ML20137K910

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Rev 0 to JPN-PSL-SENP-94-029, Safety Evaluation,Shutdown Operations Criteria for Reduced Inventory & Draining Reactor Coolant Sys
ML20137K910
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 08/15/1994
From:
FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML20137K821 List:
References
FOIA-96-485 JPN-PSL-SENP-94, JPN-PSL-SENP-94-029, JPN-PSL-SENP-94-29, NUDOCS 9704070121
Download: ML20137K910 (14)
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' I stoaIna PorEm s LIour co i e

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f. SAFETY ETALUATION SEUTDOWE OPER&TICES CRITERIA POR s

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JPN-PSL-SEEP-94-029 RETISION O SAFETY RELETED 9704070121 970402 PDR FOIA BINDER 96-485 PDR

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Tac 8. A. V ,TEC/PSL p.mc August 16,1994

.74 forb nemme D. J. om, e JP9&JS ansesse: ST. LUCE PUUfT UIETE 1 & 2 Eweduoden of miuedewei Opereelsea Cdeerde ter Reduend L _J--i and Draining a

the Reestor Coolant Sys asm . .

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In response to e sdent reajuost.1he etteched Engineering Eweduselon UP96-PSL4ENP4442M was performed. The results of the ovatustion provide the "technieri defhiaion* of reduced l

hventory and the edeeds ser determhing the thne period roghed before dreinhg 1he reactor l

cocient system to reduced bwentory fotowing a shutdown. l should there be any guestkms. please contact Museen ooindy at ess-sets in.kms seech.

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K.K. Mohedroo -JPN/JB C.L. Schaeffer .Jedc/Js C.M. Speher - JP9pJB D M. Stewart - TEC/PSL C. Scott - Out. Mgr.frSL D. West Tech /PS" R.W. Winnerd - JP9&JB J. West OPS / Pet.

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. JPN-PSL-SENP-94-029 REVISION O PAGE 3 OF 13 3- ,

TABLE OF CONTENTS i SECTION 21213 R&fs]

-- Cover 1

$ -- Table of Contents 2

-- Review and Approval 3

! -- Abstract 4 l 1.0 Purpose and Description 5 2.0 Licensing Requirements 8 l 3.0 Analysis of Effects on Safety 1, 4.0 Failure Modes and Effects Analysis 9 5.0 Plant Restrictions 9 6.0 Effact on Technical Specifications 9

. 7.0 Unreviewed Safety Question l 7 Det Ttion 10 1 8.0 Actions Required /Reccamendations 12 9.0 Conclusions 12 10.0 References 13 .

7 ATTACHMENTS

1. Figure 1, Fuel Resources-NT, FRN-89-088, St. Lucie Units 1

& 2 Thermal Hydraulic Analysis To Support Generic Letter 88-17 " Loss of Decay Heat Removal" dated January 29,1989.

2. Figure 2, Fuel Resources-NT, FRN-89-088, St. Lucie Units 1

& 2 Thermal Hydraulic Analysis To Support Generic I4tter SS-17 " Loss of Decay Heat Removal" dated January 29,1989.

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JPN-PSL-SENP-94-029 '

! REVISION O i PAGE 3 OF 13

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REVIEW AND APPRCVAL RECORD 4, PLANT ST LUCIE WIT I&2 1*

1 TITLE $WTDOW OPERATIONS CRITERIA FOR RMXED INVENTORY AW DRAININ , ,

THE REACTOR C00LANT SYSTEM l LEAD DISCIPLINE LICENSIM i

ENGINEERIM OMANIZATION ST LUCIE P " M ION EM INEERIM SROUP 4

REVIEW / APPROVAL:

i INTD FACE TYPE GROUP 1 PREPARED VDIFIED N FPL APPem O '

INPUT REVIEW l N/A i ,*

w-mm-NRM e a flECT I Itc I CITIL I .

LIC" LEAD h- b d C$1 I SS 1 Fuels X

  • For Contractor Evals As Deteretnad By Projects " Revise Interface As A Min On All 10CFR$0.58 (vals end PLAs FPL PROJECTS APPROVAL: W w . M,1 a w DATE: $1519u OTHER INTERFACES i i

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i JPN-PSL-SENP-94-029 REVISION 0 I PAGE 4 OF 13 6

j ABSTRACT l

l The purpose of this evaluation is to demonstrate the acceptability of shutdown i

operations given the following proposed changes:

i A)

The criteria for reduced inventory will now be defined as 3 feet below the reactor vessel flange.

B)

The criteria for draining the RCS after shutdown will now be limited by the time to core uncovery.

! These proposed changes will bring St. Lucie plant more in-line will NRC and industry I guidelines on shutdown operations and will provide mm flexibilit; for refueling i outages without compromising plant safety. Implementatisi of these changes i effectively amends previous submittals to the NRC on shutdown operations (Ref 6),

I however, such changes are allowed under 10 CFR 50.59 as outilned in NRC i correspondence j (Ref 2) on the same subject.

l' This safety evaluation involves an assessment of cauges to shutdown operations, and therefore, is classified as safety related.

This evaluation concludes that the proposed changes to operation of the plant during l shutdown neither involva an unreviewed safety question nor require a change to plant Technical Specifications, as defined in 10CFR50.59, and do not adversely affect l

plant operation or safety. Therefore, prior NRC approval is not required for

< implementation J

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I JPN-PSL-SENP-94-029 i REVISION O l PAGE 5 OF 13

) l l1 F 1.0 PURPOSE AfD DESCRIPTION

} The purpose of this evaluation is to demonstrate the acceptability of shutdown operations given the following proposed changes:

i

! A) The criteria for reduced inventory will now be defined as 3 feet below the

! reactor vessel flange.

i' B) The criteria for draining the RCS after shutdown will now be limited by the is time to core uncovery.

These changes will bring St. Lucie Plant more in-li1e with NRC and industry j guidelines on shutdown operations and will provide nore flexibility for refueling i outages without compromising plant safety. Implemenu+ ion of these c'.anges effectively amends previous submittals to the NRC on shutco . operations (Ref 6),

l however, such changes are allowed under 10 CFR 50.59 as outlined in NRC l

correspondence 3, (Ref 2) on the same subject.

i The current criteria for reduced inventory at St. Lucie Plant is the RCS level W scale low on the pressurizer with the reactor vessel cbsure head in-place or the refueling canal below 45' elevation. The industry definition is different.

Similarly, procedural restrictions at St. Lucie Plant currently limit draining the
RCS until 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> after shutdown. The industry has various time restrictions for j the same evolution.

i

Reduced Inventory Criteria i; l P

Generic Letter Si ..  : concerned with the Diablo Canyon event of April 10, 1987. I

This event occurred at mid-loop. There is ne definition of REDUCED INVENTORY within

' this document. Generic Letter 88-17 was concerned with loss of Decay Heat Removal Capability that could occur during various plant operating conditions includi a condition they define as REDUCED INVENTORY. Enclosure 3 to GL 88-17 deftmas

! INVENTORY as "An RCS inventory that results la a reactor vessel water level lower than three feet below the RV flange." This deftattion allows for draising the acs

! and for detensioning the reactor vessel closure head studs without the restrictions L associated with REDUCED INVENT 0RY e NUMARC forised ar. advisory comunittee made up of over 30 industry representatives involved with the operation, design and maintenance of nuclear power plants. This cosunittee developed guidelines (IRMARC gl-06) issued in December 1991.

Additionally, all utilities were required to implement the guidelines for any refueling outage which would occur after 1992. Both St. Lucie and Turkey Point Plants issued letters confirming this commitment. NUMARC 91-06 defines REDUCED i INVENTORY as a "PWR condition with fuel in the reactor vessel and level is lower i than three feet below the reactor vessel flange." This definition is in agreement l with the level specified by the NRC.

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' JPN-PSL-SENP-94-02  !

REVISION O j PAGE 6 OF 13 l i- '

1 i l i Following the issuance of Generic Letter 88-17 and the NUMARC Guidelines, the 1

procedures and operator training concerned with reduced inventory and loss of i l shutdown cooling were revised. Low Mode Off-Nermal Operating procedures were l
developed to cover the broad range of plant conditions that could be encountered and i to provide methods to recover the critical safety functions including RCS and core ,

i decay heat removal. These procedures instruct the operators that upon the loss .I

! shutdown cooling coincident with high RCS temperature or RCS level below the

! centerline of the hot leg, to increase the RCS level. Charging pumps, taking i suction from the RWT or the VCT, are preferred followed by the HPSI pumps and the  ;

LPSI pumps taking suction from che RWT. The recovery actions following a loss-of,-

shutdown-cooling event involves increasing RCS level then aligning the shutdown

, cooling system for operation. These actions are not dependent on t S initial RCS l l level.  :

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l Time After Shutdown Limit on Drainina the RCS j Draining the RCS to mid-nozzi,e has time limits which arc based on containment .

! closure capability. A review of Enclosure 2 to GL 88-17 provides guidance to I i licensees on determining restrictions for draininy ;ne RCS. A summary of the NRC's l guidance is as follows:

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1) The containment can remain open provided that closure can be accceplished l within 21/2 hours of the initial loss of decay heat removal capability, l
2) The 2 1/2 hours requirement is replaced by 30 minutes (W) or 45 minutes (CE) if openir- "taling greater than one square inch exist in the cold legs, reactor %.+4 pumps and cross over pipes of the RCS. This 30 or 45 minute time requirement may be increased to see hours if a vent path from the upper RV is provided which is sufficiently large such that core uncovery cannot i occur due to pressusIzation resulting from boiling in the core.

i 3) Implement procedures and administration controls that reasonably assure that l containment closure will be achieved prior to the time at which core uncoven could result from a loss of DR coupled with an inability to initiate t alternate cooling or addition of unter to the RCS inventrM.

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! The St Lucie response to the Generic Letter stated that procedures 'will be revised i to provide more in-depth instructions for the operators' use in tha event of 2 loss of snc. These procedures will providt for containment closure prier to een boiline l caused by a loss of SDC and containment closure will be established by providing at l least ene integral barrier to the release of radioactive material. This response is

! much more conservative than the NRC's request in that the time to core bot'.ine can

! be as soon as 20 minutes while core uncovery can occur as soon as 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The i NRC's basis is that containment closure is to be accomplished prior to core uncovery and the beginning of a major release potential.

i NUMARC 91-06 guidance concerning containment closure is as follows; "Dering shutdown

! plant conditions, it is necessary to ensure that CONTAIMENT CLOSURE can be achieved i in suffi-lent time to prevent potential fission product release." Thus, both NRC  !

and NUMARC guidenca docun nts provide the basis for contr.inment closure time as the j time to core uncovery.  !

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) Thermal hydraulic analysis (Ref. 8) was performed in support of Generic Letter 88-

17. It determined that St Lucie Plant is capable of closing containment within 30 i minutes. Figure 1 (attached) provides Time to Boil Vs Days After shutdown. Using l the 30 minute containment closure time criteria, approximately 5 days after shutdown or 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> is obtained. This is the basis in the St Lucie Plant procedures.

Figure 2 (attached) provides the Time to Core Uncovery Vs. Time After !ihutdown. i Using the criteria in GL 88-17, containment cicsure within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of ' oss of SDC. g'  ;

value as low as 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> followina shutdown is obtained. l This safety evaluation involves an assessment of changes to shutdown operations, and therefore, is classified as safety related.

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REVISION 0 l

PAGE 8 OF 13

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l l 2.0 LICDISINE REGUIRDelT5 l

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I NRC/FPL Corresoondence i I The NRC issued two Generic Letters (GL) which addressed low power and shutdown plant  !

- operating states. These were GL 87-12 (Ref II, Loss of Residual Heat Removal (RHR)

While the Reactor Coolant System (RCS) is Partially Filled, dated July 9,1987 and l i GL 88-17 (Ref 2), Loss of Decay Heat Removal, dated October 17, 1988. FPL provided 1 1 responses (Ref 6 & 7) signeci under FO.54(f) wh',ch was found by the NRC to meet the i

intent of their request. The proposed t. hanger outlined in this safety evaluation are

consistent with the guidelines contained in the GLs. GL 88-17. Enclosure 2, j discusses use of 10CFR50.59 to affect changes without prir NRC aporov.~.

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Technical Specifications j There are r.o Technical Specifications involved with either the definition of REDUCED i INVENTORY or containment closure criteria. These items are a result of NRC generic

! correspondence. NUREG 1432, Standard Technical Speci'f .ations - Combustion i Engineering Plants was reviewed and these terms or criteria are not part of the standard technical specifications.

t f.EE The FSAR was reviewed and there are no references to the subject criteria for shutdown operations

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REVISION O PAGE 9 OF 13 l

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i 3.0 ANALYSIS OF EFFECTS ON SAFETY t

The most limiting failure mode for shutdown operations is the loss of decay heat rencval. The change in the criteria for REDUCED IWYENTORY to the NRC and industry  :

standard does not change the previously evaluated failure modes for the loss of i decay heat removal capability. The change does reduce the time to core boiling.  :

however, this reduction is offset by implementation of procedures which provide the recovery actions necessary to respond to the loss of shutdown cooling. As discussou previously, the recovery actions following a loss of shutdown cooling involve increasing RCS level then aligning the shutdewn cooling system for operation. These actions are not dependent on the i..itial RCS level. The new criteria for reduced inventory does not affect any of the initiating ever.ts nor any of the recovery actions for a loss of shutdown cooling. -

The change in the criteria for containment closure is based on being able to close the containment prior to the onset of fission product release from the RCS. 5t Lucie Plant is capable of containment closure within 30 minutes. This capability exceeds the NRC and industry guidelines of containment closure within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following the loss of shutdown cooling. Thus, the new criter.ta for the ties after shutdown limit on draining the RCS based on core uncovery is conservative and more in-line with the NRC and industry guidelines of achtu ;.eg containment closure prior to fission product release.

4.0 FAILURE N0 DES AN EFFECTS ANALYSIS The proposed changes are bounded by the failure modes and effects analysis in the 4.3 & 9.3; Ref 14. Sections 5.4 & 6.3). The effects of the FSAR(Ref13,SecP changes on the pla . - we reviewed in Section 3 and new failure modes are not created.

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6.0 EFFECT ON.TECiff! CAL SPECIFICATIONS There are no Technical Specifications affected by the proposed changes as outlined in Section 2. This evaluation does not require any change to the Technical Specifications.

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JPN-PSL-SENP-94-029 REVISION 0

PAGE 10 OF 13 i

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7.0 UNREVIEWED SAFETY 00ESTI_0N DETERMINATION j i

In accordance with 10 CFR 50.59, the responses to the below listed questions serve  ;

to detemine if the proposed changes to the criteria (A & B) for shutdown operations j

constitutes an unreviewed safety question:

l 1 7.1 Do the proposed changes increase the probability of occurrence of an accidc.a

{ previously evaluated in the SMt i

A & B) The probability of occurrence of an accident previously evaluated in the SAR has not been increased. The proposed changes do not affect any accidents discussed in the SAR. ,

7.2 De the proposed changes increase the consequences of an accident previously

} evaluated in the SMt i

1 A & B) The consequences of an accident previously evaluated in the SAR have not been increased. This evaluation does not affect any of the accidents discussed in the SAR and therefore does ..ct increase any of the consequences-of the accidents discussed in the SAR.

I 1.3 De the proposed changes increase the probability of an occurrence of a l nalfunction of equipment inpertant to safety previously evaluated in the SMT s

i A) The probability of occurrence of a malfunction of equipment important to i safety previously evaluated in the SAR has not been increased by reducing the i RCS water inventory to 3 feet below the reactor vessel flange because this i

l water lev above the mid-nozzle of the hot leg.. The probability of i

occurrence imid not be affected until the RCS water level reached the mid-

) nozzle elevation.

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i B)- The change probability in the criteria'for of occurrence contatament of/a malfunction closure previously of equipment does not changecanyi evaluated 3 g?

t i in the SAR. ^ -

i 7.4 De the proposed changes increase-the cansequences of a anifenction of' equipment tapertant te safety previensly evaluated in the SART

)

i 1 A) Adopting the Reduced Inventory deffettien established by the letC la i Generic Letter 88-17 does not increase the consaquences of a malfunction of 1 equipment important to safety since the loss of shutdown cooling event was

! previously evaluated and the results of that evaluation remain valid.

)

I B) The proposed change in the containment closure criteria provides for

containment closure prior to core uncovery following a loss of shutdown i cooling event. Therefore, the consequences from the previously evaluated loss

{ of shutdown cooling event remain valid.

4 i 1.5 Do the proposed changes create the possibility of an accident of a different j type than any previously evaluated in the SM7 ,

j A) The proposed chat.je to the criteria for Reduced Inventory will not create a i different type of accident than those found in the SAR. The proposed change is i above mid nozzle. The plant can operate safely in Mode 5 at mid-nozzle.

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  • I JPN-psL-5ENP-94-029 REVI5!CN O PAGE 11 0F 13 t

B) The proposed change to the containment closure criteria provides for

! containment closure prior to core uncovery. N rsfore, no different type of I accident is created and the accident assumptions found in the SAR remain 4

valid.

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7.6 00 the proposed changes create the possibility of a anlfunction of epigment f important to safety of a different type than any previously evaluated in the SM7 i A) The proposed ch to the criteria for Reduced Inventory provides adequate margin to prevent loss of'shutdeun cooling due to draining the RCS below i aid-nozzle. The loss of shutdoun cooling is evaluated in the SAR and this change does not alter the assuptions for that evaluation. Therefers a different type of accident is not created by this cha m ,

i j B) The proposed change to the containment closure criteria does not affect i equipment laportant to safety as analyzed in the SAR. This criteria is based

on the ability to provide containment closure prior to core uncovery and j fission product release.

l 1.7 De the proposed changes twduce the margin of scety as defined in the basis i for any Technical Specificattenf 1

l A & B) The proposed changes do not affect any Technical Specification ner de i they reduce any mangins of safety defined by the Technical Specifications.

l The proposed changet incorporate the NRC accepted criteria ar.d definitices.

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  • not adversely affect safe operation of the plant (per j Sections 3 and 4), e not constitute an unrevleued safety question (per Section 7)

. and do not require a change to the Technical specifications (per Section 6) l Therefore, implementation of the proposed changes do not require prior INIC approval.

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d JPN-PSL-SENP-94-0: l 3 REVISION O PAGE 12 0F 13 8.0 ACTIONS REQUIRED /RECOMNDCATICK1 l

1) Revise the operating and administrative procedures to incorporate the new criteria of reduced inventory.
2) Revise the operating and administrai.tve procedures to incorporate the new l criteria for draining the RCS based on the time to core uncovery followie ; . i

' loss of shutdown cooling. l l 3) Provide training on the revised definition and criteria.

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l h0_CONCLUS10M i 1)

The new criteria for reduced inventory would be an RCS level of 3 feet below j the reactor vessel flange. -

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! 2) The technical basis for the time limit pr*v to draining the RCS is contingent

on the time required to achieve containment closure and the corresponding time 1

to core uncovery for the decay heat generated for that specific shutdown.

J (The time to core uncovery could be large for a forced outage following a j

refueling outace with a new core and very b (aecay heat generation.)

f This Safety Evaluation is considered Safety Related since this evaluation involves i! definitions W ariteria used in procedures and programs that govern the operation l' of the reacL. sant system and the decay heat removal capability for the reactor 4 core. Additionally, this Safety Evaluation will be used as a reference for changing existing plant procedures and committaents maos in response to Generic Letter 88-17.

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, REVISION O PAGE 13 OF 13 i j i

10.0 REFERENCES

. l i 1. NRC Generic Letter 87-12, Loss of Residual Heat Removal (RHR) While the Reactor Coolant System (RCS) is Partially Filled, dated July, 9,1987 I 2. NRC Generic Letter 88-17 Loss of Decay Heat Removal, dated October 17, 1988.

3. NUNARC 91-06, Guideline for ledustry Actions to Assess Shutdown Manpt, j dated December 1991.
4. FPL Letter L-87-390, . Generic ' Letter 87-12. dated Septs ber 18, 1987.

! 5. FPL Letter L-88-103, Generic Letter 87-12, dated February 29, 1988.

i 6. FPL Letter L-88-552, Generic Letter 88-17, dated January 1, 1989.

! 7. FPL Letter L-89-38, Generic tetter 88-17, dated February 1,1989.

8. Fuel Resources-NT, FRN-89-088, St. Lucie Units 1 & 2 Thermal Hydraulic
Analysis To support Generic Letter 88-17 " Loss of Decay Heat Removal" dated

! January 29, 1989.

l 9. FPL Letter PTM-VP0-93-002, T. F. Plunkett to M. Schoppaan, dated January 4

! 1993.

l 10. FPL Letter D.' #830-92, D. A. Sager to N. Schoppaan, dated December 18, i 1992.

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11. Administrative Procedure No. 0010145, Rev 5, Shutdoun Cooling Controls, Dated June 23,1993, e . r.. s
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12.' Adelaistrative Procedure No. 0005744. Rev 5, Outage !tanagemustfDated Jessary-4Q 25,.1994.

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13. ~ St. Lucie 6ait'1', Updated Final ' Safety Analysis Report, Mt 12.

i i 14. St. Lucie Unit 2. Updated Final Safety Analysis Report, Amendment 8.

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