3F0996-14, TS Change Request 206 to License DPR-72,revising Engineered Safeguards Actuation Sys Automatic Actuation Logic. Certificate of Svc Encl

TS Change Request 206 to License DPR-72,revising Engineered Safeguards Actuation Sys Automatic Actuation Logic. Certificate of Svc Encl

ML20129E128
Person / Time
Site:	Crystal River
Issue date:	09/23/1996
From:	Beard P FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20129E134	List: 3F0996-14, TS Change Request 206 to License DPR-72,revising Engineered Safeguards Actuation Sys Automatic Actuation Logic. Certificate of Svc Encl ML20129E137
References
3F0996-14, 3F996-14, NUDOCS 9609300302
Download: ML20129E128 (5)

Text

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.9 Florida Pswer crystal S Unk 3 Decket No. 56 382 September 23, 1996 3F0996-14 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Technical Specification Change Request No. 206, Revision 0 Engineered Safeguards Actuation System Automatic Actuation Logic

Dear Sir:

Florida Power Corporation (FPC) hereby submits Technical Specification Change Request No. (TSCRN) 206 requesting amendment to Operating License No. DPR-72.

This change request deletes a note for the Surveillance Requirement for the Engineered Safeguard Actuation System Automatic Actuation Logic. This change is necessary because the existing note is not appropriate for the conditions that exist during the test.

Revised basis pages are also included, i

Sincerely, P. M.

Deard,

Jr.

Senior Vice President Nuclear Operations Attachments PMB:AEF xc: Regional Administrator, Region II l

Senior Resident Inspector

& Ij NRR Project Manager 300084

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CRYSTAL NVER ENERGY COMPLEX

• 16760 W. Power Line Street

• Cryotel River

• Floride 34428-6708 * (904)796-6486 A Nome horrens Company 9609300302 960923 PDR ADOCK 05000302 P

PDR

'U. S. Nuclear Regulatory Commission 3F0996-14 Page 2 ATTACHMENT TO LETTER NO. 3F0996-14 STATE OF FLORIDA COUNTY OF CITRUS P. M. Beard, Jr. states that he is the Senior Vice President, Nuclear Operations for Florida Power Corporation; that he is authorizer' on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

P. M. Beard, Jr.

Senior Vice President Nuclear Operations Subscribed and sworn to befo e me, aJotary Public in and for the State and County above named, this day of SEftFMMW

, 1996.

LYM S Sm1rH V/khhE Notary Public (print)

No ry Public Notary Public, State of Florida at Large, My Commission Expires:

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'U. S. Nuclear Regulatory Commission 1-

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UNITED STATES OF AMERICA j

NUCLEAR REGULATORY COMISSION IN THE MATTER

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DOCKET NO. 50-302 FLORIDA POWER CORPORATION 1;

l CERTIFICATE OF SERVICE P. M. Beard, Jr. deposes and says that the following has been served on the Designated State Representative and Chief Executive of Citrus County, Florida, by deposit in the United States mail, addressed as follows:

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Chairman, Administrator, Board of County Commissioners Radiological Health Services of Citrus County Department of Health and Citrus County Courthouse Rehabilitative Services Inverness, FL 34450 1323 Winewood Blvd.

Tallahassee, FL 32301 1

A copy of Technical Specification Change Request No. 206, Revision 0.

J FLORIDA POWER CORPORATION i

i P.M. Bhard, Jr.

Senior Vice President Nuclear Operations SWORNTOANDSUBSCRIBEDBEFOREMETHISbfr DAYOF[F#Th7178tL,1996 i

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U. S. Nuclear Regulatory Commission 3F0996-14 Page 4 FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302/ LICENSE NO. DPR-72 REQUEST NO. 206 REVISION O ENGINEERED SAFEGUARDS ACTUATION SYSTEM AUTOMATIC ACTUATION LOGIC LICENSEE DOCUMENT INVOLVED: Technical Specifications PORTION:

Surveillance Requirement 3.3.

7.1 DESCRIPTION

OF REQUEST:

SR 3.3.7.1 The NOTE preceding the Surveillance Requirement is deleted.

REASON FOR REQUEST:

The NOTE states:

"When an ESAS automatic actuation logic matrix is placed in an inoperable status solely for performance of this Surveillance, entry into associated Conditions and Required Actions may be delayed for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, provided the associated ES function is maintained."

Because of the design of the Engineered Safeguards Actuation System (ESAS) and the way the CHANNEL FUNCTIONAL TEST is performed, maintenance of the " associated ES function" is not possible.

When the automatic actuation logic for a particular function is placed in " test," for either the "A" or "B" ES train, the associated components for that train are blocked from actuation in response to a valid automatic or manual actuation.

Thus, the NOTE, as currently written, does not provide the relief intended.

EVALUATION OF REQUEST:

Performance of the CHANNEL FUNCTIONAL TEST for the ESAS automatic actuation logic is done by ES function.

During the test, that function is bypassed while the actuation matrices are tested.

The three ES functions tested (high pressure injection, low pressure injaction, and reactor building isolation and cooling) are tested separately.

During the time they are bypassed, the associated end devices will not respond to either an automatic or manual actuation of the ESAS function. Deleting the Note will eliminate possible confusion over the need to enter the applicable Condition.

The Required Action for Condition A of the Specification ("One or more automatic actuation logic matrices inoperable") allows one hour to place the component (s) in the ES configuration or declare them inoperable.

This time is adequate to complete testing of the individual test groups, including the time needed to assess potential equipmert failures. In the event of a failure of an individual ES actuation matrix, the affected equipment is placed in the ES configuration or declared inoperable until repaired while the remaining matrices are returned to an OPERABLE configuration.

' U. S. Nuclear Regulatory Commission 3F0996-14 Page 5 SHOLLY EVALUATION OF REQUEST:

Florida Power Corporation (FPC) has reviewed the requirements of 10 CFR 50.92(c) as they relate to the proposed deletion of the NOTE for SR 3.3.7.1 (Engineered Safety Features Actuation System Automatic Actuation Logic CHANNEL FUNCTIONAL TEST) and considers the proposed change does not involve a significant hazards consideration.

In support of this conclusion, the following analysis is provided:

1.

The proposed change will not significantly increase the probability or consequences of an accident previously evaluated because unavailability of equipment is recognized in the design of the plant and in the Technical Specifications.

The probability and consequences of accidents previously evaluated are bounded by the evaluations done for the allowed outage time of the associated functions.

2.

The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because the bypassing of ES functions for testing purposes does not place the plant in a configuration which would allow the possibility of a new or different kind or accident to be created.

3 The proposed change will not involve a significant reduction to the margin of safety because deleting the NOTE does not effect the way the test is performed. The test is required by the Technical Specifications and will still be performed in the same manner.

Thus, there is no change in the unavailability of the system as a result of this change and the margin of

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safety is not reduced.

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