored within the Action time limit.
The RTS remove the surveillance requirement to demonstrate l
the operability of unaffected RHR and SI pumps of valves prior I
to_ initiating maintenance on an inoperable RHR pump, two inoperable SI pumps, lor valves in duplicate flow paths.
The CTS I
employ the surveillance requirement to demonstrate the operability of unaffected RHR and SI pumps ofvalves prior to
~i nitiating maintenance on an inoperable RHR pump, two_ inoperable L
SI pumps, or valves'in duplicate flow paths.
1 The RTS relax existing surveillance requirements in that testing is required in Modes 1 through 4 for the RHR pumps and Modes 1 through 3 for the SI pumps.
The CTS employ the requirement for surveillance testing of the RHR and the SI pumps is applicable in all operating modes.
The above relaxation of safety margins is unacceptable and represents an increase in the probability of an accident.
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Withdrawn Contention 42: Revised Tech Soec. 3/4 6.2.1
.The RTS relax existing safety margins by allowing.one Containment Spray System to be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in Mode 1.
The CTS allow one Containment Spray System inoperable for up to 24' hours in Mode 1.
'The RTS relax existing safety margins by reducing the requirement to test the Containment Spray Pumps only quarterly and to run the pumps for only 5 minutes..
The CTS employ the requirement to test the Containment Spray Pumps once every 30 days and run the pumps for a 15 minute time period.
The RTS relax existing safety margins by deleting the surveillance requirement to demonstrate the operability of unaffected containment spray pumps or valves prior to initiating maintenance on an inoperable system.
The CTS employ the surveillance requirement to demonstrate the operability of unaffected containment spray pumps or valves prior to initiating maintenance on an inoperable system.
The above described relaxation of safety margins represent an unacceptable increase in the probability of an accident,
Withdrawn Contention 46: Revised Tech'Soec. 3/4 7.1.1 The RTS relax existing safety margins-by allowing operation j
with one or more inoperable Main Steam Line Code Safety Valve (s) at a reduced power level beyond an. existing safety time limit of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
The CTS do not allow operation with on or more inoperable Main Steam Line Code Safety Valve (s) at a reduced power level beyond a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> safety time limit.
The RTS relax existing safety margins by providing for the testing of only a fraction of the safety valves every refueling outage.
The CTS require the testing of all safety valves every refueling outage.
The above described relaxation of safety margins represents an unacceptable increase-in the probability of an accident.
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Withdrawn Contention 49: Revised Tech Soec. 3/4 7.3 The RTS= relax existing safety margins by allowing on ICW pump to be inoperable.for 7 days if the remaining two ICW pumps L
are operable'from independent power supplies.
The CTS allow one ICW pump to be inoperable for only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The RTS relax existing safety. margins by allowing two ICW pumps to be inoperable up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The CTS require unit shutdown if two ICW pumps are inoperable.
The RTS relax existing safety margins by allowing one ICW Header to be inoperable up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The CTS allow one ICW Header to be inoperable for only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The RTS relax existing safety margins by not explicitily stating the requirement that valves, interlocks and piping associated with_the ICW pumps be operable.
The CTS explicitly require valves, interlocks and piping associated with the ICW
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pumps to be operable.
The above described relaxation of safety margins is-unacceptable and represents an increase in the probability of an accident.
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.1 Withdrawn Contention 54: Revised Tech Soec. 6.12 The RTS relax existing safety margins by specifying that the high radiation intensity is to be' measured at 18 inches l
fromthe radiation source, The RTS relax existing safety margins by allowing personnel escorted.by Health Physics personnel to 71ter a High Radiation Area without'a Radiation Work Permit (F/
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The above described relaxation cf
- afety margins is unacceptable an represents an increacs in the possibility of an employee receiving an exposure greater than that allowed by 10 C.F.R. 20.
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Withdrawn Contention 55: No aDolicable tech soec.
Tho'RTS relax existing safety margins by not~ including the following. requirements:
(a) Boron Injection Tank Contained Volume, Boron Concentration and Flow Path Heat Tracing. (3.4.1.a.2)
(b) Instrumentation in Table 4.1-1 covering:
- charging flow (item #12)
- residual heat removal pump flow (item #13)
- boric acid tank level (item #14)
- volume control tank level (item #16)
- boric acid control (item #19)
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- emergency portable survey instruments (item #24)
- seismograph (item #25)
(c) Sampling frequencies in Table 4.1-2 covering:
- boron injection tank boron concentration (item #4)
- refueling systeminterlocks (item #9)
- turbine stop and control valves,
- reheater stop and intercept valves (item #15)
- LP turbine rotor inspection (item #16)
(d) Surveillance of " power availability" for components in safety related systems flow paths in 4.18.
(e) Design Features for the following systems and components:
- reactor coolant system design and maximum potential seismic accelerations (5.22 a & b)
- containment function (5.3.A.1)
- containment design seismic acclerations (5.3.A.2)
- containment penetration and isolation valve actuation
- system design details (5.3.B1 & 2)
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- containment cooling system design details (5.3.C1, 2 & 3)
- fuel storage RCC assemblies (5.2.4) l
.(2) The RTS relax safety margins existing 1n the CTS which L
include the above detailed information.
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