ML20207J161
| ML20207J161 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/25/1988 |
| From: | Edison G Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC-63038, TAC-63039, NUDOCS 8808300265 | |
| Download: ML20207J161 (14) | |
Text
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August 25, 1988 Docket Nos. 50-250 DISTRIBUTION and 50-251 MM S. Varga NRC & Local PDRs NRC Participants P022 Reading ACRS (10)
LICENSEE:
Florida Power and Light Company H. Berkow B. Troskoski G. Edison G. Lainas FACILITY:
Turkey Point Units 3 and 4 OGC-Roc kville E. Jordan
SUBJECT:
SUMMARY
OF MEETING HELD WITH FLORIDA POWER AND LIGHT COMPANY (FP&L) ON AUGUST 18, 1988 REGARDING TECHNICAL SPECIFICATIONS CONVERSION
REFERENCE:
TAC Numbers 63038 and 63039 A meeting was held in Rockvillo, Maryland on August 18, 1988 with representa-tives of Florida Power and Light Company (FP&L) to discuss details of their Technical Specifications Revision Project.
This project is a voluntary effort by FP&L to upgrade their approved Technical Specifications (TS) towards Standard TS to the extent practical.
An initial proposal was submitted by FP&L to the NRC staff on September 29, 1986, followed by the electrical portion on November 28, 1986, with the expectation that detailed discussions with the staff would result in substantial changes to the proposal, and therefore result in a completely revised submittal for NRC staff review.
Previous meetings on this subject were held November 18, 1986, June 17 and 18, 1987, January)9, February 23, and (1
FP&L's ef forts to provide Mdrch 28, 1988.
This recent meeting focussed on:
comment on the staff's "Proof and Review" draft of revised TS, (2) the process for resolution of differences that may arise, and (3) the process for completion of the TS revision and issuance of a license amendment.
FP&L indicated that they have formed a special team to increase their effort on the TS Revision Project.
The licensee stated they would propose a new plan in early September 1988 for completion of the project. Within a week or two j
of this meeting, the first portions of their comments on the "Proof and Review" draft will be provided to the NRC staff, and the complete formal submittal will be made by September 23, 1988. Any additional comments related to the technical basis for the revised TS will be incorporated into a "Final Draft" submittal following the proof and review phase.
FP&L stated they will not attempt to incorporate into this project any new standard TS that might be developed by the nuclear power industry during the next year or so.
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[l 8808300265 880825 DR ADOCK 0500 go
., A meeting agenda, attendance list, and FP&L handout materials from the meeting are' enclosed.
Gordon E. Edison, Sr. Project Manager Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation
Enclosures:
As stated
.cc w/ enclosures:
See next page kW D:[p1b-LA (1-2' PM:PDII-2 DM fr GEd on:bg HBer Ww 8
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Mr. W. F. Conway Florida Power and Light Company Turkey Point Plant cc Harold F. Reis, Esquire Administrator Newman and Holtzinger, P.C.
Department of Environmental 1615 L Street, N.W.
Regulation 1
Washington, DC 20036 Power Plant Siting Section State of Florida Mr. Jack Shreve 2600 Blair Stone Road Office of the Public Counsel Tallahassee, Florida 32301 Room 4. Holland Building Tallahassee, Florida 32304 Regional Administrator, Region II U.S. Nuclear Regulatory Comission John T. Butler, Esquire Suite 2900 Steel, Hector and Davis 101 Marietta Street 4000 Southeast Financial Atlanta, Georgia 30323 Center Miami, Florida 33131-2398 Attorney General Department of Legal Affairs Mr. J. Odom, Vice President The Capitol Turkey Point Nuclear Plant Tallahassee, Florida 32304 Florida Power and Light Company i
P.O. Box 029100 Plant Manager
. Miami, Florida 33102 Turkey Point Nuclear Plant Florida Power and Light Company P.O. Box 029100 County Manager of Metropolitan Miami, Flurfua aotue Dade County 1
Hiami, Florida 33130 Resident Inspector U.S. Nuclear Regulatory Comission Turkey Point Nuclear Generating Station Post 0.'fice Box 57-1185 Miami, Florida 33257-1185 l
Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.
Tallahassee, Florida 32399-0700 Intergovernmental Coordination and Review Office of Planning & Budget Executive Office of the Governor The Capitol Building Tallahassee, Florida 32301
[
ENCLOSURE 1 FPL/NRC MEETING AUGUST 18, 1988 AGENDA i
1.
FPL PROCESS FOR PROOF & REVIEW COMMENTS 2.
INFORMATION NEEDED FOR PROOF & REVIEW COMMENTS 0
LEVEL OF DETAIL FOR COMMENT JUSTIFICATION (EXAMPLES) o FORMAT (MARKUP WITH SEPARATE JUSTIFICATION) 3.
RESOLUTION OF COMMENTS o
NRC COMMENT RESOLUTION o
MEETINGS TO RESOLVE FPL COMMENTS o
NRC TECHNICAL SUPPORT AT REVIEW MEETINGS o
PROCESS FOR RESOLUTION OF ITEMS THAT CANNOT BE RESOLVED BY WORKING GROUP (FPL/NRC TSCB) 4.
INFORMATION NEEDED TO PLAN FOR SUBMITTAL o
LEVEL OF DETAIL IN CURRENT SUBMITTAL o
DESCRIPTION OF CHANGES o
NO SIGNIFICANT HAZARDS EVALUATION
ENCLOSURE 2 ATTENDEES AT NEETING I
August 18, 1988 NAME ORGANIZATION 1.
G. E. Edison NRC/NRR 2.
H. N. Berkow NRC/NRR 3.
V. A. Kaminskas FP&L 4.
J. C. Balaguero FP&L 5.
B. P. Burdic,k FP&L 6.
T. C. Grozan FP&L 7.
J. Arias, Jr.
FP&l, 8.
C. Moon NRC/NRR/E0EA/0TSB 9.
E. Butcher NRC/NRR/E0EA/0TSB
- C. Christensen (Region II) participanted via telephone.
1
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ENCLOSURE 3 I
O HAND 0UT 1 0F 4 APEw INTER 4FFICE CORRESPOf.DENCE To:
Distribution LOCATION:
W JB FROM:
y, p, g gy DATE:
August 11, 1988 l
SUSJECT: r g g I}gp g COPIES TO:
K. N. Harris
'I1XHTICAL bFELmCM'ICH HnTBCP C. O. Woody
'Ihe purpose of this letter is to define the program being irplemented for capletion of the Revised 'Ibchnical Specification (RPS) project.
As dimM in the August 4, 1988 meeting at Turkey Point, two teams have been formed to support this effort.
'Ihe caposition and objectives of each team, as well as the efforts required by other organizations to support these teams, is described below.
'Ib caplete the FPL review and ensure cxzpleticn of the RIS project a team has been established on a full time basis with the following membership:
Project}% nager:
J. Arias, Jr.
Member:
J. C. Balaguero (Plant 'Ibchnical)
J Mecber:
B. P. Burdick (JPE)
Mmber:
V. A. Kaminskas (Plant Operations)
Member:
P. L. Pace (JNE)
'Ihe objectives of the RIS Team will be to:
1.
Resolve FPL internal omments en }mC's Proof an:1 Review h unt.
2.
Brief Executive Oversight Ctanittee cm current status prior j
to Septa ber NRC meeting.
i 3.
Identify the cbjectives for the early Septaber meeting with the NRC.
4.
Establish a schedule, by the early part of Septaber, for i
RIS capleticn.
5.
Review RIS to ensure their ocosistency with PIN design (technical / accuracy / adequate justification).
7.
Issue cxzposite set of FPL Proof and Review mar.s to the NRC by Septaber 23, 1988.
'Ihis may include partial issuance of w&&s as they are caplei:ed.
8.
Pmolve FPI/NRC ccr.ments en Proof and Review with the NRC.
9.
Prepare sutnittal of license amendment to NRC.
'Ihis will incitrie representaticn at REC and OmB.
10.
Make m - -endations for irplementing the RIS (including training).
11.
Monthly meetings (rcre often if rmiad) with tha Executive Oversight Camittee to resolve key issues.
an FPL Group company
,.,,,, s oos m.m a... sise
PIN Pefised TS Project Pace two To provide ranagement guidance and direction to this project an Executive Oversight Ctzmittee has been established with the following membership:
Chairman:
J. S. Odca Member:
D. A. Sager (JNE Staff)
Member:
J. E. Cross (Plant Management)
Member:
J. B. Hosmer (JF2)
Meter:
J. K. Hays (JNL)
Member:
F. H. Southworth (Plant Technical)
The objectives of the Executive Oversight Ccemittee will be to:
1.
Review and a@ rove the RIS Team objectives.
2.
Review aM disposition the RIS Team's r+>-.-andations on key issues.
3.
Meet with NRC Management to resolve issues that cannot be resolved through workirg level negotiations.
4.
Provide resources for the RIS effort.
5.
Advise senior management of the project status.
6.
Provide feedback to the RIS T4am cm senior level d%=ioru with the NRC as they relate to the RIS project.
This comittee will meet as pa'a===_ry to acomplish these objectives.
In addition to the primary representatives cm the RIS Team, additional personnel will be. responsible to provide support in certain areas of expertise.
h individuals will be contacted by team members regarding th6 review su@ ort required and the methods the team will use to nsolve cau.inrus in their areas of expertise.
These individuals aM their assigned areas are as follows:
lax: lear Fuels:
D. C. Peteralski Quality Assurance:
L. W. Bladow Fire Protectico:
R. W. Kenmer Instrumentation & Centrol:
D. J. Tcnaszawaki Electrical Maintenance:
M. Wayland Trainirg:
T. A. Finn Mechanical Maintenance:
J. C. Strong The overall theme of the RIS project is to provide Turkey Point with revised Technical Specifications that are technically acx: urate aM issued in a timely fashico.
We have ocmmitted to provide FPL's cxmments on the NRC's Proof and Review version of the Technical Specifications by Septaser 23, 1988.
The smaful cxmpletion of this project will require the dedicated effort of these teams and the involved departments.
W.
Senior Vice President - lhx: lear
PIN Revised TS Project Pace th WEC/ PIP /gp Distribution: RDS Team 14anhars Doecutive Oversight nemsnittee 14seham Support ca* Eta C. A. INill PIN Superinterdents JNE Staff Managers 1
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HAND 0UT 2 0F 4
.g.rsmd os/i7/ss
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START l
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Accepts Return to Team reviews Comments / Justification Department RTS H eadl lupt.
and comments for signatvre i
D Rejects g.
AC:epts Comment /
Return to Comments N/
Reject justification Department Head
) y I
request further justification m
Accepts "T
4 Rejection Notity Y
STOP Department 1 -
I!ead Approval by Department Head / Supt.
Appeal l
Department Rejects Team m
Head discuss reviews with Team Accept Document Reject Comment /
Superintendent u
m Justification Approval 7
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Chain i
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Command NRC
HANDOUT 3 0F 4
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t kri,Lc Ud Eis, kPL Cuwwnturr/ Jump.
N ADMIRT TRATIVE C
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f 6.1 RESPONSIBILITY
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6.1.1 The Plant Manager - Nuclear shall be responsible for overall unit opera-tion and shall delegate ia writing the succession to this responsibility during his absence.
6.1.2 The Plant Supervisor - Nuclear (or during his absence from the control room, a designated individual) shall be responsible for the control room con-mand function.
A management directive to this effect, signed by the Site Vice' President - Nuclear Energy shall be reissued to all station personnel on an annual bas 4.
6.2 ORGANIZATION ONSITE AND OFFSITE ORGANIZATION ArS An onsite and an offsite organization shall be xbl.....d
'zation shall\\orfacilit E
6.2.1 operation and corporate management.
The onsite and offsite orgar include the positions for activities tffe_cting the safety of the nuclear power P '" '
( sA M O A ntvi G W 3
)4g a.
Lines of authority, responsibi1 Tty and communiifation lshall be a
established and defined from the highest management evels through
/
interwediate levels to an including all operating organization positions.
Those relationships shall be documented and updated, as appropriate, in the fore of organizational charts.
These organiza-tional. charts will be documented in the Topical Quality Assurance Report and updated in accordance with 10 CFR 50.54(a)(3),
b.
The Senior Vice President-Nuclear shall be responsible for overall plar,t nuclear safety, and shall take any seasures needed to ensure acceptable performance of the staff in operating, maintaining, and p oviding technical support to the plant to ensure nuclear safety, c.
The Plant Manager-Nuclear shall be responsible for overall unit safe operation and shall have contaol over those onsite activities necessary for safe operation and maintenance of the plant.
d.
Although the individuals who train the operating staff and those who carry out the quality assurance functions may report to the appro-priate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.
e.
Although health physics individuals may report to any appropriate manager onsite, for satters relating to radiological health and safety of employees and the public, the health physics manager shall _
have direct access to that onsite individual having responsibility for overall unit sanagement.
Health physics personnel shall have the authority to cease any work activity when worker safety is jeopardized or in the event of unnecessary personnel radiation w
k exposures.
c SA 44YVWftSoff' G @-
TURKEY POINT - UNITS 3 & 4 6-1
TECH SPEC: M JUSTTFICAT10N:
1)
".'his is sample justification #1.
2)
This is sample justification #2.
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NO SIGNIFICANT HAZARDS EVALUATION PROPOSED TECHNICAL SPECIFICATION TITLE:
RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION - LOW WATER LEVEL N0:
3/4.9.8.2 A.
DESCRIPTION OF CHANGES 1)
Present Condition of License:
As described in the current Turkey Point Unit 3 and 4 Technical Specification in Specification 3.10.7.2, Table 4.1,2 Item 18 and 83.10.7.
2)
Proposed Condition 4 License:
a.
The amendment consolidates the current requirements into this specification and explicitly states the LC0, APPLICABLE M00ZS, ACTION Limits and SURVEILLANCE REQUIREMENfS.
b.
The revision ish than the current Technical Specification as foTlows:
The surveillance requirement in the revision specifies verification that RHR loop circulation flow is at least 3000 gpm.
The current Technical Specification specifies verification of flow but does not specify a value.
The circulation flow which is an alarmed parameter has been exchanged for core outlet temperature which does not alann in the control room.
c.
The revision the folicwing current requirement:
The frequency of monitoring the RHR cooling system operation has been decreased from every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
C.
BASIS FOR N0 SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION:
The standards t ed to arrive at a proposed determination that the changes descr, bed above involve no significant hazards consideration are included in 10 CFR 50.92.
The regulations state that if operation of the facility in accordance with the proposed amendment would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety, then a no significant hazards detennination can be maJe.
App. B 3/4 9-18
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Proposed Tech Spec. No. 3/4.9.8.2 The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve a significant hazards consideration.
Example (i) relates to a purely administrative change to Technical Specifications:
for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature.
Example (ii) relates to a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications for example, a more stringent surveillance requirement.
1)
The proposed change as described in Item 2.a is similar to example (i) of 48 FR 14870 in that it is an admin jtrative change which consolidates current requirements into a technical specification fonnat consistent with the Standard Technical Specifications and does not involve technical or plant modifications.
2)
Tne proposed change as described in Item 2.b is similar to example (ii) of 48 FR 14870 in that it provides additional information by including the required minimum flow from the RHR cooling loop which is an alarmed parameter.
3)
The proposed change to relax the time interval for checking RHR loop cooling operability does not involve a significant hazards consideration because this change would not:
a)
Involve a significant increase in the probability of or consequence of an accident previously evaluated.
By exchanging the temperature measurement for the alanned flow measurement to determine operability of the required RHR loop the probability of losing RHR cooling without being noticed by the operator is less.
The low flow alarm will alert the operator to investigate and restore cooling.
Increasing the surveillance time interval is justified by the continous monitor provided by the low flow alarm.
b.
Create the possibility of a new or different kind of accident from any previously analyzed because the proposed change l
introduces no new mode of plant operation nor involves a i
physical modification to the plant.
1 c.
Involve a significant reduction in a margin of safety because one method of monitoring RHR cooling capability is being exchanged for another and is consistent with industry practice in that it is the same as Standard Technical Specifications.
App. B 3/4 9-19
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Proposed Tech. Spec. No. 3/4.9.8.2 Based on the above considerations the changes included in the development of proposed Technical Specification 3/4.9.8.2 are considered not to involve a significant hazards consideration as defined in 10 CFR 50.92.
Further, there is reasonable assurance that the health and safety of the public will not be endangered by the propc' sed changes.
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