ML20138G413
| ML20138G413 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point  |
| Issue date: | 11/12/1996 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hebdon F NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20137Q937 | List: |
| References | |
| FOIA-96-485 NUDOCS 9611270038 | |
| Download: ML20138G413 (6) | |
Text
{{#Wiki_filter:T ! Y November 12, 1996 MEMDRANDUM T0: Frederick J. Hebdon. Director Project Directorate II-3 Division of Reactor Projects I/II Orig signed by Ellis W. Merschoff FROM: Ellis W. Merschoff. Director Division Reactor Projects Region II
SUBJECT:
TASK INTERFACE AGREEMENT (TIA-019) CONCERNING DISCREPANCIES BETWEEN THE CONTAINMENT RADIATION MONITORING SYSTEM DESCRIBED IN THE UPDATED FINAL SAFETY ANALYSIS REPORT (UFSAR) AND REGULATORY GUIDE 1.45 AT ST. LUCIE UNITS 1 AND 2. AND TURKEY POINT UNITS 3 AND 4 Your technical assistance is requested to evaluate discrepancies between the Containment Radiation Monitoring system design described in the UFSAR at St. Lucie and Turkey Point and guidance provided by Regulatory Guide (RG) 1.45.
" Reactor Coolant Pressure Boundary Leakage Detection Systems."
ST. LUCIE On October 30. 1990. the NRC accepted Topical Report CEN-367. " Leak-Before-Break Evaluation of Primary Loop Piaing in Combustion Engineering Designed Nuclear Steam Supply Systems." whic1 was submitted for staff review by Combustion Engineering Owners Group (CEOG) letter, dated November 20. 1987. ~ However, the NRC also required that licensees referencing CEN-367 as a technical basis for applying leak before-break (LBB) to primary loop piping, also submit information to demonstrate that leakage detection systems installed at the specific facility are consistent with RG 1.45. On August 26, 1992, the licensee submitted a letter to the NRC. seeking approval to eliminate the dynamic effects associated with high energy piae rupture in the reacter coolant system piping from the licensing and design 3ases of St. Lucie l Units 1 and 2 by applying the (LBB) technology documented in CEN-367. As l required. the licensee also stated in their submittal that the leakage i detection systems on both units were consistent with the recommendations of ' Regulatory Guide 1.45. As a basis for this statement, the licensee referenced the original Safety Evaluation Reports (SER) for each unit which documented acceptance of the system design (See Attached). While inspecting the Unit 1 Containment Radiation Monitoring system the inspectors identified several discrepancies between the UFSAR and the guidance provided in RG 1.45 that were not addressed in either the licensee's submittal or the subsequent SER. RG 1.45 states that all detector systems should respond to a one gpm. or its equivalent, leakage increase in one hour or less. Unit 1 UFSAR states that a one gpm leak is said to be " identified" when a ten percent deviation in the normal readings of the various monitoring systems occurs. The amount of time for this deviation to occur with the containment radiation monitor is 15.1 hours and 18.1 hours for the noble gas and
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3. F. Hebdon 2 Turkey Point The inspectors reviewed licensee calculation JPN-PTN-SEIP-94-039. Safety Evaluation for Containment Airborne Radiation Monitors R-11/R-12 ESF - . Setpoints, to determine licensee methodology for calculating alarm setpoints l' for containment particulate and gaseous radiation monitors. R-11 and R-12. Particularly, the inspectors were interested in the capability of containment [ monitors. R-11 and R-12. to detect Reactor Coolant System (RCS) leakage. Based on the information provided by the licensee. including calculation JPN- ' PTN-SEIP-94-039, the inspectors could not ascertain how the Regulatory Guide 1.45. Reactor Coolant Pressure Boundary Leakage Detection Systems, criteria which recommends that detection capability for an RCS leakage of one gallon i per minute in one hour was met. Further. the inspector was provided correspondence from the NRC to FPL dated November 28. 1988. This letter - concerned Generic Letter 84-04. Asymmetric LOCA and it stated that the leakage detection system had a required sensitivity capable of detecting 1 gpm leak in four hours. The inspectors questioned the applicable leakage criteria at Turkey Point. Consequently, the licensee generated condition report 96-1184. to address - inspector questions. Initial calculations by the licensee, assuming 1% failed i fuel and a one gallon per minute leak, determined.that the R-11 monitor would alarm within the one hour, and the R-12 monitor would alarm within four hours. Pending further licensee review as well as NRC review, this issue is ' considered as an Unresolved Item (URI) 50-250.251/96-10-02. Reactor Coolant , System Leakage Detection. Question Does the Staff consider the system described in the UFSAR consistent with RG 1.45?- Please do not hesitate to contact Joel Munday or Mark Miller at St. Lucie !
-and Binoy Desai or Thomas Johnson at Turkey Point. of my staff, with any ,
questions you may have regarding this issue. 1 Dockets: 50-335 and 50-389 50-250 and 50 251
Attachment:
As stated arfftt h stGNAtuRE hemt $kirm DATE [11' / . / 96 11 / / 96 11 / / 96 11 / / 96 11 / / 96 11 / / 96 COPY? Yl1 NO [ YES) NO VES NO VES NO VE5 NO VES N0 urt ALIA mund LUFY Q J1.h4 AAMt; 6;\iiAsseir.h w 1 a
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' l REACTOR COOLANT PRESSURE BOUNDARY l . LEAKAGE DETECTION SYSTEnts A. INTRODUCTION imings Separasion !
i A linked amount of leakage is espected from,the i General Design Criterion 30," Quality of Reactor Coolant Pressure Boundary," of Appendix A to 10 RCFB ud from ' auxiliary systems within the CFR Part 50, " General Design Criteria for Nuclear contaimnent such as from valve stem packms glands, l circulating pump shaft seals, and other egepment 'Ast Power Plants," requires that means be provided for : i detecting and, to the extent practical,ideatifying the cannot practicauy be made 2005 leaktight. The ressser location of the sowce of rescior coolantleakage.This vessel closure seals and safety and relief valves shculd J l guide describes acceptsble methods of imi dementing not leak significantly; however, if leakage occurs via this requirement with reptd to the selection ofleakage thsee paths or via pump and valve semis,it should be , detectable and collectable and, to the antent practscal, ) i detection systeena for the reactor coolsat possure boundary. This guide apples to light.wster<ooled isolated froan the metainment atmosphem so as not to ! mask any potentinDy serious leak diodd it occas. j r ea ct ors. The Advisory Committee on Reacter Safeguards has been consulted concerning this guide "these leakages are known as " identified leakage" and and has concurred in the regulatory position. shodd be piped to tsnks or sumps so that the flow l rate .cm be estabhshed and monitored dwmg plaat S. DISCUSSION operation. The safety signinance of leaks from the reactor Uncollected leakage to the containment suolant pessure boundary (RCPB) can very widely atmosphem from sources such as valve stem podmg dependmg on the source of. Ahe leak as well as the glands and other sources that are not cellected leakap rate and duration. Therefore, the detection and increases the hunidity of the contamment. 'fhe moisture removed from the atmosphere by air coolers ! monitoring of leakap of reactor coolant into the together with any assocsated ligiad leakage to the ; contamment area is necessary. In most cases, methods ] containment is known as " unidentified leakage" and for separating the leakage from an identified source from the leakage from an unidentified source are should be co5ected in tanks or sumps where the l'ow i necessary to provide prompt and quantitative rate can be established and monitored durag p ast mformation to the operators to permit them to take operation. A smau amount of unidentified leakage tasy imme diste corrective action should a leak be be impractical to eliminate, but it should be redu:ed ! detrimental to the afety of the facility. Identifled to a anall flow rate, peferably less than one gaDon per : leakap is: (1) leakage into cloesd systems, such as minute (gym), to permit the leakap detection systeas pump seal or valve packing leaks that are captured, to detect positively and rapdly a snau increase in flow ; now metered, and conducted.to a sump or couecting rate. Thus a manB uudentified leaksy rate that s. of tank, or (2) leakap into thepntainment atmosphere macern wSI not be masked by a laryr acceptable from sources that are both, identified leakage rate. 4 known either not to interfere,specificallywith the opersuonlocated of and unidentified leakage monitoring systems or not to be Substantial interrystem leakage from the RCPP to l from a flew in the RCPB. Unidentified leakap is a5 other systems across passeve barners or valves is not j other leakage. expected. However, should and leakage occur, it :ney ew a.-=a ed unnec naeutatony eusese c * .m m == = -.e i a ~.==cw . . Illl1.". E'" '"e*"d"" " "
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! aut be 1 detectable throgh tho' above. mentioned methods differ in sensitivity and response time, prudent 4 de esthm systems, and other alarm and detectnam asiscuan of detection methods shouldinclude sufficient neesluis diould he employed. For esasaple, eseam geacrasor irakap m pressurtred water teactors (PWR's) systems to assuso effective monitoring during penods
< dould he memitored to deteci tube ar tube sheetleaks, when sonne detection systems may be ineffectne or inoperable.Some of these systems should serve as early alarm systems apalms the operators that closer Asesetshie Desenteen asseheds emansnation of other detection systems is riecessary to l determsme the essent of any corrective action that er:sy i Ahhough momtonne of both identified and .) besegdsed. , j etandentified Isakage is important, effective syntanes for
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detectuig and locating unidentified leakags see also Duessear aansttMty needed. The followns parayaphs descrbe asme acorptable deteceson seethods. It is euential that leakage detection systems have j la addition to nionitoring flow reis changes to tanks the capebsity Io detect significant RCFB depadation as soon after occwience as practical to snuunuse the j- and semps for bquid ootection, other snsthods should potential for a pass boundary faGute, it is passable that he indaded to indkuse wines and wisse coolant is some cracks might develop and penetrate the RCPB wou, released to the cautainment atmaphase. Por saample, enkbit very slow powth, and efford ample tune for a theer adetional doesction methods would indeste enfe and orderly plant shutdown after a leak is detected. 1 mad /or sannster dianys in: ' l On the other hand, leakage such as that roulting from
- s. airborne particulate reeanctMey, strouMundsted corrosion in ===l== siest or from a flaw
< b. mir6 eras gaseous resoectMty, 3 at a high datigue point in the RCFB would demand raped l c. containment r / 7 besiety, detection and probable plant shutdown. Therefore, an
- d. centsinment atmosphere preuma's and teenerretime, .
andy wendag agnal is neccesary to perwat poper oudstion of as umidentified leakser.
- s. condensate flow rete inns air coolnes, Sees interrystem leakage does not rdamse reactor ladustry practace has shown that weer fic= rete j
Sundant to the contaisonnent sumosphere, detection changes of froen 0.5 to 1.0 sysn can readily be driected methods should include monitoring of* water in contahumant sumps by saasutonsg chasses m sump [ , raeanetMty in the consweted sysseme where the water level,in flow rete, or in the operstang frequency of systems flows through the ===8====* boundary,and pump. Samp and tanks used to couset unmientified mamsesrig of airborsie radioactMey where nedt spsamme leakage and air cooler condensate aboidd be , see rested outsade the containement bountry. Ascabar hatrumented to sienn for increases of frame 0.5 to 1.0 e mportsat method of obtahdas laecutions of simi in the mennel flow rates. This sensstivity would astonesvaned er undedrehte lasersystes. flow would be provide as neceptable perfornance for detecting the ese of a water inventory bahnee, designed to provide increment hi unidentified liquid leeksgr by thss smethod. appoprimer information ass as absonnel weaur is,els in ' As iussense in hurnadity of time contentnent temks sud absorsaal water flow rate. stamphase wedd indscote reasses of water vapor to the Pusentaal dascharps froen closed afety and relief somed====% Dow point temperenne msennemems can ! he used to monitor huseidky levais of time contmansem vulies ese unmauy piped to tasks er water pools and assusemed part e( identined isshags. Tasaparatee
~ .' - A 1* Inerosse in dew poess is well withan the seemitssety remos espebiitty of available istruments.
sensers in the 6schup pah of afety and edis(values Snes the huseety level in Amflisenced by several factors, i ur flow insters in the lenk<offlimas weeld poiles as a aleamstette eseletion of en adicated leakage rate acswesable method of spalhas ensu laskap fross these may be gunstionable and should be compared to seemes. ehearsed immesses in hqad flow from asnps and l Whee the abovementioned lashap detection , esademmte Aus from air coolers. Husudity triel menisertug h emmedered most useful as sa alarm or syseemis reflect J the pesant sense of tedinoingy, k is e g smand that asher deteeman assheds susy he ledheet ietssthe devior to alert the operstar to a l potential pehlem. eles'tsped and used in order to ehtain operettag esp.nsase web these. Ameses sansk smashads are semic indentes and masture sensitive tapes appued to RCFB Ramster cooient normally contaans sources of aanpumma parts. Desesse af the passettel importness reestnam whish, wtwn released to the contaanment. can
- of essly leek detecteam ts the of ==da==== be esassend by the monnorms systeses. However, nasammed uupeesmanes in ama sea == sed senser eschant resoectivtty should be low dunas estini l~
lasses sectuuques emed be ses@t. sonster startey and for a few weeks therefter unti settveted emessaism poducia have base formed and I8 ** m* acessesey that eB of the shese meme===d canon peducts become available frosa faded fuel l - lahage dewson aseheds er tyeneses be magioged in a eissnents, desing that period. radaosetmty morutarms 1 i I45a2 ] I f _ _ _ _ - . - - -i
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. mnerumouls inay he of lumled value m poviding an Signol Correisaien seed Calibressen carly warmng of very small lanka in the RCPB. I s instrument scnutmiles of 10* pCi/cc radmactivity fo' It is important to be able to asociate a sgnal nr '
inlicatiosi of a change in the normal siperasing
.m particulate moriitorirg arid of 104 uCJcc !
radunicalvity for todmps monitoring are practical fo' conditions with a quantitative leakage Ild* ' ate.15cri alic c leakage - detecima systems. Radioactivity for flow rete or level change measurements from Links. nowulorms systems should be included for every piant sumps, or pump, signals from other Icakage detectam (espe 66 ally particulate actmty monitormg) because of - systems do not provule information reashly enueveihl*
- their sensiemiy and rapid response to leaks from the to a commun denonunstor. Appros maic relatamdisp* !
converting these signals to umas of water flow sould he l RCP8. formulated to sasist the operator in interpretmg signals. 3 2 Since operstmg conditions may influence aume of the
. Air iemperature and pressure morutoring methods conversion procedures, the procedures diould be revised t may also .be med to mfer RCPB leakap to the during such patiods. To assure the coetmund rehabdity containment. Contam, ment temperature and pressure of the leakage detection systens, the eqmpment should fluctuate slightly during plant operation, but a rise tbove comply with Paragraph 4.10 of IEEE Std. 279 1978. t the normally indicated range of values may indicate .. Criteria for Protection Systems for Nuclear Poorer '
j RCPB leakap mto the contamment.The accuracy and Genereung Stations,"' for tests and calibration. i reievance ut ternperature and pressure measurements is s' . - funcimn of containment ' free volu,me and detector , g g, g,,,;,, . location. Alarm signals from these instruments can be i valuable in recogmaang rapid and sizable energy releassa Since nuclear power plants may be operatmg at the , to the containment. - tirne an earthquake occurs and may continue to operate after earthquakes, it is prudent to require the leakage detection systems to function under the .same ; Wtule the concern about instrtiment sensitmty conditions, if a sennuc mnt anA m s u l ' of service for whsch the shutdown applies mstrummistoare the lower thrange 'e upper instrument selected. range earthquake -(SSE) occurs. it woulJ ben ; 8mPortant for the operator to aaness the condition wit h . lim:ts should be established /to prevent exceeding the the containment quickly. Tk proper functiomng o a , s.ituration hmits of instruments, thus making them useless as mdicators of contamment conditions.
* '8' wi the iou th nd containment in the event leakage has developed in the i l
< Detecsor Response Time RCPB. The airborne particulate radianctmty morutor:#v
' equipment has the desirable sensitivity to indicate RCPB leakage, and it should be included for all plants The need to evaluate the severity of an alarm or Com nents for the airborne particulate radioactivit) indicahon is important to the operators, and the ability equiPment should be quahfied to function through the ' to compare with mdications - from other systems is SSE.
necesury. The system response time should therefore be meluded m the functional requirements for leakage C. REGULATORY P0g TION sietection systems. Except for the lirmtations durmg the ~ nuinal tew weeks of plant operation. as discussed The source of reactor coolant leakage shouid be prevammly. all detector systems should respond to a one identifiable to the extent practical. Reactor ecolan. h spm. on os equivalent, leakage increase in one hoi.r or less. Multiple in.trument locations in morutored areas pressure boundary leakage detection and collectiot systems should be selected and designed to include the, shoukt he utilized if necessary to assure that the transport delay time of the leakage effluent frorn its I83I** *'8 source to the detector or mstrument location wdl yield
- 1. leakap to the pnmary reactor contamment frorr:
an acceptable everall responsi time. A ureful techmque in identifpr g the generallocation of a leakage area is the identified sources should be ecliected or otherwiec placmg of several sensors within the contamment area isolated so that:
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, Jied observing differences in responte from the se'isors. umdentified leakage, and and this technique should be used to satisfy this requirement of General Desen Critenon 30. b. the total flow rate can be establahed anc
- monitored.
' lo malyrmg the sensiuvHy of leak 'dettetion 1 r
- 2. Leakap to the primary reactor contammerit irorrs 4
9 micm - using ' airborne p.stuculate or gaseous 4.nihuisissiv. a. scahMic primary s;oolant radsoastmty urudentified sources should be collected and the 00* iveni a .C i n .mumpison should be used. The expected iCopies may be obtamed from the insisivie or IIcstics a ues uses m the piant envronmental report would be ,sul Dectrosucs Ens neers. Uruted Ememeering Center. 34) Esot
##dp' 3N' 47th street. New York. N.Y. Innl7 4
I.45 1. 9'
i' _ . . _ ~ o* este emmituesd with sa escuracy of oss piles per employed for unidentified leakap should be adestust to umiute (spm) or better, desset a leakap reas, or 6ts equivelset of oss gpm m teen ' % m u. 7
- 1 At least three esperate detection methods abeuid be
- 6. The leakar detection systems should be capable ul employed and two of these methods should be (1) sump
, Perforsmhg their functions followsig seismsc events that
'Jestead flow monisering and (2) sistoras pensaints sadioactively monteerin6. The third susehod any be de 888 8898888 Pl ant shutdown.The aarborne particulate sodioactivity monstenas system should remain asiected froen the following Asessional when subpected to the SSE.
i s. maastoring of ooedsasete Gour rete tous air coolers,
- 7. ladkators and alarms for each leaksy detection
- b. mon 6toring of airbores goescus redlonestetty.
Huaudity, teasperature, or presse,e snesstertes or system should be provuled in the maan control room. the emessinenset atmosphere should be cosmidored a Proenduses for soevertas various indications to a seamens bekage eganniset ainould be sveitable to the alarms or indsrect indication of leakass es the operaters. The seiltration of the indicators should someneasset. asseunt for sueded ladspondsat vertables.
- 4. Provisons sould be sunde to amaitor sysesas
' 3. The laakses detection systems should be egsopped sumaseted to the ItCPB for mens ofintersyseess tankap. with pnssiskins to % permit testang fa operanty Methods should include radioactivity escattertes and and enh destas plant operatsoa. ,' indicators to show abnormal water levels er Asw is the cffected ares. 9. The technical spec 6Acatens shodd include the hadting conditions for identirsed and unsdentified * . S. The sensitivity and respoems time of aesh laukap isskap and addreas the svadainlity of vanous types of dsecten system in regulatory posettaa 3. shows issanuments to annare adequate coversy at all tarnes.
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I ~:JPN-PSL- ' F4; 110:4Cf?-691-2100 F M .!!E maal P03 (-0? '9510115:0-3 ID:FPL 'IL 4EG a s mees,,g k UNITED STATES I '
% NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 200M.0001
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m ,* SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION , LEAK-BEFORE-BREAK TECHN0tQfd FLORIDA p0WER & LIGHT COMFANY ST.'lVCIE PLANT. UNITS NO. 1'AND 2 DOCKET NOS. 50-335 AND 50-389 INTRODUCTION , i By letter dated August 26, '.992, Florida Power &. Light Company (FPL) proposed to
, eliminate the dynamic effects associated with high energy pipe rupture in the reactor coolant system (RCS) piping from the licensing and design bases of St.
Lucie Units 1 and 2 by the application of leak-before-break (LBB) technology-This change in the licensing and design bases is permitted by revised General Design Criterion 4 (GDC-4) of Appendix A to 10 CFR 50. The revised GDC-4 is based on the development of advanced fracture mechanics technology using the LB3 concept. On October 27, 1987, a final rule was published (52 FR 41288), effective November 27, 1987, amending GDC-4 of Appendix A to 10 CFR 50. The revised GDC-4 allows the use of analyses to eliminate from the design basis.the dynamic effects of postulated pipe ruptures in high energy piping in nuclear power plants. Implementation permits the removal of pipe whip restraints and jet impingement barriers as well as other related changes in operating plants. Although the functional and performance requirements for containments, emergency core cooling systems, and environmental qualification of equipment remain unchanged, local dynamic effects uniquely associated with postulated ruptures in piping which qualify for LBB may be excluded from hthe design basis (53 FR - 11311). DISCUSSION
- On October 30, 1990, the NRC accepted Topical Report CEN-367, " Leak-Before-Bren Evaluation of Primary Loop Piping in Combustion Engineering Designed Nuclear Steam Supply Systems," which was submitted for staff review by Combustion Engineering Owners Group (CEOG) letter dated November 20, 1987. FPL was a participating CEOG member and St. Lucie Units 1 and 2 were included in the ,
bounding analyses submitted. The NRC Safety Evaluationldated October 30, 1990, approving CEN-367, concluded that the subject CEOG priinary loop piping complied with the revised GDC-4 when reviewed according to the~NRC staff criteria. Thus, the probability or likelihood of large pipe breaks occurring in the primary coolant system loops of the applicable CEOG plants is sufficiently low such that dynamic effects associated with postulate.1 pipe breaks need not be a design basis. Licensees - referencing the CE0G topical report, CEN-367-A, as a technical basis for applying LBB to primary loop piping, must submit information to demonstrate thi.t leakage detection systems installed at'the specific facility are consistent with Regulatory Guide 1.45. ATTACHMENT f pgy r gg n 7f l "Cl~TLO i uvv w Q() .
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(-09 '95 r10N 15:05 !D FPL PSL-PEG F M NO:4Q7-691-2200 FAM.itE n441 PO? s 9 2- , 4 Accordingly, to documen't St. Lucie Unit I consistency with Regulatory Guide l 1.45, the licensee submitted the following analysis: !
?
l The plant Technical Specifications provide part of the technical basis for '
; the St. Lucie Unit 1 operating license. Section 3/4.4.6.1 of the Unit 1 Technical Specification bases states ,
i "The RCS leakage detection systems required by this specification are , provided to monitor and detect leakage from the Reactor Coolant Pressure Boundary (RCPBl. These detection systems are consistent with l the recommendations of Regulatory Guide 1.45, Reactor Coolant Pressure l BoundaryLeakageDetectionSystems,May19p." l
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+ The RCS leakage detection systems are described in the Unit 1 FUSAR section 5.2.4. The design was evaluated by the NRC and acceptance is documented in
' the Unit 1 original Safety Evaluation Report, Safety Evaluation of the St. Lucie Plant Unit 1, dated November 8,1974, section 5.3 which states in part: . 1
" ... The airborne particulate radioactivity monitoring system was '
designed prior to Regulatory Guide 1.45 and has not been Otherwise, specifically , > designed to remain functional when subjected to the SSE. ' the leakage leakage detection system proposed to detect leakage from components and piiing of the reactor coolant pressure boundary is in accordance with tie recommendations of AEC Regulatory Guide 1.45. The systems will provide reasonable assurance ... and l l are therefore acceptable with respect to the requirements of AEC j i General Design Criterion 30 and Appendix A of 10 CFR Part 50." In preparation of this, submittal, FPL has reviewed the design of the RCS ' leakage detection systems and reaffirmed the original NRC staff conclusion. Similarly, to document St. Lucie Unit 2 consistency with Regulatory Guide 1.45, the licensee submitted the following analysis: l The plant Technical Spe::ifications provide part of the technical basis for the St. Lucie Unit 2 operating license. Section 3/4.4.6.1 of the Unit 2 i Technical Specification bases states: ) l "The RCS leakage detection systems required by this specification are ' provided to monitor and detect leakage from the Reactor Coolant 4 Pressure Boundary.[RCPB). These detection systems are consistent with ! the recommendations of Regulatory Guide 1.45, Reactor Coolant Pressure i Boundary Leakage Detection Systems, May 1973.* The RCS leakage detection systems are described in the Unit 2 FUSAR section 5.2.5. The design was evaluated and acceptance is documented in the Unit 2 original Safety Evaluation Report, Safety Evaluation Report related to the operation of the St. tucie Plant Unit 2, dated October 1981, section 5.2.5 which states in part: j t
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t JPN-PSL- FA ' ilO:aO7-691-2200 FA LilE 2441 P10 Y-03 '95101 15:06 ID:FPL P!L-FEG ,
... Based on the above, we conclude that the RCPB leakage detection systems are diverse and provide reasonable assurance that primary system leakage (both identified and unidentified) will be detected and meet the requirements of General Design Criterion 30 with respect to -
provisions for RCPB leakage detection and identification, and the guidelines of Regulatory Guide 1.45 with respect to RCPB leakage detection system design and are, therefore, acceptable." In ) reparation of this submittal, FPL has reviewed the design of the RCS lea (age detection systems and reaffirmed the original NRC staff conclusion. The staff finds the above analyses acceptable. The requirements for the leakage detection systems are included in the Technical Specifications for St. Lucie Unit I and Unit 2. The leakage detection systems were evaluated by the NRC during original plant licensing and determined to meet the ' guidelines of Regulatory Guide 1.45. In addition, the NRC has reviewed the leakage detection capability at St. Lucie as part of tne FPL response to NRC Generic Letter 88-05, " Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR plants," which required that licensees address among other things, procedures for locating small coolant leaks (i.e., leak rates at less than Technical Specification limits). CONCLUSION SincetheSt.LucieUnitsare!boundedbytheCEOGana'.ysesandtheleakage detection systems are capable'of detecting the specified leakage rates, the r,taff concludes that the dynamic effects associated w.th postulated pipe breaks in the )rimary coolant systeci piping can be excluded from the licensing and design sases of the St. Lucie Units. Accordingly, the staff grants the request to allow use of LBB technology as part of the bases of design engineering scheduled to begin in 1993. Principal Contributor: Jan Norris Oate: March 5, 1993 f .l e 4
- 2. -
l a , P 0. Box 128. Ft. Pietes. FL 34954-0123 August 26, 1992 ppt L-92-231
. 10 CFR 50.4 l
l U. S. Nuclear Regulatory Commission Attn: Document control Desk i Washington, D. C. 20555 i i i RE: .St. Lucie Units'1 and 2 Docket Nos. 50-335 and 50-389 Application of Leak-Before-Break Technolouv to Reactor coolant System Pinina l Florida Power and Light Company (FPL) proposes to eliminate the l dynamic effects associated with high energy pipe rupture in the i reactor coolant system piping from the licensing and design bases j of St. Lucie Units 1 and 2 by the application of leak-before-break (LBB) technology. This change to the licensing and design bases is . permitted by revised General Design Criterion 4 (GDC-4) of Appendix ; A to 10 CFR 50. l
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Approval is requested by February 26, 1993, to allow use of LBB technology as part of the bases of design engineering scheduled to begin in 1993. On October 30, 1990, the NRC provided acceptance for referencing of Topical Report CEN-367, Leak-Before-Break Evaluation of Primary Coolant Piping in Combustion Engineering Designed Nuclear Steam Supply Systems. CEN-367-A was issued in February 1991. The information requested by the NRC safety evaluation when referencing this topical report lis attached. Please contact us if there are any questions about this submittal. Very truly yours, D. A. .ager Vice esident St. Lucie Plant DAS/GRM/kw s cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL 752-92 na FPt Group semenar
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- St' Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Application of Leak-Before-Break Tachnoloav to Reactor Coolant system Pinina APPLIchTION OF LD_T-BEFORE-BRM_W TEcRNOLN2Y TO ST. LUcIE UNITS 1 AND 2 Z. BACEGROUND l
This change to the licensing and design bases is permitted by revised General Design' Criterion 4 (GDC-4) of Appendix A to 10 CFR-
- 50. .The revised GDC-4 is based on the development of advanced fracture mechanics technology using the LBB concept. On October i
27,. 1987, a final rule was published (52 FR 41288), effective November 27, 1987, amending GDC-4 of Appendix A to 10 CFR 50. The revised GDC-4 allows the use of analyses to eliminate from the design basis the dynamic effects of postulated pipe ruptures in high energy piping in nuclear power plants. Implementation permits the removal of pipe whip restraints and jet impingesent barriers as well as other related changes in operating plants. Although the functional and perfor: nance requirements for centainments, emergency core remain cooling unchanged, systems, and environmental qualification of equipment , local dynamic effects-uniquely associated with postulated ruptures in piping which qualify for LBB may be excluded from the design basis (53 FR 11311). On October 30, 1990, the NRC accepted Topical Report CEN-367, Leak-Before-Break Evaluation of Primary Loop Piping in Combustion Engineering Designed submitted for staff re;. Nuclear Steam Supply Systems, which was
' view by Combustion Engineering Owners Group (CEOG) letter dated November 20, 1987. FPL was a participating CEOG bounding memberanalyses and St. ~ Lucie Units 1 and 2 were included in the subnitted. ~ '
The NRC Safety Evaluation dated October 30, 1990, approving CEN-
'367, concluded that the subject CEOG primary loop piping complied with the revised GDC 4 when reviewed according to the NRC staff criteria. Thus, the probability or likelihood of large pipe breaks r
occurring CEOG' plants the in is primary coolant system . loops of the applicable ~ sufficiently low such that dynamic effects
- i. associated with postulated pipe breahs need not be a design basis.
' Licensees referencing the CEOG. topical report, CEN-367-A, 'as a :
a technical basis for Applying LBB to primary loop piping, must submit : information~ to demonstrate that leakage detection systems , installed at the spec.tfic facility are consistent with Regulatory Guide.l.45.> . 1 I i c y y e-- ------ y ,,3- .-s o r--m -t -
1a . i II. UNIT 1 CONSISTENCY WITH REGULATORY GUIDE 1.45 The plant Technical Specifications provide part of the technical bar's for the St. Lucie Unit 1 operating + license. Section T 3/4,4.6.1 of the Unit 1 Technical Specification bases states:
"The RCS leakage detection systems required by this !
specification are provided to monitor and detect leakage ' from the Reactor Coolant Pressure Boundary (RCPB). These detection systems are consistant with the recommendations 1 i of Regulatory Guide 1.45, Reactor Coolant Pressure . Boundary Leakage Detection Systems, May 1973." j The RCS leakage detection systems are described in the Unit 1 FUSAR section 5.2.4. The design was evaluated by the NRC and acceptance l is documented in the Unit 1 original Safety Evaluation Report, Safety Evaluation of the St. Lucie Plant Unit 1, dated November 8, ) ! 1974, section 5.3 which states in part: ; The airborne particulate radioactivity monitoring system was designed prior to Regulatory Guide 1.45 and has not been specifically designed to remain functional i when subjected to the gE. Otherwise, the leakage ] detection system proposed to detect leakage from-components and piping cf the reactor coolant pressure !. boundary is in accordance with the recommendations of AEC Regulatory Guide 1.45. The systems will provide reasonable assurancia 4
... and are therefore acceptable ' with respect to the requirements of AEC General Design Criterion 30 and Appendix A of 10 CFR Part 50."
' ~ ' - In preparation of this submittal, FPL has reviewed the design of the RCS leakage detection systems and reaffirmed the original NRC staff conclusion. III.
- UNIT 2 CONSISTENCY'WITH REGULATORY GUIDE 1.45 4
The plant Technical Specifications provide part of the technical basis for the St. 'ucie Unit 2 operating license. Section 3/4.4.6.1 of the Unit 2 Technical Specification bases states:
"The RCS leakage detection systems required by this :
specification art provided to monitor and detect leakage from the Reactor Coolant Pressure Boundary (RCPB . These detection systems are consistent with the recomme)ndations of Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leakage Detection Systems, May 1973." ; t ' 2
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The RCS leakage detec. tion systems are described in the Unit 2 FUSAR section 5.2.5. The . design was evaluated and acceptance is documented in the Un t 2 original Safety Evaluation ' Report, Safety Evaluation Report related to the operation of the St. Lucie Plant
- Unit 2, dated October 1982, section 5.2.5 which states in part:
" ... Based on the above, we conclude that the RCPB leakage detection systems are diverse and provide reasonable assurance that primary system leakage (both identified and unidentified) will be detected and meet.
the requirements of General Design Criterion 30 with respect to provisions for RCPB leakage detection and identification, and the guidelines of Regulatory Guide i 1.45 with respect to RCPB leakage detection system design and are, therefore, acceptable." In preparation of this submittal, FPL has reviewed the design.of the RCS leakage detection systems and reaffirmed the original NRC . staff conclusion. 7 IV CONCLUSIONS: ~ The requirements for the leakage detection systems are included in the Technical Specifications for St. Lucia Unit 1 and Unit 2. The leakage detection systems were evaluated by the NRC during original e plant Guide licensing and dotermined to meet the guidelines of Regulatory 1 1.45. In addition, the NRC has reviewed the leakage detection capability at St. lucia as part of the FPL response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in !WR plants, which required . that licensees addrens among other things, procedures for locating small coolant leaks
. Specification limits).
(i.e., leakrates at less than Technical Since the St. Lucie Urits are bounded by the CEOG analyses and the s [ leakage detection sys: ems are capable of detecting the specified 1eakage rate, the dyn..mic effects associated with postulated pipe breaks in the primary coolant system piping can be excluded from the licensing and design bases of the St. Lucie Units. 3 i
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