View source for L-77-197, Proposed Amendment to Facility Operating License DPR-67. Page 3/4 1-26 and Page B 3/4 1-4 Maximum Allowable CEA Drop Time in Specification 3.1.3.4 Is Changed from 3.3 Seconds to 3.0 Seconds

{{Adams
| number = ML18096B491
| issue date = 06/30/1977
| title = Proposed Amendment to Facility Operating License DPR-67. Page 3/4 1-26 and Page B 3/4 1-4 Maximum Allowable CEA Drop Time in Specification 3.1.3.4 Is Changed from 3.3 Seconds to 3.0 Seconds
| author name = Uhrig R
| author affiliation = Florida Power &amp; Light Co
| addressee name = Stello V
| addressee affiliation = NRC/NRR
| docket = 05000335
| license number = DPR-067
| contact person = 
| case reference number = L-77-197
| document type = Letter type:L
| page count = 11
}}

=Text=
{{#Wiki_filter:NRC.roRM 195 (2 78)
U.S. NUCLEAR REGVLATORV COMMISSION d-3 DOCKET N MUSH NRC DISTRIBuTION roR PAn        i'0 DOCKET MATERIAL                          FILE NUMBER FROM:                                      DATE OF DOCUMENT TO Mr. Victor Stello                           FPL                                   06-30-77 Miami, Florida 33101                DATE RECEIVED Robert E. Uhrig                       07-05-77 QNOTORIZED               PROP                  INPUT FORM           NUMBER OF COPIES RECEIVED E     ER 408 C LASS RIG IN Elcopv AL                  IFIE D S(4    ~ED ENCLOSURE DESCRIPTION                                                                     Notorized,06-30-77...Amd'lt to Appendi A, Operatin'g Lidense,PPR-67/Change to Tech Specs..
consisting of Page 3/0 1-26 and Page B 3/4 1-4 concerning The maxim(@ alloqable       CEA drpp time in specification 3.1.3.$ is changed from 3.3 seconds to 3.0 seconds to be','onsistent with the previous 2 pages.                                           performed. accident ahalysis.....-
4 pages PLANT NAME: ST LUCIE jcm 07-06-77 UNIT,g     1 o
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HEINEMAN                       TEDESCO                      ENVIRON ANALYSIS ROEDER                   BENAROYA                      DENTON '& MULLER ENGINEERING                  IPPOLITO ENVIRO TECH ERNST OPERATING REACTORS             BALLARD YOUNG BLOOD BAER VA                           BUTLER                     GAMMILL        2 GRIME CHECK                                                         SI'7E ANALYSIS VOLLMER AT    I                                                       BUNCH ALTZMAN                                                     J ~ COLLINS R TBERG                                                     KREGER EXTERNAL DISTRIBUTION                                          CONTROL NUMBER TIC                                 NSIC REG    IV J HMCHETT 16 CYS ACRS SENT CAT      GO   Y                                                                 77187O284

P. O. BOX   013100, MIAMI, FL 33101 FLORIDA POWER       8 LIGHT COMPANY June 30, 1977
                      ~Regulatory Docket Fjje           L-77-197 Director of Nuclear Reactor Regulation
.Attention: Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. 20555

==Dear Mr. Stello:==

Re:   St. Lucie Unit    1 Docket No. 50-335                  I Proposed Amendment to Facilit   0  eratin License    DPR-67 During a recent NSSS vendor review of the St. Lucie Unit 1 Technical Specifications,      it was noted that the CEA drop time specification is nonconservative with respect to the accident analysis. The specified drop time is <3.3 seconds, whereas the accident analysis assumes a drop time of 3.0 seconds. The discrepancy has had no safety significance because the measured drop times at St. Lucie Unit 1 have all been well below 3.0 seconds (about 2.4 seconds maximum). However, Technical Specification 3.1.3.4 should be amended to be consistent with the accident analysis.
In accordance with 10 CFR 50.30, Florida Power 6 Light Company submits herewith three (3) signed originals and forty (40) conformed copies of a request to amend Appendix A of Facility Operating License DPR-67. The proposed change is described below and shown on the accompanying Technical Specification pages bearing the date of this letter in the lower right hand corner.
Page  3/4 1-26 and  Pa e B   3/4 1-4 The maximum   allowable CEA drop time in Specification 3.1.3.4 is changed from 3.3 seconds to 3.0 seconds to be consistent with the previously performed accident analysis.
The proposed amendment has been reviewed by the St. Lucie Facility Review Group (FRG) and the Florida Power 6 Light Nuclear Review Board (CNRB).        They have concluded   that       it Company is an I
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Director of Nuclear Reactor Regulation Page Two administrative change to bring the Technical Specifications into conformance with the accident analysis and does not involve an unreviewed safety question.
Very  truly yours, Robert E. Uhrig Vice President REU/MAS/cpc Attachment cc:   Mr. Norman C. Moseley, Region XX Robert Lowenstein, Esquire

REACTIVITY CONTROL SYSTEMS CEA DROP TIME LIMITING CONDITION        FOR OPERATION 3.1.3.4 The individual full length (shutdown and control) CEA drop time, from a fully withdrawn position, shall be < '3,0 seconds .rom when electrical power is interrupted to the CEA drive mechanism until the CEA reaches its 90 percent insertion position with:
: a.      T avg-)  515 F, and
: b.      All reactor coolant      pumps  operating.
APPLICABILITY:        HOOE   3.
ACTION:
: a.      With the drop time of any full length CEA determined to exceed the above limit, restore the CEA drop time to within the above limit prior to proceeding to MODE 1 or 2.
: b.   . With the CEA drop times within limits but determined at less than full reactor coolant flow, operation may proceed provided THERMAL POWER is restricted to less than or equal to the maximum THERMAL POWER level       allowable for the reactor coolant pump combination operating       at the time of CEA drop time determination.
SURVEILLANCE RE UIREMENTS 4.1.3.4     The CEA drop time of      full  length CEAs  shall be demonstrated through measurement prior to         reactor  criticality:
a ~     For all    CEAs  following  each removal  of the reactor vessel head,
: b.      For  specifically affected individual CEAs following any main-tenance on or modification to the CEA drive system which could affect the drop time of those specific CEAs, and C.      At least once per 18 months.
ST. LUCIE     -  UNIT  1                 3/4 1-26

~ 'r REACTIVITIY CONTROL SYSTEMS BASES 3/4.1.3    MOVABLE CONTROL ASSEMBLIES     Continued protective system would not detect the degradation in radial peaking factors and since variations in other system parameters (e.g., pressure and coolant temperature) may not be sufficient to cause trips, it is possible that the reactor could be operating with process vari'ables less conservative than those assumed in generating LCO and LSSS setpoints.
Therefore, the ACTION statement associated with the large misalignment of a CEA requires a prompt and significant reduction in THERMAL POllER prior to attempting realignment of the misaligned CEA.
The ACTION statements applicable to misaligned or inoperable CEAs include requirements to align the OPERABLE CEAs in a given group with the inoperable CEA. Conformance with these alignment requirements bring the core, within a short period of time, to a configuration consistent with that assumed in generating LCO and LSSS setpoints. However, extended operation with CEAs significantly inserted in the core may lead to perturbations in 1) local burnup, 2) peaking factors and 3) available '-
shutdown margin which are more adverse than the conditions assumed to exist in the safety analyses and LCO and LSSS setpoints determination.
Therefore, time limits have been imposed on operation with inoperable CEAs to preclude such adverse conditions from developing.
Operability of the CEA position indicators (Specification 3.1.3.3~
is required to determine CEA positions and thereby ensure compliance with the CEA alignment and insertion limits and ensures proper operation of the rod block circuit. The CEA "Full In" and "Full Out" limits provide an additional independent means for determining the CEA positions when the CEAs are at either their fully inserted or fully withdrawn positions.
Therefore, the ACTION statements applicable to inoperable CEA position indicators permit continued operations when the positions of CEAs with inoperable position indicators can be verified by the "Full In" or "Full Out"  limits.
CEA positions and OPERABILITY of the CEA position indicators are required to be verified on a nominal basis of once per 12 hours with more frequent verifications required     if an automatic monitoring channel is inoperable. These verification frequencies are adequate for assuring that the applicable LCO's are satisfied.
The maximum CEA drop time   permitted by Specification 3.1.3.4 is-the assumed   CEA drop  time of 3.0  seconds used in the accident analyses.
Measurement with Tav ~ 515'F and with all reactor coolant pumps operating ensures that the measured drop times will be representative of insertion times experienced during a reactor trip at operating conditions.
B 3/41-4

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SAFETY EVALUATION Introduction This evaluation supports a proposed change to the maximum allowable CEA drop time specified in Technical Specification 3.1.3.4.
Discussion As discussed  in the cover letter, Specification 3.1.3.4 should be changed-to  be consistent with the accident analysis.       No equip-ment  related changes are  necessary,  so the  amendment. will not affect the probability  or  consequences  of  equipment   malfunctions.
Neither will  it affect the probability or consequences of hypo-thetical accidents because we are using the existing accident analysis as the basis for administrative correction of a Technical Specification. Also, there is no decrease in safety margin because the proposed change is in the conservative direction.
Conclusion Based on these  considerations, (1) the proposed change does not increase the probability or consequences of accidents or mal-functions of equipment important to safety and does not reduce the margin of safety, therefore, the change does not involve an unreviewed safety question, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

STATE OF FLORIDA      )
                      )     SS ~
COUNTY OF DADE        )
Robert E. Uhrig, being    first    duly sworn, deposes and says:
That he is a Vice President of Florida Power                      6   Light    Company, the Licensee herein; That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best, of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.
Robert E. Uhrig Subscribed and sworn to before        me    this ctay oa                                    19~7 NOTARY P    BLIC, in and for  t  e  County        of   Dade, State of Florida                     IOTARY PUBLIC STATE OP FLORIDA aI LARGE hIY CON~!SSIOII   EXPIRES   hIAY BQIIDED QIRII BIAYIIARQ BOIIOuYG My  .commission expires:                                                AGENCY

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