L-90-353, Documents Written & Verbal Request of Region II Personnel Re Temporary Waiver of Compliance of Tech Spec 3.6

Documents Written & Verbal Request of Region II Personnel Re Temporary Waiver of Compliance of Tech Spec 3.6

ML20062A831
Person / Time
Site:	Turkey Point
Issue date:	09/26/1990
From:	Harris K FLORIDA POWER & LIGHT CO.
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
L-90-353, NUDOCS 9010230164
Download: ML20062A831 (3)

Text

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O P.O. Box 0291D, Miami, FL,33102-9100 i

I 5: P L SEP'2 61990 1

. L - 9 0'-3 5 3 l

Stewart D. Ebneter-Regional Administrator, Region II

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U.

S. Nuclear Regulatory Commission l

101 Marietta St.,

N.W., Suite 2900 Atlanta, GA 30323 I

Mr. Stewart D. Ebneter:

lh Re:

Turkey Point Unit 3 Docket No. 50-250 j

Boric Acid Filter Discharge Isolation Valve 3-348 y

Temporary Waiver of Compliance This letter documents a written and verbal request of ; Region ;IIl personnel for a. temporary waiver of compliance of Technical Specifica. tion.3. 6,

" Chemical and Volume Control--~ System.'"'

On Septembar 26, 1990 leakage was detected from the boric. acid.

filter discu rge isolation diaphragm valve-3-346..The-boric" acid filter by paes line must.be. isolated to repair the valve.. This configuration results in no flow path from:the boric-acidu torage s

tanks to the Rt. actor Coolant' System (RCS)'during valve' repair.'

~i Technical Specification (TS) 3.6 requires system piping, interlocks.

l and valves to be operable to'the extent of establishing one' flow path to the RCS from the boric acid -storage tanks and one flow. path-from the refueling water storage tank,. to the RCS when the reactor.

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is critical. - TS 3.6 has no Limiting Conditions For. Operation (LCO) for flow path unavailability and therefore TS 3.0.1. applies.

TS 3.0.l' requires that when an LCO action statement can=not.be met, action shall be initiated within one hour to place the unit ~1n a.

i condition where the specification does not apply. -In this. case the reactor would need to be placed in a subcritical condit' ion within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The revised Technical Specifications (RTS) approved by the;NRClon August 28, 1990 provides an LCO for this condition as follows:

RTS 3.1.2.2 ACTION:

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a. With no boration source path from a boric' acid storage. tank; OPERABLF.,

1. Demonstrate the OPERABILITY of the second flow path-from the refueling water storage tank - to - the. charging pump suction by verifying the flow path valve alignment; and 9010230164 900926 PDR ADOCK 0500 GO P

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2.

Restore the boration source - path from.a boric acid storage tank to OPERABLE status within'72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in-at least HOT STANDBY..._within the next 6-hours..

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The revision. allows operation with the flow path isolated for' 72'

. i hours if the paths from the Refueling Water Storage Tank (RWST) are-1 operable.

At this time the flow paths--from'the RWST are operable.

No credit is taken for the concentrated boric acid contain~ed in the 1

Boric Acid Storage Tanks.(BAST) in any of.the Design Basis Accidents described in the Turkey Point Final Safety Analysis i

Report (FSAR).

Sufficient shutdown. margin under hot. shutdown-conditions for the most severe anticipated cooldown transient -(main'.

q steamline break (MSLB)), assuming the most reactive rod control cluster to be fully withdraun, is achieved via the usenof boron from the RWST through the Safety Injection System.-

The MSLB if analysis does allow the reactor to return to. criticality 1due tol

.j cooldown inserted positive reactivity, provided no core damage exists.

A Westinghouse analysis has demonstrated that no: core I

damage is expected to occur during cooldown.

-i The BASTS and the boric acid transfer pumps provide a-source-of concentrated boric acid to be added to the-primary coolant? to offset reactivity changes caused by n'ormal plant operating ~

j transients, and changes-in-power levels.

These~ borict. acid i

additions are also made to attain and maintain cold. shutdown :

conditions.

An additional means for providing borated water 'isl i

2 from the RWST through the charging pumps'to the primary, coolant.

Due to difficulties which could be encountered during<the_ repair-1 effort, a temporary waiver of compliance with TS 3.0.1. is requested allowing Turkey Point Unit 3 to continue;to-operate'for.'up:tos24 j

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hours with the flow path from the; boric acid storage: tanks to thei il primary coolant inoperable.

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Based upon the above analysis and the expedited, repair of valve 3-348, the plant will not.be placed in-a condition.that/ compromises the health and safety of plant personnel or the general publ'ic.

Following review by the Plant Nuclear Safety. Committee,' approval 'of j

this document was recommended to L: thel Plant Manager.

The Plant Manager subsequently approved this-document.

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It 'you' have any questions concerning this ' issue please). contact us, i

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Very truly yours, H

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Vic<

resident Tur;tey Point Nuclear KNH/JEK/jek

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Document Control Desk,-USNRC.:

Dr. G. E. Edison, Project. Manager, NRR,:USNRC' Senior ResidentLInspector,LUSNRC,. Turkey Point Plant-

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