ML17349A521

Proposed Tech Specs 3/4.4.4 & 3/4.4.9.3 Re Relief Valves & Overpressure Mitigating Sys,Respectively

ML17349A521
Person / Time
Site:	Turkey Point
Issue date:	11/25/1992
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17349A520	List: ML17349A519 ML17349A521
References
NUDOCS 9212040263
Download: ML17349A521 (27)

Text

Attachment 2 to'-92-285 Page 1 of 9 TECHNICAL SPECIFICATIONS:

3/4.4.4 RELIEF VALVES 3/4.4.9.3 OVERPRESSURE MITIGATING SYSTEMS INTRODUCTION Florida Power & Light Company has determined that these amendments involve a "no significant hazards consideration" determination by application of regulatory standards contained in 10 CFR 50.92. This determination ensures that 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, (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.

The Nuclear Regulatory Commission has provided guidance concerning the application of these criteria by publishing examples (51 FR 7751) of amendments which are considered not likely to involve a Significant Hazard. Example (ii) relates to a change which constitutes an additional limitation, restriction or control not presently included in the Technical Specifications.

DESCRIPTION OF PROPOSED CHANGES Technical Specification 3/4.4.4 RELIEF VALVES Action statement a. includes the requirement to maintain power to block valves closed to isolate PORVs with excessive seat leakage because removal of power would render the block valves inoperable, and the requirements of action statement c. would apply. Power is maintained to the block valve(s) so that it operable and may be opened subsequently to allow use of the PORV is for reactor pressure control or decay heat removal. Closure of the block valve(s) establishes reactor coolant pressure boundary integrity in the case of a PORV with excess leakage. (Reactor coolant pressure boundary integrity takes priority over the capability of the PORV to mitigate an overpressure event.)

This is a new action statement which constitutes an additional restriction not presently included in the Technical Specifications.

Action statements b. and c. include removal of power from a closed block valve to preclude inadvertent opening of the block valve isolating inoperable PORVs. (In contrast, action 9212040263 92l125 PDR ADQCK 05000250 P PDR

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to'L-92-285 Page 2 of 9 statement a. is intended to permit continued plant operation for a limited period with the block valves closed, i.e., continued operation is not dependent on maintenance at power to eliminate excessive PORV leakage. Therefore, action statement a. does not require removal of power from the block valve.) These are new action statements which constitute additional restrictions not presently included in the Technical Specifications.

Action statement d. establishes remedial measures consistent with the function of block valves. The most important reason for the capability to close the block valve is to isolate a stuck-open PORV. Therefore, if the block valve(s) cannot be either closed or restored to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the remedial action is to place the PORV in manual control within the next hour to preclude its automatic opening, and thus avoid the potential for a stuck-open PORV at a time when the block valve is inoperable. The time allowed to restore the block valve(s) to operable status is consistent with the existing action statement and is based upon the remedial action time limits for inoperable PORVs per action statements b. and c.

This action statement is revised to add additional restrictions not presently included in the Technical Specifications.

Additional editorial changes are proposed to clarify the intent of the Limiting Condition for Operation consistent with the Generic Letter 90-06 guidance and to maintain administrative consistency within the Turkey Point Technical Specifications.

Technical Specification 3/4.4.9.3 OVERPRESSURE MZTZGATZNG SYSTEMS With one PORV inoperable, the allowable outage time (AOT) is 7 days only in Mode 4, with an additional 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided for depressurization and venting of the RCS. In Mode 5, or in Mode 6 with the reactor head on, the AOT of a single inoperable PORV is reduced to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with an additional 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (for a total of 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />) provided for depressurization and venting of the RCS. These action statements are revised to add additional restrictions not presently included in the Technical Specifications.

Additional editorial changes are proposed to clarify the intent of the action statements consistent with the Generic Letter 90-06 guidance and to maintain administrative consistency within the Turkey Point Technical Specifications.

Bases PPL proposes to make changes to the Bases for Technical Specifications 3/4.4.4 consistent with the proposed Technical Specifications changes. The revision to the Bases provides additional clarification to the proposed Technical Specifications changes.

to'L-92-285 Page 3 of 9 NO SXGNIFXCANT HAZARDS CONSIDERATION DETERMINATION Technical Specification 3/4.4.4 Relief Valves Limitin Condition for 0 ezation (1) Does operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

The FPL proposed changes include changing the word "each" to "both" in reference to the two PORVs, and adding "and their associated" to expand the Technical Specifications to include both the PORVs and the block valves. These proposed changes are in accordance with the GL recommendations. This proposed is editorial in nature and does not presentchange an increase in the probability or consequences of an accident previously evaluated.

(2) Does operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change is editorial in nature and is in accordance with the GL recommendations. The proposed change does not impact plant equipment or change the operation of the facility. Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Does operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

The proposed change is editorial in nature and is in accordance with the GL recommendations. The proposed change does not impact the safety analysis results as presented in the FSAR or the Technical Specifications, therefore, operation of the facility in accordance with the proposed amendment does not involve a reduction in a margin of safety.

Action Statements Action Statements a b c and d:

Action statement a. proposed by FPL is consistent with the GL recommendations and results in additional restrictions not presently included in the Technical Specifications.

Action statements b, c, and d proposed by FPL differ from the suggested action statements in GL 90-06. The

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to L-92-285 Page 5 of 9 been previously evaluated and is not a new or different kind of accident. The proposed changes will not result in the PORVs or block valves being operated or used in a new or different manner. Therefore, the possibility of a new or different kind of accident is not created.

(3) Does operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

Operation of the facility in accordance with the proposed amendment does not involve a significant reduction in a margin of safety. Overall plant safety would be enhanced as a result of the additional restrictions placed on PORVs and block valves.

Technical Specification 3/4.9.3 Overpressure Mitigating Systems Limitin Condition for 0 eration Does operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

The FPL proposed change adds the statement "(below an RCS average coolant temperature of 275'F)" defining more specifically the applicability statement for Mode

4. The proposed change is editorial in nature and is consistent with the current Turkey Point Technical Specifications. Therefore, operation of the facility with the proposed amendment does not present an increase in the probability or consequences of an accident previously evaluated.

(2) Does operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change is editorial in nature and is consistent with the current Turkey Point Technical Specifications. The proposed change does not impact plant equipment or change the operation of the facility. Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Does operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

The proposed change is editorial in nature and is consistent with the current Turkey Point Technical

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Attachment to'L-92-285 Page 6 of 9 2

t Specifications. The proposed change does not impact the safety analysis results as presented in the FSAR or the Technical Specifications, therefore, operation of the facility in accordance with the proposed amendment does not involve a reduction in a margin of safety.

Action Statements Action Statement 3.4.9.3.b Does operation of the facility in accordance with the proposed amendment involve a significant increase in the pzobability or consequences of an accident previously evaluated?

FPL proposes to revise this action statement consistent with the GL recommendations. The FPL proposed change also adds the statement "(below an RCS average coolant temperature of 275'F)" defining more specifically the applicability statement for Mode 4. The proposed change is editorial in nature and is consistent with the current Turkey Point Technical Specifications.

Therefore, as previously determined by the NRC in GL 90-06, this proposed change does not present an increase in the probability or consequences of an accident previously evaluated.

(2) Does operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change is in accordance with the GL recommendations. The proposed change does not impact plant equipment or change the operation of the facility. Therefore, as previously determined by the NRC in'GL 90-06, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Does operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

The proposed change is in accordance with the GL recommendations. The proposed change does not impact the safety analysis results as presented in the FSAR or the Technical Specifications, therefore, operation of the facility in accordance with the proposed amendment does not involve a reduction in a margin of safety.

Action Statement 3.4.9.3.c Does operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident

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~J J to'-92-285 Page 4 of 9 differences are that the action statement time limits for 3.4.4.b, 3.4.4.c and 3.4.4.d are different in that they permit operation with one inoperable PORV or block valve as long as the associated block valve is closed with power removed from the block valve. Also, with both PORVs or block valves inoperable, it allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore at least one PORV or block valve to OPERABLE status or to close the associated block valve with power removed from the block valve, and allows 30 days to restore at least one PORV or block valve to operable status'1)

Does operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

FPL has performed plant 'specific analyses for feed and bleed using the MAAP 3.0B Computer Code, Rev. 16, for Turkey Point using a combination of best estimate and conservative analysis assumptions. These analyses show that feed and bleed is achievable using a single PORV, provided that it is opened within a certain time frame.

Availability of the PORVs and block valves for feed and bleed does not represent a high sensitivity in reference to the total core melt frequency. This is primarily due to the diverse sources of feedwater available, including three steam driven auxiliary feedwater pumps and two electric driven feedwater pumps. Brief periods of unavailability of feed and bleed will have little impact on the plant's total core melt frequency. Therefore, a 30 day action statement for a single inoperable PORV is considered acceptable. These same arguments apply to the block valves.

Operation of the facility in accordance with the proposed amendments does not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed amendments place more stringent Limiting Conditions for Operation on the facility. These include new and/or shorter allowable outage times for PORVs and associated block valves.

(2) Does operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Operation of the facility in accordance with the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. With the exception of a failed-open PORV, resulting in the equivalent of a small-break LOCA, the PORVs and block valves cannot initiate accident sequences. The case of a failed-open PORV has

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to'-92-285 Page 7 of 9 previously evaluated?

FPL proposes to include this action statement consistent with the GL recommendations. Addition of the words "with the reactor vessel head on," clarifies the MODES 5 or 6 condition of applicability consistent with the current Turkey Point Technical Specifications and in accordance with the GL recommendations. This action statement is revised to add additional restrictions not presently included in the Technical Specifications. Therefore, operation of the facility in accordance with the proposed change does not present an increase in the probability or consequences of an accident previously evaluated.

(2) Does operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change is in accordance with the GL recommendations. The proposed change does not impact plant equipment or change the operation of the facility. Therefore, possibility of it does not create the a new or different kind of accident from any accident previously evaluated.

(3) Does operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

The proposed change is in accordance with the GL recommendations. The proposed change does not impact the safety analysis results as presented in the FSAR or the Technical Specifications, therefore, operation of the facility in accordance with the proposed amendment does not involve a reduction in a margin of safety.

Action Statement 3.4.9.3.d Does operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change is editorial in nature to maintain consistency with the GL recommendations and the Turkey Point Technical Specifications format. The time to complete depressurization and venting of the RCS with both PORVs inoperable has been maintained at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to allow for an orderly depressurization. This is consistent with the current Turkey Point Technical Specifications. FPL also proposes to add the words "either restore one PORV to operable status or" to provide additional clarification and consistency in format with the other action statements. This proposed

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to'-92-285 Page 8 of 9 change is editorial in nature, therefore, operation of the facility in accordance with the proposed amendment does not present an inczease in the probability or consequences of an accident previously evaluated.

(2) Does operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

This proposed change is editorial in nature, therefore, operation of the facility in accordance with the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed changes will not result in the PORVs or block valves being operated or used in a new or different manner. Therefore, the possibility of a new or different kind of accident is not created.

(3) Does operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

This proposed change is editorial in nature, therefore, operation of the facility in accordance with the proposed amendment does not involve a reduction in a margin of safety.

Action Statement 3.4.9.3.e Does operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

This proposed change provides additional clarification to the requizements for the submittal of a Special Report. The proposed change is editorial in nature and does not present an increase in the probability or consequences of an accident previously evaluated.

(2) Does operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change is editorial in nature and does not impact plant equipment or change the operation of the facility. Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Does operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

to'L-92-285 Page 9 of 9 The proposed change is editorial in nature and does not impact the safety analysis results as presented in the FSAR or the Technical Specifications, therefore, operation of the facility in accordance with the proposed amendment does not involve a reduction in a margin of safety.

Based on the above, and on supporting technical justifications, Florida Power & Light Company has concluded that there are no significant hazards considerations involved in this amendment request.

ATTACHMENT 3 TO L-92-285 Proposed Changes to Turkey Point Units 3 and 4 Operating Licenses DPR-31 and DPR-41 Page 3/4 4-10 Page 3/4 4-36 Page 3/4 4-36a (New)

Page B 3/4 4-3 Page B 3/4 4-3a (New)

Page B 3/4 4-3b (New)

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REACTOR COOLANT SYSTEM 3 4.4.4 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.4 Botg power-operated relief valves (PORVs) an'd.;"::?)+~he:'::.":r".

gssss'O'cjoy't$ d block valvem shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

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al'at)'i:ng,!,;:HL}h'anbt's':. A}XA~}}'a"A 'VW The provisions of Specification 3.0.4 are not applicable. TURKEY POINT UNITS 3 & 4 3/4 4-10 AMENDMENT NOS. AND

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REACTOR COOLANT SYSTEM OVERPRESSURE MITIGATING SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.9.3 The high pressure safety injection flow paths to the Reactor Coolant System (RCS) shall be isolated, and below an RCS average coolant temperature of 275'F at least one of the following Overpressure Mitigating Systems shall be OPERABLE: a) Two setting of power-operated 415 + 15 relief valves (PORVs) with a psig, or lift b) The RCS depressurized with a RCS vent of greater than or equal to 2.20 square inches. APPIICABILITY: MODES 4 ((h ela e!Bgefan::,:"YR,dS!~:::::::.i:,i,enrage)""i': aaaLneen

                                       ,gamp'i'i~a vie.,~,"';.".c"f:,,'";::"!2475.'"'F)'., 5, and 6            with the reactor vessel head on.

ACTION: a ~ With the high pressure safety injection flow paths to the RCS unisolated, restore isolation of these flow paths within 4 hours. b.

            ,e'j:":,x?&RAN>;.",:.:.'>!':hoQL"..S~j v    IPh'(PNNehYP(h'NshhNhhhveNNhnwkh44      v WNaith'Xn"Ya'.":.":,t'Ot'aI Ahh      ~h4h4'NCVhWhYhNVhh4VAA       i;:;.Of::::i: ':.".'4:".;hOu'iS'5 eNYihhhhNW      hh'ehVhVh Nhh4 With both                     PORVs          inoperable                    e'xthe~Pr'est';or'ej;:in'eajPORO,,::sE'o OP,;:;:gthe@RCS,.;:e4hxou+h! 'a't""1'east'"'8":""2"::20'::'::'8qj6'8're'"':."iYCh:.,:.;,.:.:veht
                )%D .C~4@Nh:A             'BW AAN4 Zn      the event either the                                     PORVs or a 2.20 square inch vent is      used        to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days.                                                                   The report shall TURKEY POINT  UNITS 3                          6    4            3/4 4-36              AMENDMENT NOS.                  AND

~ c REACTOR COOLANT SYSTEM OVERPRESSURE MITIGATING SYSTEMS LIMITING CONDITION FOR OPERATION Continued describe the circumstances initiating the transient, the effect of the PORVs or RCS vent(s) on the transient, and any corrective C .~ )sVNPN M'M)'ri M~ NCCC Vh' action necessary .P')4 to

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                                                                            . ~                 prevent IAWJ+Og+ .. MgN '%'h recurrence.
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p'ii'riy'ciiri~'ri"'i'!))riiii~i'i"'ri'i'iizi'i'oj'~iiSi%'e'ii;!j'g't'ai'ii'!9"' Th'ri~i))'vari))3!s i:ciri'rishi'io8!!s'ari)riri),.riii'ria't')ririo;::;:!0!!ri)~)ri)!rid~.'rio~t:::-riT)p3Rrii81ri:';) TURKEY POINT UNITS 3 & 4 3/4 4-368; AMENDMENT NOS. AND

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1 1 r I ~ e {" 0 REACTOR COOLANT SYSTEM BASES 3 4.4.4 RELIEF VALVES The opening of the no safety-related power-operated function and no credit is taken for their relief valves (PORVs) fulfills operwation in the safety analysis for MODE 1 2 or 3. E'ej6'ipeiPag limyl't~e'dI,'to,::,:,:aau:::,:::bO:::::.:'po}{ei:::::::::sacvurche:;::::i) Each pORV has a remotely operated block valve to provide a positive shutoff capability should a PORV

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A'Ah~~.VhhhAAYAV%~&A~~~AWAhh~AAR> h >WY TURKEY POINT UNITS 3 & 4 B 3/4 4-3I AMENDMENT NOS . AND

REACTOR COOLANT SYSTEM BASES RELIEF VALVES (Continued) TURKEY POINT UNITS 3 & 4 B 3/4 4-3$ AMENDMENT NOS . AND

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