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| {{#Wiki_filter:REGULATORY FORNATION DISTRIBUTION SY-N(RIDS).ACCESSlON NBR:8701130269 DOC.DATE:87/Oi/OVNOTARIZED: | | {{#Wiki_filter:REGULATORY FORNATION DISTRIBUTION SY-N (R IDS).ACCESSlON NBR: 8701130269 DOC.DATE: 87/Oi/OV NOTARIZED: |
| NOFACIL:50-335St.LuciePlantiUnit1>FloridaPowerZcLightCo.AUTH.NANEAUTHORAFFILIATION MOODY'.Q.FloridaPower8cLightCo.RECIP.NAI'lERECIPIENT AFFILIATION RecordServicesBranch(Document ControlDesk)DOCKET05000335
| | NO FACIL: 50-335 St.Lucie Planti Unit 1>Florida Power Zc Light Co.AUTH.NANE AUTHOR AFFILIATION MOODY'.Q.Florida Power 8c Light Co.REC IP.NAI'lE RECIPIENT AFFILIATION Record Services Branch (Document Control Desk)DOCKET 05000335 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| Forwardsjustification for861010requestforexemption to10CFR50>AppJ~Paragraph III.D.2(b)(ii)8caddidocumentati onreNSHCinsupportofapplication foramendtoLicenseDPR-67rerequirements fortestingofcontainment airlocks.DISTRIBUTION CODE:A017DCOPIESRECEIVED:
| | Forwards justification for 861010 request for exemption to 10CFR50>App J~Paragraph I I I.D.2(b)(i i)8c addi documentati on re NSHC in support of application for amend to License DPR-67 re requirements for testing of containment air locks.DISTRIBUTION CODE: A017D COPIES RECEIVED: LTR+ENCL SIZE: TITLE: QR Submittal: |
| LTR+ENCLSIZE:TITLE:QRSubmittal: | | Append J Containment Leak Rate Testing NOTES: RECIPIENT ID CODE/NAI'lE PNR-8 ADTS PNR-8 PEICSB PNR-8 PDB LA TQURIQNY>E PNR-8 RSB INTERNAL: ADN/LFNB NRR BAR ADTS NRR PNR-8 ADTS NRR/DSRO/RSIB COPIES LTTR ENCL 1 2 2 1 0 1 1 1 0 1 1 1 1 RECIPIENT ID CODE/NAI'1E PNR-8 EB PMR-8 FOB PMR-8 PDS PD 01 PWR-8 PEICSB ELD/HDS2 08 NRR PAR-A ADTS EIB 04 COPIES LTTR ENCL 1 1 1 5 5 1 1 1 1 1 EXTERNAL: LPDR NSIC 03 05 1 1 1 NRC PDR 02 TOTAL NU})BER OF COPIES REQUIRED: LTTR 25 ENCL 23 |
| AppendJContainment LeakRateTestingNOTES:RECIPIENT IDCODE/NAI'lE PNR-8ADTSPNR-8PEICSBPNR-8PDBLATQURIQNY>
| | ~11 Ih 4 h'.'C<<i'-i<<.AC/ |
| EPNR-8RSBINTERNAL:
| | h'"'}'I h., 4 I" 4$<<v P.O.B 4000, JUNO BEACH, FL 33408-0420"gNUwY 09lSA L-87-9 U.S.Nuclear Regulatory Commission Document Control Desk Washington, D.C.20555 Gentlemen: |
| ADN/LFNBNRRBARADTSNRRPNR-8ADTSNRR/DSRO/RSIB COPIESLTTRENCL1221011101111RECIPIENT IDCODE/NAI'1E PNR-8EBPMR-8FOBPMR-8PDSPD01PWR-8PEICSBELD/HDS208NRRPAR-AADTSEIB04COPIESLTTRENCL1115511111EXTERNAL: | | Re: St.Lucie Unit 1 Docket No.50-335 Containment Air Locks By letter L-86-412, dated October 10, 1986, Florida Power&Light Company (FPL)applied for an amendment to Facility Operating License DPR-67 regarding surveillance requirements for testing of containment air locks.The intent of this proposed amendment is to bring the St.Lucie Unit I Technical Specifications to the same form as those of Unit 2 for air lock testing.By letter dated November 25, 1986 (E.G.Tourigny to C.O.Woody), the NRC stated that the specific exemption included in the amendment should be made in accordance with 10 CFR 50.12.The staff also requested additional information to address each factor under 10 CFR 50.92(c), the No Significant Hazards Consideration. |
| LPDRNSIC0305111NRCPDR02TOTALNU})BEROFCOPIESREQUIRED:
| | Attachment I is the justification for the requested exemption to 10 CFR 50, Appendix J, Paragraph 111.D.2(b)(ii).Attachment ll is additional documentation regarding the No Significant Hazards Consideration. |
| LTTR25ENCL23
| | Please contact us if you have any questions about this submittal. |
| ~11Ih4h'.'C<<i'-i<<.AC/ | | Very truly yours,.Woody roup Vice President Nuclear Energy COW/E JW/gp At tachments (2)cc: Dr.J.Nelson Grace, Region ll, USNRC Mr.Alan Schubert, Florida Dept.of Health and Rehabilitative Services Harold F.Reis, Esquire t 8701130269 870109 PDR ADOCK 05000335I P PDR I~j PEOPLE...SERVING PEOPLE |
| h'"'}'Ih.,4I"4$<<v P.O.B4000,JUNOBEACH,FL33408-0420" gNUwY09lSAL-87-9U.S.NuclearRegulatory Commission DocumentControlDeskWashington, D.C.20555Gentlemen: | | ~v~Tl>>~U'Uh*v~I~f v I Ih h'I~It I U v v'the Ii t ,~~~'~U I v I h~li Ca I I'I h v'*k v~a 5>>aal v Ud~if I vs I'a~'f Uv'~f k"I t,a I v~Iifw-" II vh.II I I'ha i~n-It U.-~~h fl fa I h a~Ih>>V~II I~II, A,'I I~v'>>I I'lI ItI ffv I I T" f>>v-'V U,l hl aav a Utgha.~I~h Ia>>f yJ.I vl~I vt ifv ftvv I I U'''>>I I>>(~I~v'~~\~~ |
| Re:St.LucieUnit1DocketNo.50-335Containment AirLocksByletterL-86-412, datedOctober10,1986,FloridaPower&LightCompany(FPL)appliedforanamendment toFacilityOperating LicenseDPR-67regarding surveillance requirements fortestingofcontainment airlocks.Theintentofthisproposedamendment istobringtheSt.LucieUnitITechnical Specifications tothesameformasthoseofUnit2forairlocktesting.ByletterdatedNovember25,1986(E.G.TourignytoC.O.Woody),theNRCstatedthatthespecificexemption includedintheamendment shouldbemadeinaccordance with10CFR50.12.Thestaffalsorequested additional information toaddresseachfactorunder10CFR50.92(c), | | JUSTIFICATION FOR THE RE UESTED EXEMPTIONS TO 10CFR50 APPENDIX J 10CFR50.12(a) |
| theNoSignificant HazardsConsideration.
| | (1)In accordance with 10CFR50.12(a) |
| Attachment Iisthejustification fortherequested exemption to10CFR50,AppendixJ,Paragraph 111.D.2(b) | | (1), the Commission may grant exemptions under the following circumstances: (I)the activities to be conducted are authorized by law, (IZ)operation with the exemption will not present undue risk to the health and safety of the public, and (ZIZ)the common defense and security are not endangered. |
| (ii).Attachment llisadditional documentation regarding theNoSignificant HazardsConsideration. | | The evaluations to these standards, contained herein, are in accordance with 10CFR50.12 as revised by final rule dated January 13, 1986.I.The Re uested Exem tions and the Activities Which Would Be Allowed Thereunder Are Authorized b Law There are no other prohibitions of law to preclude the activities which would be authorized by the requested exemption. |
| Pleasecontactusifyouhaveanyquestions aboutthissubmittal.
| | Therefore, the Commission is authorized by law to grant this exemption request.IZ.The Re uested Exem tions Will Not Present Undue Risk to the Health and Safet of the Public The evaluation of"no undue risk" considers such factors as the type of plant operation contemplated, the length of time the exemption would be in effect, the existence of alternative means of compliance or compensatory measures, and other safety factors.The results of the evaluations considering these factors are discussed below.Containment Air Lock Testin Exem tion Re uest 10CFR50, Appendix J, Paragraph III.D.2(b) details three explicit air lock testing requirements. |
| Verytrulyyours,.WoodyroupVicePresident NuclearEnergyCOW/EJW/gpAttachments (2)cc:Dr.J.NelsonGrace,Regionll,USNRCMr.AlanSchubert, FloridaDept.ofHealthandRehabilitative ServicesHaroldF.Reis,Esquiret8701130269 870109PDRADOCK05000335I PPDRI~jPEOPLE...
| | In the proposed amendment to St.Lucie Unit 1, Technical Specification 4.6.1.3, items a, b, and c comply with Appendix J requirements with one exception. |
| SERVINGPEOPLE
| | Appendix J, Paragraph III.D.2(b)(ii)requires that"Air locks opened during periods when containment integrity is not required by the plant's Technical Specifications shall be tested at the end of such periods at not less than Pa.".Whenever the plant is in Mode 5 or 6 CONTAINMENT> |
| ~v~Tl>>~U'Uh*v~I~fvIIhh'I~ItIUvv'theIit,~~~'~UIvIh~liCaII'Ihv'*kv~a5>>aalvUd~ifIvsI'a~'fUv'~fk"It,aIv~Iifw-"IIvh.IIII'hai~n-ItU.-~~hflfaIha~Ih>>V~III~II,A,'II~v'>>II'lIItIffvIIT"f>>v-'VU,lhlaavaUtgha.~I~hIa>>fyJ.Ivl~IvtifvftvvIIU'''>>II>>(~I~v'~~\~~ | | VESSEL INTEGRITY is not required.Therefore, if an air lock is opened during either of these conditions, paragraph 1ZZ.D.2(b)(ii)requires that an overall air lock leakage test at not less than Pa be conducted prior to entry into Mode 4.This requirement is excessively restrictive since.it requires a termination of containment entries while preparing to leave Mode 5 until the air lock that was opened and operated in Mode 5 or 6 is tested pursuant to paragraph IIZ.D.2(b)(ii).Primary Containment entries during Mode 5 are important to ensure that surveillance requirements and minor maintenance activities are completed. |
| JUSTIFICATION FORTHEREUESTEDEXEMPTIONS TO10CFR50APPENDIXJ10CFR50.12(a) | | The requirements of paragraph IIZ.DE 2(b)(ii.)would apply even if the six month testing requirement of paragraph ZII.D.2(b)(i)had been satisfied. |
| (1)Inaccordance with10CFR50.12(a) | | Subsequent containment entries while in Mode 5 would require retesting of the air lock uti.lized. |
| (1),theCommission maygrantexemptions underthefollowing circumstances: | | Access to containment during Periods when CONTAINMENT |
| (I)theactivities tobeconducted areauthorized bylaw,(IZ)operation withtheexemption willnotpresentunduerisktothehealthandsafetyofthepublic,and(ZIZ)thecommondefenseandsecurityarenotendangered. | | .VESSEL INTEGRITY is required by plant Technical Specifications is governed by paragraph ZIZ.D.2(b)(iii).The existing air lock doors are so designed that a full pressure test at Pa of an entire air lock can only be performed after strongbacks (structural bracing)have been installed on the inner door.This is because the pressure exerted on the inner door during the test is in a direction opposite to that of force experienced during a postulated accident and the locking mechanisms are not designed to wi.thstand such reverse forces..Installing strongbacks, performing the test, and removing the strongbacks, is a cumbersome process requiring at least 14 hours during which access through the air lock is prohibited. |
| Theevaluations tothesestandards, contained herein,areinaccordance with10CFR50.12 asrevisedbyfinalruledatedJanuary13,1986.I.TheReuestedExemtionsandtheActivities WhichWouldBeAllowedThereunder AreAuthorized bLawTherearenootherprohibitions oflawtoprecludetheactivities whichwouldbeauthorized bytherequested exemption.
| | The Appendix J periodic 6-month test requirement of paragraph ZII.D.2(b)(i)and the 3-day test requirement of paragraph ZZI.D.2(b)(iii)provide assurance that the air lock will not leak excessively if no maintenance which could affect the ability of the air lock to seal has been performed on the air lock and if the air lock is properly engaged and sealed.An exempti.on from paragraph ZZI.D.2(b)(ii)of Appendix J is requested since the proposed amendment to Techni,cal Specification (FPL letter L-86-4 12, dated October 10, 1986)is substantially as safe as the requirement itself.This exemption is included as a part of the NRC's CE Standard Technical Specifications approved December 31, 1981, and is consistent with current regulatory practice and poli.cy.Because of the proposed Techni.cal Specification surveillance requirements, the requested exemption involves a de facto requirement for an air lock seal test in lieu of the ZIZ.D.2(b)(ii)test.Appendix J, Paragraph III.D.2(b)(ii.i)already allows an air lock seal test in lieu of a simi.lar required air lock test at a pressure of not less than, Pa.Thus the functional equivalence of these tests under similar.circumstances has been recognized. |
| Therefore, theCommission isauthorized bylawtograntthisexemption request.IZ.TheReuestedExemtionsWillNotPresentUndueRisktotheHealthandSafetofthePublicTheevaluation of"nounduerisk"considers suchfactorsasthetypeofplantoperation contemplated, thelengthoftimetheexemption wouldbeineffect,theexistence ofalternative meansofcompliance orcompensatory | | PPL proposes an alternative'est to be conducted during those periods when CONTAIN-MENT VESSEL INTEGRITY is not required by the Plant Technical Specifications and pri.or to entering Mode 4.The alternative test consists of testing the seals of the inner and outer doors by pressurizing the area between the seals and verifying an acceptable leakage rate.Zf, however, maintenance has been performed on the air lock since the last successful test performed pursuant to paragraph IZZ.D.2(b)(i), an overall air lock test will be performed. |
| : measures, andothersafetyfactors.Theresultsoftheevaluations considering thesefactorsarediscussed below.Containment AirLockTestinExemtionReuest10CFR50,AppendixJ,Paragraph III.D.2(b) detailsthreeexplicitairlocktestingrequirements.
| | It is concluded that there is reasonable assurance against undue air lock leakage provided under the exemption and no material increase in the probability or extent of air lock leakage is to be expected.Therefore, there is no signi'ficant increase in the probability of higher post-accident offsite or onsite doses related to the exemption and no significant increase in environmental impact beyond that experienced without an exemption. |
| Intheproposedamendment toSt.LucieUnit1,Technical Specification 4.6.1.3,itemsa,b,andccomplywithAppendixJrequirements withoneexception.
| | As a result, this exemption will not present undue risk to the health and safety of the public.The Re uested Exem tion Will Not Endan er the Common Defense and Securit The requested exemption will have no impact on the common defense and security.In conclusion, the standards of 10CFR50.12(a) |
| AppendixJ,Paragraph III.D.2(b)
| | (1)are met for the specific exemption. |
| (ii)requiresthat"Airlocksopenedduringperiodswhencontainment integrity isnotrequiredbytheplant'sTechnical Specifications shallbetestedattheendofsuchperiodsatnotlessthanPa.".WhenevertheplantisinMode5or6CONTAINMENT> | |
| VESSELINTEGRITY isnotrequired.
| |
| Therefore, ifanairlockisopenedduringeitheroftheseconditions, paragraph 1ZZ.D.2(b) | |
| (ii)requiresthatanoverallairlockleakagetestatnotlessthanPabeconducted priortoentryintoMode4.Thisrequirement isexcessively restrictive since.itrequiresatermination ofcontainment entrieswhilepreparing toleaveMode5untiltheairlockthatwasopenedandoperatedin Mode5or6istestedpursuanttoparagraph IIZ.D.2(b) | |
| (ii).PrimaryContainment entriesduringMode5areimportant toensurethatsurveillance requirements andminormaintenance activities arecompleted. | |
| Therequirements ofparagraph IIZ.DE2(b)(ii.)wouldapplyevenifthesixmonthtestingrequirement ofparagraph ZII.D.2(b)
| |
| (i)hadbeensatisfied. | |
| Subsequent containment entrieswhileinMode5wouldrequireretesting oftheairlockuti.lized. | |
| Accesstocontainment duringPeriodswhenCONTAINMENT
| |
| .VESSELINTEGRITY isrequiredbyplantTechnical Specifications isgovernedbyparagraph ZIZ.D.2(b) | |
| (iii).TheexistingairlockdoorsaresodesignedthatafullpressuretestatPaofanentireairlockcanonlybeperformed afterstrongbacks (structural bracing)havebeeninstalled ontheinnerdoor.Thisisbecausethepressureexertedontheinnerdoorduringthetestisinadirection oppositetothatofforceexperienced duringapostulated accidentandthelockingmechanisms arenotdesignedtowi.thstand suchreverseforces..Installing strongbacks, performing thetest,andremovingthestrongbacks, isacumbersome processrequiring atleast14hoursduringwhichaccessthroughtheairlockisprohibited. | |
| TheAppendixJperiodic6-monthtestrequirement ofparagraph ZII.D.2(b)
| |
| (i)andthe3-daytestrequirement ofparagraph ZZI.D.2(b) | |
| (iii)provideassurance thattheairlockwillnotleakexcessively ifnomaintenance whichcouldaffecttheabilityoftheairlocktosealhasbeenperformed ontheairlockandiftheairlockisproperlyengagedandsealed.Anexempti.on fromparagraph ZZI.D.2(b) | |
| (ii)ofAppendixJisrequested sincetheproposedamendment toTechni,cal Specification (FPLletterL-86-412,datedOctober10,1986)issubstantially assafeastherequirement itself.Thisexemption isincludedasapartoftheNRC'sCEStandardTechnical Specifications approvedDecember31,1981,andisconsistent withcurrentregulatory practiceandpoli.cy.BecauseoftheproposedTechni.cal Specification surveillance requirements, therequested exemption involvesadefactorequirement foranairlocksealtestinlieuoftheZIZ.D.2(b) | |
| (ii)test.AppendixJ,Paragraph III.D.2(b) | |
| (ii.i)alreadyallowsanairlocksealtestinlieuofasimi.larrequiredairlocktestatapressureofnotlessthan,Pa.Thusthefunctional equivalence ofthesetestsundersimilar.circumstances hasbeenrecognized. | |
| PPLproposesanalternative'est tobeconducted duringthoseperiodswhenCONTAIN-MENTVESSELINTEGRITY isnotrequiredbythePlantTechnical Specifications andpri.ortoenteringMode4.Thealternative testconsistsoftestingthesealsoftheinnerandouterdoorsbypressurizing theareabetweenthesealsandverifying anacceptable leakagerate.Zf,however,maintenance hasbeenperformed ontheairlocksincethelastsuccessful testperformed pursuanttoparagraph IZZ.D.2(b)
| |
| (i),anoverallairlocktestwillbeperformed. | |
| Itisconcluded thatthereisreasonable assurance againstundueairlockleakageprovidedundertheexemption andnomaterialincreaseintheprobability orextentofairlockleakageistobeexpected.
| |
| Therefore, thereisnosigni'ficant increaseintheprobability ofhigherpost-accident offsiteoronsitedosesrelatedtotheexemption andnosignificant increaseinenvironmental impactbeyondthatexperienced withoutanexemption. | |
| Asaresult,thisexemption willnotpresentunduerisktothehealthandsafetyofthepublic.TheReuestedExemtionWillNotEndanertheCommonDefenseandSecuritTherequested exemption willhavenoimpactonthecommondefenseandsecurity.
| |
| Inconclusion, thestandards of10CFR50.12(a)
| |
| (1)aremetforthespecificexemption. | |
| 10CFR50.12(a) | | 10CFR50.12(a) |
| (2)Inaccordance with10CFR50.12(a) | | (2)In accordance with 10CFR50.12(a) |
| (2),theCommission willnotconsidergrantinganexemption unlessspecialcircumstances arepresent.Specialcircumstances inwhichtheCommission believesitwouldbereasonable tograntanexemption areidentified inSections50.12(a)(2)(i)through(vi)oftherevisedfinalrule.Thefollowing evaluations pertaintoeachofthesecriteria. | | (2), the Commission will not consider granting an exemption unless special circumstances are present.Special circumstances in which the Commission believes it would be reasonable to grant an exemption are identified in Sections 50.12(a)(2)(i)through (vi)of the revised final rule.The following evaluations pertain to each of these criteria.50.12(a)(2)(i)-"Application of the regulation in the particular circumstances would be in conflict with other rules or requirements of the Commission." The specific exemption request discussed herein is not applicable to the special circumstance of Section 50.12(a)(2)(i).50;12(a)(2)(ii)-"Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." 4 Application of this special circumstance shows that application of the regulation is not necessary to serve the specific purpose.of the regulation. |
| 50.12(a)(2)(i)-"Application oftheregulation intheparticular circumstances wouldbeinconflictwithotherrulesorrequirements oftheCommission." | | ~i~'The Containment Air Lock leakage rate testing is performed to ensure CONTAINMENT VESSEL INTEGRITY. |
| Thespecificexemption requestdiscussed hereinisnotapplicable tothespecialcircumstance ofSection50.12(a)(2)(i).50;12(a)(2)(ii)-"Application oftheregulation intheparticular circumstances wouldnotservetheunderlying purposeoftheruleorisnotnecessary toachievetheunderlying purposeoftherule."4Application ofthisspecialcircumstance showsthatapplication oftheregulation isnotnecessary toservethespecificpurpose.oftheregulation.
| | CONTAINMENT VESSEL INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses.The restriction, in conjunction with the leakage rate limitation, will limit the site boundary radiation doses to within the limits of 10CFR Part 100 during accident conditions. |
| ~i~'TheContainment AirLockleakageratetestingisperformed toensureCONTAINMENT VESSELINTEGRITY. | | 3 The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure.As noted above, and in the previous discussion of"no undue risk", the application of the requirements of 10CFR50, Appendix J, Paragraphs ZII.D.2(b)(ii)is not necessary to serve the underlying purpose of these regulations. |
| CONTAINMENT VESSELINTEGRITY ensuresthatthereleaseofradioactive materials fromthecontainment atmosphere willberestricted tothoseleakagepathsandassociated leakratesassumedintheaccidentanalyses. | | This is true since the alternatives presented limit the postulated accident doses to within the 10CFR100 guidelines. |
| Therestriction, inconjunction withtheleakageratelimitation, willlimitthesiteboundaryradiation dosestowithinthelimitsof10CFRPart100duringaccidentconditions.
| | Therefore, the special circumstances of Section 50.12(a)(2)(ii)apply to these specific exemption requests.50.12(a)(2)(iii)-"Compliance would result in undue hardship or other costs that are significantly in excess of those incurred by others similarly situated." This special circumstance is intended to provide equitable treatment to all applicants and licensees. |
| 3 Thelimitations oncontainment leakageratesensurethatthetotalcontainment leakagevolumewillnotexceedthevalueassumedintheaccidentanalysesatthepeakaccidentpressure. | | As noted in the discussion of the Containment Air Lock test exemption request, undue hardships or unnecessary difficulties, in the form of excessive restrictions to Containment access and the cumbersome process of installing/removing strongbacks on the inner door, would result from literal compliance to 10CFR50, Appendix J, Paragraph ZZZ.D.2(b)(ii).Such literal compliance to this Appendix J requirement would not result in any measurable difference in protection to the public health and safety relative to the protection afforded if this exemption is granted.In addition, similar exemptions to these requirements have been granted by the NRC for the Grand Gulf Nuclear Station, Fermi Unit 2, and Salem Nuclear Generating Station.Exemption requests from this requirement have been filed by Perry Nuclear Power Plant, Nine Mile Point Unit 2, Seabrook and the Clinton Power Station.Therefore, with respect to the Containment Air Lock test exemption, the special circumstance of Section 50.12(a)(2)(iii)applies.Furthermore, compliance to this requirement would result in undue hardship and cost through reduced operational flexibility and unwarranted. |
| Asnotedabove,andinthepreviousdiscussion of"nounduerisk",theapplication oftherequirements of10CFR50,AppendixJ,Paragraphs ZII.D.2(b)
| | delays in power ascension over the life of the plant in excess of those incurred by other similar facilities that have received exemption from the subject Appendix J paragraph. |
| (ii)isnotnecessary toservetheunderlying purposeoftheseregulations. | | Performance of the leakage rate tests required by paragraph ZZI.D.2(b)(ii)takes approximately 14'ours per air lock and requires installation of a strong.back device on the insid'e air lock door (Test pressuie applied inside the air lock tends to unseat this door because it is de'signed to seal with accident pressure from inside containment). |
| Thisistruesincethealternatives presented limitthepostulated accidentdosestowithinthe10CFR100guidelines.
| | This evolution can potentially occur several times during a refueling outage and ultimately can delay mode change on start up. |
| Therefore, thespecialcircumstances ofSection50.12(a)(2)(ii)applytothesespecificexemption requests. | | 50.12(a)(2)(iv)-"The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption." The above discussions |
| 50.12(a)(2)(iii)-"Compliance wouldresultinunduehardshiporothercoststhataresignificantly inexcessofthoseincurredbyotherssimilarly situated." | | 'on the Containment Air Lock leak rate test exemption support the basis for this special circumstance. |
| Thisspecialcircumstance isintendedtoprovideequitable treatment toallapplicants andlicensees.
| | In the exemption request, the design and/or alternative testing is substantially as safe as the requirements themselves. |
| Asnotedinthediscussion oftheContainment AirLocktestexemption request,unduehardships orunnecessary difficulties, intheformofexcessive restrictions toContainment accessandthecumbersome processofinstalling/removing strongbacks ontheinnerdoor,wouldresultfromliteralcompliance to10CFR50,AppendixJ,Paragraph ZZZ.D.2(b)
| | Therefore, the special circumstance of Section 50.12(a)(2)(iv)applies to this specific exemption. |
| (ii).Suchliteralcompliance tothisAppendixJrequirement wouldnotresultinanymeasurable difference inprotection tothepublichealthandsafetyrelativetotheprotection affordedifthisexemption isgranted.Inaddition, similarexemptions totheserequirements havebeengrantedbytheNRCfortheGrandGulfNuclearStation,FermiUnit2,andSalemNuclearGenerating Station.Exemption requestsfromthisrequirement havebeenfiledbyPerryNuclearPowerPlant,NineMilePointUnit2,SeabrookandtheClintonPowerStation.Therefore, withrespecttotheContainment AirLocktestexemption, thespecialcircumstance ofSection50.12(a)(2)(iii)applies.Furthermore, compliance tothisrequirement wouldresultinunduehardshipandcostthroughreducedoperational flexibility andunwarranted. | | 50.12(a)(2)(v)"The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation." This special circumstance does not apply to these exemption requests since it is for the operating lifetime of St.Lucie Unit l.50.12(a)(2)(vi)-"There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption." There is not present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption. |
| delaysinpowerascension overthelifeoftheplantinexcessofthoseincurredbyothersimilarfacilities thathavereceivedexemption fromthesubjectAppendixJparagraph.
| | REATTACHMENT II)'ETERMINATION OP NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no signif icant hazards consideration are included in the Commission |
| Performance oftheleakageratetestsrequiredbyparagraph ZZI.D.2(b)(ii)takesapproximately 14'oursperairlockandrequiresinstallation ofastrong.backdeviceontheinsid'eairlockdoor(Testpressuieappliedinsidetheairlocktendstounseatthisdoorbecauseitisde'signed tosealwithaccidentpressurefrominsidecontainment). | | 'regulations, 10 CFR 50.92.These regulations state that no significant hazards consideration are involved if the 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.Each standard is discussed as follows: (1)Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the, probability or consequences of an accident previously evaluated. |
| Thisevolution canpotentially occurseveraltimesduringarefueling outageandultimately candelaymodechangeonstartup.
| | The air lock configuration |
| 50.12(a)(2)(iv)-"Theexemption wouldresultinbenefittothepublichealthandsafetythatcompensates foranydecreaseinsafetythatmayresultfromthegrantoftheexemption." | | 'or current method of testing is not being changed.Therefore, the PSAR analysis for accident probability, malfunction type, accident type, and consequence of failure has not been affected.(2)Use of the modified specification would not create the possibility of a new or different kind of accident from any accident previously evaluated. |
| Theabovediscussions
| | The proposed amendment will result in no changes to the plant's procedures, structures, systems, mode of operation or components. |
| 'ontheContainment AirLockleakratetestexemption supportthebasisforthisspecialcircumstance. | | No additional tests or experiments not described in the FSAR are necessary to implement the proposed change.(3)Use of the modified specification would not involve a significant reduction in a margin of safety.The margin of safety for Technical Specifications has not been reduced since acceptance criteria will remain unchanged. |
| Intheexemption request,thedesignand/oralternative testingissubstantially assafeastherequirements themselves.
| | Based on the above, PPL has determined that the amendment request does not (1)involve a significant increase in the probability or consequences of a accident previously evaluated, (2)create the probability of a new or different kind of accident from any accident previously evaluated, or (3)involve a significant reduction in a margin of safety;and therefore does not involve a significant hazards consideration. |
| Therefore, thespecialcircumstance ofSection50.12(a)(2)(iv)appliestothisspecificexemption. | | a~1 g~t ll l I l 1a'I}} |
| 50.12(a)(2)(v)"Theexemption wouldprovideonlytemporary relieffromtheapplicable regulation andthelicenseeorapplicant hasmadegoodfaitheffortstocomplywiththeregulation." | |
| Thisspecialcircumstance doesnotapplytotheseexemption requestssinceitisfortheoperating lifetimeofSt.LucieUnitl.50.12(a)(2)(vi)-"Thereispresentanyothermaterialcircumstance notconsidered whentheregulation wasadoptedforwhichitwouldbeinthepublicinteresttograntanexemption."
| |
| Thereisnotpresentanyothermaterialcircumstance notconsidered whentheregulation wasadoptedforwhichitwouldbeinthepublicinteresttograntanexemption.
| |
| REATTACHMENT II)'ETERMINATION OPNOSIGNIFICANT HAZARDSCONSIDERATION Thestandards usedtoarriveatadetermination thatarequestforamendment involvesnosignificanthazardsconsideration areincludedintheCommission | |
| 'regulations, 10CFR50.92.Theseregulations statethatnosignificant hazardsconsideration areinvolvediftheoperation ofthefacilityinaccordance withtheproposedamendment wouldnot:(1)involveasignificant increaseintheprobability orconsequences ofanaccidentpreviously evaluated, or(2)createthepossibility ofanewordifferent kindofaccidentfromanyaccidentpreviously evaluated, or(3)involveasignificant reduction inamarginofsafety.Eachstandardisdiscussed asfollows:(1)Operation ofthefacilityinaccordance withtheproposedamendment wouldnotinvolveasignificant increaseinthe,probability orconsequences ofanaccidentpreviously evaluated. | |
| Theairlockconfiguration
| |
| 'orcurrentmethodoftestingisnotbeingchanged.Therefore, thePSARanalysisforaccidentprobability, malfunction type,accidenttype,andconsequence offailurehasnotbeenaffected. | |
| (2)Useofthemodifiedspecification wouldnotcreatethepossibility ofanewordifferent kindofaccidentfromanyaccidentpreviously evaluated. | |
| Theproposedamendment willresultinnochangestotheplant'sprocedures, structures, systems,modeofoperation orcomponents.
| |
| Noadditional testsorexperiments notdescribed intheFSARarenecessary toimplement theproposedchange.(3)Useofthemodifiedspecification wouldnotinvolveasignificant reduction inamarginofsafety.ThemarginofsafetyforTechnical Specifications hasnotbeenreducedsinceacceptance criteriawillremainunchanged.
| |
| Basedontheabove,PPLhasdetermined thattheamendment requestdoesnot(1)involveasignificant increaseintheprobability orconsequences ofaaccidentpreviously evaluated, (2)createtheprobability ofanewordifferent kindofaccidentfromanyaccidentpreviously evaluated, or(3)involveasignificant reduction inamarginofsafety;andtherefore doesnotinvolveasignificant hazardsconsideration.
| |
| a~1g~tlllIl1a'I}} | |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17241A5001999-10-21021 October 1999 Forwards Rev 3 to Emergency Response Data Sys (ERDS) Data Point Library for St Lucie Unit 1.Rev Provides Replacement Pages & Follows Format Recommended by NUREG 1394, ERDS Implementation, Rev 1,App C ML17309A9981999-10-19019 October 1999 Forwards Revised Epips,Including Rev 3 to EPIP-10 & Rev 25 to HP-202.EPIP-10 Added Onsite Monitoring Points,Made Administrative Changes & Incorporated New Attachments & HP-202 Added Red Team Survey Points ML20217F6171999-10-0808 October 1999 Forwards Insp Repts 50-335/99-11 & 50-389/99-11 on 990827 & 990907-09.No Violations Identified.Matl Encl Contained Safeguards Info as Defined by 10CFR73.21 & Disclosed to Unauthorized Individuals Prohibited by Section 147 of AEA ML17241A4811999-10-0101 October 1999 Reports Number of Tubes Plugged During Unit 1 Refueling Outage SL1-16,per TS 4.4.5.5.a ML20212M1601999-09-28028 September 1999 Refers to 990908 Engineering Meeting Conducted at NRC Region II to Discuss Engineering Issues at Lucie & Turkey Point Facilities.List of Attendees & Copy of Presentation Handout Encl ML17241A4701999-09-25025 September 1999 Forwards Info Requested by NRC Staff During 990916 Telcon to Complete Staff Review of Request for risk-informed Extension of Action Completion/Aot Specified for Inoperable Train of LPSI Sys at Plant ML17241A4721999-09-24024 September 1999 Forwards Rev 1 to Plant Change/Mod (PCM) 99016 to St Lucie Unit 1,Cycle 16 COLR, IAW TS 6.9.1.11.d.Refueling Overhaul Activities Are Currently in Progress & Reactor Operations for Cycle 16 Are Scheduled to Commence in Oct 1999 ML17241A4681999-09-22022 September 1999 Requests Restriction Be Added to Senior Operator License SOP-21093 for TE Bolander.Nrc Forms 369,encl.Encl Withheld Per 10CFR2.790(a)(6) ML17241A4671999-09-20020 September 1999 Forwards Completed NRC Form 536, Operator Licensing Exam Data, for St Lucie Units 1 & 2,as Requested in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. ML17241A4581999-09-13013 September 1999 Forwards Info Requested by NRC Staff During 990630 & 0816 Telcons,To Complete Review of Proposed License Amend for Fuel Reload Process Improvement Program ML17241A4531999-08-31031 August 1999 Informs That No Candidates from St Lucie Plant Will Be Participating in PWR Gfes Being Administered on 991006 ML17241A4521999-08-31031 August 1999 Withdraws Relief Request 16 & Suppl Relief Request 15 with Info Requested During 990526 Telephone Conference Re ISI Insp Plan,Third 10-yr Interval ML17241A4501999-08-26026 August 1999 Informs That FPL Has Reviewed Reactor Vessel Integrity Database,Called RVID2,re Closure of GL 92-01,rev 1,suppl 1. Requested Corrections & Marked Up Pages from Rvid 2 Database Summary Repts That Correspond to Comments,Attached ML17241A4371999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data for six- Month Period Ending 990630,per 10CFR26.71(d) ML17241A4461999-08-11011 August 1999 Requests That W Rept Entitled, Evaluation of Turbine Missile Ejection Probability Resulting from Extending Test Interval of Interceptor & Reheat Stop Valves at St Lucie Units 1 & 2, Be Withheld from Public Disclosure L-99-171, Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3)1999-07-29029 July 1999 Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3) ML17309A9911999-07-26026 July 1999 Forwards Revised EPIPs & Revised Procedures That Implement Emergency Plan as Listed.Procedures Provides Instruction for Operational Support Ctr (OSC) Chemistry Supervisor to Establish Remote Labs at Locations Specified ML17241A4471999-07-22022 July 1999 Requests That Rev 1 to WCAP-14732 & Rev 1,Add 1 to WCAP-14732 Be Withheld from Public Disclosure ML17241A4221999-07-22022 July 1999 Forwards List of Proposed Licensing Actions for St Lucie Units 1 & 2,planned During Fys 2000 & 2001,in Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. ML17241A4151999-07-22022 July 1999 Forwards Revised Relief Request 25 for Second 10-yr ISI Interval for Unit 2 ML17241A4101999-07-16016 July 1999 Forwards FP&L Supplemental Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17309A9881999-07-0707 July 1999 Forwards Rev 5 to EPIP-03, Emergency Response Organization Notification/Staff Augmentation. Rev 5 to EPIP-03 Was Revised to Transfer EP Responsibilities from Training Manager to Protection Svcs Manager ML20209F1541999-07-0606 July 1999 Informs That NRC in Process of Conducting Operational Safeguards Response Evaluations at Nuclear Power Reactors. Plant Chosen for Such Review Scheduled for Wk of 990823-26 ML17241A4011999-06-30030 June 1999 Forwards Info Copy of Florida Wastewater Permit (FL0002208) (Formerly NPDES Permit) Mod,Which Was Issued by Florida Dept of Environ Protection on 990604 ML17241A3971999-06-30030 June 1999 Forwards Suppl Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, as Requested in 990317 Ltr ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17241A3951999-06-29029 June 1999 Provides Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants, Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML17241A3731999-06-17017 June 1999 Supplements Relief Requests 4,11 & 13 for Third ten-year ISI Interval with Info Requested During 990526 Telcon.Expedited Review Is Requested by 990730 to Avoid Negatively Impacting Upcoming St Lucie Unit 1 Refueling Outage (SL1-16) ML17241A3641999-06-14014 June 1999 Submits Supplement to Relief Request 24 with Info Requested by Nrc.In Addition Relief Request 24 Is Identical to St Lucie Unit 1 Relief Request 4 for Third ISI Interval Being Supplemented by FPL Ltr L-99-139 ML20195F3871999-06-11011 June 1999 Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5) IA-99-247, Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5)1999-06-11011 June 1999 Final Response to FOIA Request for Documents.App a Records Being Withheld in Entirety (Ref FOIA Exemption 5) L-99-129, Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3)1999-06-0909 June 1999 Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3) ML17241A3561999-06-0707 June 1999 Forwards Rept Containing Brief Description & Summary of SEs for Changes,Tests & Experiments Which Were Approved for Unit 3 During Period of 970526-981209 ML17241A3601999-06-0707 June 1999 Forwards Correction to Annual Radiological Environ Operating Rept for CY98.Util Has Identified Transcription Error on Last Page of Attachment C of Rept,Results from Interlaboratory Comparison Program 1998 ML20195F3941999-05-27027 May 1999 FOIA Request That Memo from J Calvo to Fl Lebdon Re TIA - St Lucie,Unit 1 Environ Qualification of Woodward Governor Controls Be Placed in PDR ML17241A3461999-05-24024 May 1999 Forwards Revised Relief Request 22 to Clarify Several Areas of Relief.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17241A3391999-05-20020 May 1999 Forwards Notification of Change to Small Break LOCA ECCS Evaluation Model Used for St Lucie Unit 1.Anomaly Was Discovered & Corrected That Resulted in Reducing Calculated PCT for Limiting SBLOCA by More than 50 F ML17241A3371999-05-20020 May 1999 Forwards Util Suppl to GL 95-07 Response Re pressure-locking & Thermal Binding of safety-related power-operated Gate Valves,In Response to NRC Second RAI Dtd 990225 ML20207C7531999-05-17017 May 1999 Discusses Issue Identified by FPL in Feb 1998 Involving Potential for Fire to Cause Breach of Rc Sys High/Low Pressure Interface Boundary & NRC Decision for Exercise of Enforcement Discretion ML17241A3301999-05-17017 May 1999 Forwards LER 99-004-00 Re as Found Cycle 10 Psv Setpoints Outside TS Limits,Which Occurred on 990415.Root Cause Determination Not Yet Complete.Suppl to Include Root Cause & Corrective Actions Will Be Submitted ML17309A9821999-05-10010 May 1999 Forwards Rev 36 to St Lucie Emergency Plan, Per 10CFR50.54(q).Executive Summary & Summary of Changes Incorporated by Rev,Encl IR 05000335/19980141999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17241A3221999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17229B1071999-04-28028 April 1999 Forwards 1998 Annual Environ Operating Rept for St Lucie Unit 2. Rept Includes Discussions of 5-inch Barrier Net Maint & Taprogge Condenser Tube Cleaning Sys Ball Loss,As Agreed at First Biennial Sea Turtle Meeting Held on 980120 ML17229B1051999-04-22022 April 1999 Requests That Listed Individuals Be Placed on Official Serve List for Nuclear Matl Safety & Safeguards Info Notices ML17229B1061999-04-21021 April 1999 Notifies NRC of Change in Medical Status of Licensed Operator Pf Farnsworth (Docket 55-21285,license SOP-21094). NRC Form 3996, Medical Exam Certification, Encl.Encl Withheld Per 10CFR2.790(a)(6) ML17309A9851999-04-15015 April 1999 Requests That NRC Review Denial of Appeal from Assessment of Fees Assessed in 981101 Invoice RS0062-99 & Assessment of Fees in Invoice RS0182-99 Which Was Also Denied in 990305 Ltr.Both Invoices Are for Fees Re Inspector GG Warnick ML20205M0431999-04-13013 April 1999 Eighth Partial Response to FOIA Request for Records.App Q & R Records Encl & Being Made Available in PDR ML17229B0951999-04-0808 April 1999 Requests Approval of Encl Revised Relief Request 6,in Response to 990322 Telcon with NRC & 10CFR55.55a(a)(3). Request States That Visual VT-3 Exams Will Be Conducted IAW IWA-2213 & Repairs Will Be IAW Util ASME Section IX Program ML17229B0821999-04-0707 April 1999 Requests Approval of Interim Relief Request 26 Re Repair Requirements for Class 2 ECCS Piping,Per 10CFR50.55a(a)(3) & 50.55a(g)(iii).Alternative Actions Apply Guidance of GLs 91-18 & 90-05 & ASME Code Case N-513.Evaluation,encl 1999-09-28
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17241A5001999-10-21021 October 1999 Forwards Rev 3 to Emergency Response Data Sys (ERDS) Data Point Library for St Lucie Unit 1.Rev Provides Replacement Pages & Follows Format Recommended by NUREG 1394, ERDS Implementation, Rev 1,App C ML17309A9981999-10-19019 October 1999 Forwards Revised Epips,Including Rev 3 to EPIP-10 & Rev 25 to HP-202.EPIP-10 Added Onsite Monitoring Points,Made Administrative Changes & Incorporated New Attachments & HP-202 Added Red Team Survey Points ML17241A4811999-10-0101 October 1999 Reports Number of Tubes Plugged During Unit 1 Refueling Outage SL1-16,per TS 4.4.5.5.a ML17241A4701999-09-25025 September 1999 Forwards Info Requested by NRC Staff During 990916 Telcon to Complete Staff Review of Request for risk-informed Extension of Action Completion/Aot Specified for Inoperable Train of LPSI Sys at Plant ML17241A4721999-09-24024 September 1999 Forwards Rev 1 to Plant Change/Mod (PCM) 99016 to St Lucie Unit 1,Cycle 16 COLR, IAW TS 6.9.1.11.d.Refueling Overhaul Activities Are Currently in Progress & Reactor Operations for Cycle 16 Are Scheduled to Commence in Oct 1999 ML17241A4681999-09-22022 September 1999 Requests Restriction Be Added to Senior Operator License SOP-21093 for TE Bolander.Nrc Forms 369,encl.Encl Withheld Per 10CFR2.790(a)(6) ML17241A4671999-09-20020 September 1999 Forwards Completed NRC Form 536, Operator Licensing Exam Data, for St Lucie Units 1 & 2,as Requested in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. ML17241A4581999-09-13013 September 1999 Forwards Info Requested by NRC Staff During 990630 & 0816 Telcons,To Complete Review of Proposed License Amend for Fuel Reload Process Improvement Program ML17241A4531999-08-31031 August 1999 Informs That No Candidates from St Lucie Plant Will Be Participating in PWR Gfes Being Administered on 991006 ML17241A4521999-08-31031 August 1999 Withdraws Relief Request 16 & Suppl Relief Request 15 with Info Requested During 990526 Telephone Conference Re ISI Insp Plan,Third 10-yr Interval ML17241A4501999-08-26026 August 1999 Informs That FPL Has Reviewed Reactor Vessel Integrity Database,Called RVID2,re Closure of GL 92-01,rev 1,suppl 1. Requested Corrections & Marked Up Pages from Rvid 2 Database Summary Repts That Correspond to Comments,Attached ML17241A4371999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data for six- Month Period Ending 990630,per 10CFR26.71(d) ML17241A4461999-08-11011 August 1999 Requests That W Rept Entitled, Evaluation of Turbine Missile Ejection Probability Resulting from Extending Test Interval of Interceptor & Reheat Stop Valves at St Lucie Units 1 & 2, Be Withheld from Public Disclosure L-99-171, Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3)1999-07-29029 July 1999 Forwards Rev 56 to Physical Security Plan.Summary of Changes & Marked Up Copy of Revised Pages Also Encl.Encls Withheld from Public Disclosure Per 10CFR2.790(a)(3) ML17309A9911999-07-26026 July 1999 Forwards Revised EPIPs & Revised Procedures That Implement Emergency Plan as Listed.Procedures Provides Instruction for Operational Support Ctr (OSC) Chemistry Supervisor to Establish Remote Labs at Locations Specified ML17241A4221999-07-22022 July 1999 Forwards List of Proposed Licensing Actions for St Lucie Units 1 & 2,planned During Fys 2000 & 2001,in Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. ML17241A4471999-07-22022 July 1999 Requests That Rev 1 to WCAP-14732 & Rev 1,Add 1 to WCAP-14732 Be Withheld from Public Disclosure ML17241A4151999-07-22022 July 1999 Forwards Revised Relief Request 25 for Second 10-yr ISI Interval for Unit 2 ML17241A4101999-07-16016 July 1999 Forwards FP&L Supplemental Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17309A9881999-07-0707 July 1999 Forwards Rev 5 to EPIP-03, Emergency Response Organization Notification/Staff Augmentation. Rev 5 to EPIP-03 Was Revised to Transfer EP Responsibilities from Training Manager to Protection Svcs Manager ML17241A4011999-06-30030 June 1999 Forwards Info Copy of Florida Wastewater Permit (FL0002208) (Formerly NPDES Permit) Mod,Which Was Issued by Florida Dept of Environ Protection on 990604 ML17241A3971999-06-30030 June 1999 Forwards Suppl Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, as Requested in 990317 Ltr ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17241A3951999-06-29029 June 1999 Provides Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants, Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML17241A3731999-06-17017 June 1999 Supplements Relief Requests 4,11 & 13 for Third ten-year ISI Interval with Info Requested During 990526 Telcon.Expedited Review Is Requested by 990730 to Avoid Negatively Impacting Upcoming St Lucie Unit 1 Refueling Outage (SL1-16) ML17241A3641999-06-14014 June 1999 Submits Supplement to Relief Request 24 with Info Requested by Nrc.In Addition Relief Request 24 Is Identical to St Lucie Unit 1 Relief Request 4 for Third ISI Interval Being Supplemented by FPL Ltr L-99-139 L-99-129, Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3)1999-06-0909 June 1999 Forwards Rev 55 to Physical Security Plan,Summary of Changes & Marked Up Copy of Revised Pages.With Directions for Incorporating Rev Into Plan & Copies of Replacement Pages.Rev Withheld,Per 10CFR2.790(a)(3) ML17241A3601999-06-0707 June 1999 Forwards Correction to Annual Radiological Environ Operating Rept for CY98.Util Has Identified Transcription Error on Last Page of Attachment C of Rept,Results from Interlaboratory Comparison Program 1998 ML17241A3561999-06-0707 June 1999 Forwards Rept Containing Brief Description & Summary of SEs for Changes,Tests & Experiments Which Were Approved for Unit 3 During Period of 970526-981209 ML20195F3941999-05-27027 May 1999 FOIA Request That Memo from J Calvo to Fl Lebdon Re TIA - St Lucie,Unit 1 Environ Qualification of Woodward Governor Controls Be Placed in PDR ML17241A3461999-05-24024 May 1999 Forwards Revised Relief Request 22 to Clarify Several Areas of Relief.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17241A3371999-05-20020 May 1999 Forwards Util Suppl to GL 95-07 Response Re pressure-locking & Thermal Binding of safety-related power-operated Gate Valves,In Response to NRC Second RAI Dtd 990225 ML17241A3391999-05-20020 May 1999 Forwards Notification of Change to Small Break LOCA ECCS Evaluation Model Used for St Lucie Unit 1.Anomaly Was Discovered & Corrected That Resulted in Reducing Calculated PCT for Limiting SBLOCA by More than 50 F ML17241A3301999-05-17017 May 1999 Forwards LER 99-004-00 Re as Found Cycle 10 Psv Setpoints Outside TS Limits,Which Occurred on 990415.Root Cause Determination Not Yet Complete.Suppl to Include Root Cause & Corrective Actions Will Be Submitted ML17309A9821999-05-10010 May 1999 Forwards Rev 36 to St Lucie Emergency Plan, Per 10CFR50.54(q).Executive Summary & Summary of Changes Incorporated by Rev,Encl ML17241A3221999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated IR 05000335/19980141999-04-29029 April 1999 Provides Confirmation of NRC Staff Conclusions Re Cited & non-cited Violations in Insp Rept 50-335/98-14 & 50-389/98-14.Utils Position Re Consideration of Multiple Spurious Actuations in Event of Fire,Reiterated ML17229B1071999-04-28028 April 1999 Forwards 1998 Annual Environ Operating Rept for St Lucie Unit 2. Rept Includes Discussions of 5-inch Barrier Net Maint & Taprogge Condenser Tube Cleaning Sys Ball Loss,As Agreed at First Biennial Sea Turtle Meeting Held on 980120 ML17229B1051999-04-22022 April 1999 Requests That Listed Individuals Be Placed on Official Serve List for Nuclear Matl Safety & Safeguards Info Notices ML17229B1061999-04-21021 April 1999 Notifies NRC of Change in Medical Status of Licensed Operator Pf Farnsworth (Docket 55-21285,license SOP-21094). NRC Form 3996, Medical Exam Certification, Encl.Encl Withheld Per 10CFR2.790(a)(6) ML17309A9851999-04-15015 April 1999 Requests That NRC Review Denial of Appeal from Assessment of Fees Assessed in 981101 Invoice RS0062-99 & Assessment of Fees in Invoice RS0182-99 Which Was Also Denied in 990305 Ltr.Both Invoices Are for Fees Re Inspector GG Warnick ML17229B0951999-04-0808 April 1999 Requests Approval of Encl Revised Relief Request 6,in Response to 990322 Telcon with NRC & 10CFR55.55a(a)(3). Request States That Visual VT-3 Exams Will Be Conducted IAW IWA-2213 & Repairs Will Be IAW Util ASME Section IX Program ML17229B0821999-04-0707 April 1999 Requests Approval of Interim Relief Request 26 Re Repair Requirements for Class 2 ECCS Piping,Per 10CFR50.55a(a)(3) & 50.55a(g)(iii).Alternative Actions Apply Guidance of GLs 91-18 & 90-05 & ASME Code Case N-513.Evaluation,encl ML17229B0851999-04-0505 April 1999 Requests Approval of Encl Relief Request 25 Which Proposes to Use Alternative Requirements of ASME Code Case N-613 in Lieu of Requirements of ASME Section XI Figures IWB-2500-7(a) & IWB-2500-7(b).Action Requested by Aug 1999 ML17309A9791999-03-31031 March 1999 Forwards Revised EPIPs Including Rev 2 to EPIP-00,rev 2 to EPIP-09,rev 2 to EPIP-10 & Rev 10 to HP-207.Summary of Revs Listed ML17309A9761999-03-23023 March 1999 Forwards Revised Epips,Including Rev 4 to EPIP-03, Er Organization Notification/Staff Augmentation, Rev 3 to EPIP-05, Activation & Operation of OSC & Rev 14 to HP-200, HP Emergency Organization. Changes to Epips,Discussed ML17229B0691999-03-19019 March 1999 Transmits TS Pages Requested by NRC for Use in Issuance of Proposed License Amend Re SFP Storage Capacity,Per Soluble Boron Credit ML17229B0721999-03-16016 March 1999 Requests Approval of Enclosed Relief Requests 23 & 24 Re ISI Plan for Second ten-year Interval.Nrc Action Is Requested to Be Complete by Aug 1999 to Support Planning for Spring 2000 Unit 2 Refueling Outage ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML17229B0481999-03-10010 March 1999 Informs That Util Delivered Matls Requested in Encl 1 of NRC Ltr by Hand on 990308,as Requested by NRC Ltr Dtd 990218 1999-09-25
[Table view] Category:UTILITY TO NRC
MONTHYEARML17223A9401990-09-13013 September 1990 Forwards Evaluation of Potential Safety Impact of Failed Control Element Assemblies on Limiting Transients for Facility ML17223A9341990-09-10010 September 1990 Forwards Addl Info Re Generic Implications & Resolution of Control Element Assembly (CEA) Failure at Facility,Per NRC Request.Description of Testing Program for Old Style CEAs in Unit 1 Core Encl L-90-315, Advises That Util Has Completed Evaluation of NUREG-0737, Item II.D.1,SER Item 81990-08-30030 August 1990 Advises That Util Has Completed Evaluation of NUREG-0737, Item II.D.1,SER Item 8 ML17223A9201990-08-28028 August 1990 Forwards Forms NIS-1 & NIS-2, Owners Rept for Inservice Insps as Required by Provisions of ASME Code Rules, Per 900725 Ltr ML17223A8911990-08-20020 August 1990 Forwards Corrected Monthly Operating Repts for Jul 1990 for St Lucie Units 1 & 2 & Summary of Operating Experience ML17348A5041990-08-17017 August 1990 Forwards fitness-for-duty Program Performance Data for Jan-June 1990 L-90-301, Discusses Generic Implications & Resolution of Control Element Assemblies Failure at Plant1990-08-16016 August 1990 Discusses Generic Implications & Resolution of Control Element Assemblies Failure at Plant ML17223A8751990-08-0909 August 1990 Responds to Violations Noted in Insp Rept 50-335/90-14. Corrective Actions:Rcs Flow Determination by Calorimetric Procedure Repeated W/Supervisor of Individual Observing & Individual Counseled by Supervisor IR 05000335/19900141990-08-0909 August 1990 Responds to Violations Noted in Insp Rept 50-335/90-14. Corrective Actions:Rcs Flow Determination by Calorimetric Procedure Repeated W/Supervisor of Individual Observing & Individual Counseled by Supervisor ML17348A4701990-07-27027 July 1990 Forwards Rept Detailing Investigative Analysis of Unsatisfactory Blind Specimen Results,Identification of Causes & Corrective Actions Taken by Lab to Prevent Recurrence,Per Unsatisfactory Performance Testing ML17223A8621990-07-25025 July 1990 Advises That NIS-1 & NIS-2 Forms,As Part of Inservice Insp Rept,Will Be Submitted by 900831 ML17348A4281990-07-25025 July 1990 Forwards Decommissioning Financial Assurance Repts for Plants,Per 10CFR50.33(k) & 50.75(b) ML17223A8631990-07-25025 July 1990 Submits Addl Info Re Implementation of Programmed Enhancements Per Generic Ltr 88-17, Loss of Dhr. All Mods for Unit 1 Completed & Operational.Mods for Unit 2 Schedule for Upcoming Refueling Outage L-90-271, Responds to NRC Ltr Re Violations Noted in Insp Repts 50-335/90-09 & 50-389/90-09.Corrective Actions:Procedural Expectation Re Hanging & Removal of Deficiency Tags Will Be Reemphasized to Personnel Generating Work Orders1990-07-20020 July 1990 Responds to NRC Ltr Re Violations Noted in Insp Repts 50-335/90-09 & 50-389/90-09.Corrective Actions:Procedural Expectation Re Hanging & Removal of Deficiency Tags Will Be Reemphasized to Personnel Generating Work Orders ML17223A8581990-07-19019 July 1990 Forwards Implementation Status of 10CFR50.62 Mod at Facility Re Requirements for Reduction of Risk from ATWS Events for Light Water Cooled Nuclear Power Plants ML17223A8491990-07-18018 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill Oil in Transmitters Mfg by Rosemount. No Rosemount Transmitters Models 1153 Series B,1153 Series D & 1154 Mfg Prior to 890711 Supplied by Different Vendor ML17223A8521990-07-17017 July 1990 Forwards Addl Info Requested Re Generic Implications & Resolution of Control Element Assembly Failure at Plant.Encl Confirms Util Intent to Follow C-E Regulatory Response Group Action Program IR 05000335/19900131990-07-0909 July 1990 Responds to Violations Noted in Insp Repts 50-335/90-13 & 50-389/90-13.Corrective Actions:Maint Personnel Counseled & Aware of Importance of Verifying Design Configuration Requirements ML17223A8421990-07-0909 July 1990 Responds to Violations Noted in Insp Repts 50-335/90-13 & 50-389/90-13.Corrective Actions:Maint Personnel Counseled & Aware of Importance of Verifying Design Configuration Requirements ML17348A3881990-07-0505 July 1990 Requests Audit of NRC Records to Independently Verify Reasonableness of Charges Assessed Against Util,Per 10CFR170 Svcs ML17223A8391990-07-0303 July 1990 Forwards Results of Beach Survey Procedure & Reduction of Field Survey Data,Per Tech Spec 4.7.6.1.1.Unit 1 Updated Fsar,Section 2.4.2.2,concluded That Dune Condition Acceptable Per Tech Spec 5.1.3 ML17223A8381990-07-0202 July 1990 Requests Termination of Operator License for s Lavelle.Util Also Requests That Ltr Be Withheld (Ref 10CFR2.790) L-90-239, Forwards Rev 6 to Guard Training & Qualification Plan.Rev Withheld (Ref 10CFR73.21)1990-07-0202 July 1990 Forwards Rev 6 to Guard Training & Qualification Plan.Rev Withheld (Ref 10CFR73.21) ML17223A8371990-06-27027 June 1990 Provides Details of Implementation Plan Re Recommendations & Schedular Requirements in Generic Ltr 89-10,per 891228 Ltr.Design Basis Review of safety-related motor-operated Valves & Determination of Switch Settings in Progress ML17308A4981990-06-27027 June 1990 Responds to Generic Ltr 90-04 Re Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions ML17223A8341990-06-19019 June 1990 Forwards Corrected Proposed Tech Spec Figure 3.4-2 Per 900207 Application for Amend to License NPF-16,incorporating Revised Pressure/Temp Limits & Results of Revised Low Temp Overpressure Protection Analysis Into Tech Specs ML17223A8241990-06-18018 June 1990 Forwards Revised Combined Semiannual Radioactive Effluent Release Rept for Jan-June 1988. ML17223A8271990-06-18018 June 1990 Forwards Ma Smith 900601 Ltr to WR Cunningham of EPA Requesting Mod to Plant NPDES Permit to Permit Cleaning of Facility & to Establish Discharge Limits for Chemical Cleaning Wastes ML17348A2981990-06-12012 June 1990 Forwards Rev 16 to Topical QA Rept. ML17223A6761990-05-31031 May 1990 Advises That Air Operated safety-related Components Will Perform All Design Basis Events,Per 881227 Ltr.All Actions Required by Generic Ltr 88-14 Complete for Plant ML17348A2651990-05-29029 May 1990 Submits Rept Detailing Investigative Analysis of Unsatisfactory Blind Specimen Results,Identification of Causes & Corrective Actions Taken by Lab to Prevent Recurrence,Per 10CFR26,App A.2.8(e)(4) ML17223A6741990-05-22022 May 1990 Forwards Info Re Status of 10CFR50.62 Mods to Meet ATWS Requirements as of 900515.Plant Change/Mod Package Necessary for Installing ATWS Will Be Issued by 900630.Hardware Procurement for Diverse Scram Sys Approx 90% Complete ML17223A6361990-05-0808 May 1990 Forwards Final Response to NRC Bulletin 88-010, Nonconforming Molded-Case Circuit Breakers. One Untraceable Circuit Breaker Installed in Unit 2 Qualified SPDS & Replaced W/Traceable Breaker ML17223A6281990-04-21021 April 1990 Forwards St Lucie Unit 2 Annual Environ Operating Rept, Vol 1 1989. ML17223A6081990-04-13013 April 1990 Responds to Violations Noted in Insp Repts 50-335/90-02 & 50-389/90-02.Corrective Actions:Nuclear Plant Supervisor Required to Remain in Control Room During Significant Changes in Power Operation & Preventive Maint Upgraded ML17223A6071990-04-0505 April 1990 Responds to NRC Bulletin 89-001, Failure of Westinghouse Steam Generator Tube Mechanical Plugs. Removal & Replacement of Cold Leg Side Plugs of Heat Number 3513 for Unit 1 Completed During Refueling Outage ML17308A4911990-04-0202 April 1990 Forwards Description & Summary of Safety Evaluations of Plant Changes/Mods Reportable Per 10CFR50.59.Repair &/Or Replacement of Protective Coatings on Surfaces Inside Bldg Pose No Unreviewed Safety Question ML17223A5931990-03-30030 March 1990 Forwards Status of 10CFR50.62, Requirements for Reduction of Risk from ATWS Mods at Plant as of 900315.Diverse Scram Sys Module Prototype Fabrication in Progress ML17223A5921990-03-27027 March 1990 Forwards Addl Info on Proposed License Amend Re Increased Max Allowable Resistance Temp Detector Delay Time,Per 891219 Telcon & Advises That Util Request to Increase Plant Resistance Temp Detector Response Time Remain Unchanged ML17223A5831990-03-19019 March 1990 Forwards Response to Generic Ltr 89-19, Request for Action Re Resolution of USI A-47, 'Safety Implications of Control Sys in LWR Nuclear Power Plants,' Per 10CFR50.54(f) ML17347B6191990-03-13013 March 1990 Provides Listing of Property Insurance Programs ML17223A5531990-03-0909 March 1990 Submits Results of Investigation of Error Detected in Dose Assessment During 900124 NRC Evaluated Exercise at Plant. Operator Error Caused Keyboard Hangup Requiring Computer Restart ML17223A5451990-03-0808 March 1990 Forwards Revised Tech Specs Re Steam Generator Tube Repairs, Per 890602 Telcon & Subsequent Discussions W/Nrc ML17308A4871990-03-0707 March 1990 Forwards Response to Eight Audit Questions & Licensing Bases Criteria to Resolve Station Blackout Issue.Util Currently Has Procedures to Mitigate Effects of Hurricanes & Tornados Which Meet or Exceed NUMARC 87-00 Guidelines ML17347B5881990-03-0101 March 1990 Responds to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey. Info Covers Time Spent by Key Power Plant Managers in Responding to Operational Insps & Audits ML17347B6031990-02-27027 February 1990 Requests Approval to Use Code Case N-468 at Plants ML17223A5321990-02-26026 February 1990 Forwards CEN-396 (L)-NP, Verification of Acceptability of 1-Pin Burnup Limit of 60 Mwd/Kg for St Lucie Unit 2. ML20012A0011990-02-26026 February 1990 Notifies That Followup Actions Completed on Schedule & Incorporated Into Rev 25 to Plant Physical Security Plan,Per NRC 890605 Request ML17223A5411990-02-26026 February 1990 Provides Addl Info Re Proposed License Amends Re Moderator Temp Coefficient Surveillance Requirements,Per 891026 & 900109 Telcons IR 05000335/19890241990-02-22022 February 1990 Responds to Violations Noted in Insp Repts 50-335/89-24 & 50-389/89-24.Corrective Actions:Applicable Procedures Changed to Clarify Which Spaces & Blocks Required to Be Completed on Plant Work Order & QC Supervisor Counseled 1990-09-13
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REGULATORY FORNATION DISTRIBUTION SY-N (R IDS).ACCESSlON NBR: 8701130269 DOC.DATE: 87/Oi/OV NOTARIZED:
NO FACIL: 50-335 St.Lucie Planti Unit 1>Florida Power Zc Light Co.AUTH.NANE AUTHOR AFFILIATION MOODY'.Q.Florida Power 8c Light Co.REC IP.NAI'lE RECIPIENT AFFILIATION Record Services Branch (Document Control Desk)DOCKET 05000335
SUBJECT:
Forwards justification for 861010 request for exemption to 10CFR50>App J~Paragraph I I I.D.2(b)(i i)8c addi documentati on re NSHC in support of application for amend to License DPR-67 re requirements for testing of containment air locks.DISTRIBUTION CODE: A017D COPIES RECEIVED: LTR+ENCL SIZE: TITLE: QR Submittal:
Append J Containment Leak Rate Testing NOTES: RECIPIENT ID CODE/NAI'lE PNR-8 ADTS PNR-8 PEICSB PNR-8 PDB LA TQURIQNY>E PNR-8 RSB INTERNAL: ADN/LFNB NRR BAR ADTS NRR PNR-8 ADTS NRR/DSRO/RSIB COPIES LTTR ENCL 1 2 2 1 0 1 1 1 0 1 1 1 1 RECIPIENT ID CODE/NAI'1E PNR-8 EB PMR-8 FOB PMR-8 PDS PD 01 PWR-8 PEICSB ELD/HDS2 08 NRR PAR-A ADTS EIB 04 COPIES LTTR ENCL 1 1 1 5 5 1 1 1 1 1 EXTERNAL: LPDR NSIC 03 05 1 1 1 NRC PDR 02 TOTAL NU})BER OF COPIES REQUIRED: LTTR 25 ENCL 23
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h'"'}'I h., 4 I" 4$<<v P.O.B 4000, JUNO BEACH, FL 33408-0420"gNUwY 09lSA L-87-9 U.S.Nuclear Regulatory Commission Document Control Desk Washington, D.C.20555 Gentlemen:
Re: St.Lucie Unit 1 Docket No.50-335 Containment Air Locks By letter L-86-412, dated October 10, 1986, Florida Power&Light Company (FPL)applied for an amendment to Facility Operating License DPR-67 regarding surveillance requirements for testing of containment air locks.The intent of this proposed amendment is to bring the St.Lucie Unit I Technical Specifications to the same form as those of Unit 2 for air lock testing.By letter dated November 25, 1986 (E.G.Tourigny to C.O.Woody), the NRC stated that the specific exemption included in the amendment should be made in accordance with 10 CFR 50.12.The staff also requested additional information to address each factor under 10 CFR 50.92(c), the No Significant Hazards Consideration.
Attachment I is the justification for the requested exemption to 10 CFR 50, Appendix J, Paragraph 111.D.2(b)(ii).Attachment ll is additional documentation regarding the No Significant Hazards Consideration.
Please contact us if you have any questions about this submittal.
Very truly yours,.Woody roup Vice President Nuclear Energy COW/E JW/gp At tachments (2)cc: Dr.J.Nelson Grace, Region ll, USNRC Mr.Alan Schubert, Florida Dept.of Health and Rehabilitative Services Harold F.Reis, Esquire t 8701130269 870109 PDR ADOCK 05000335I P PDR I~j PEOPLE...SERVING PEOPLE
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JUSTIFICATION FOR THE RE UESTED EXEMPTIONS TO 10CFR50 APPENDIX J 10CFR50.12(a)
(1)In accordance with 10CFR50.12(a)
(1), the Commission may grant exemptions under the following circumstances: (I)the activities to be conducted are authorized by law, (IZ)operation with the exemption will not present undue risk to the health and safety of the public, and (ZIZ)the common defense and security are not endangered.
The evaluations to these standards, contained herein, are in accordance with 10CFR50.12 as revised by final rule dated January 13, 1986.I.The Re uested Exem tions and the Activities Which Would Be Allowed Thereunder Are Authorized b Law There are no other prohibitions of law to preclude the activities which would be authorized by the requested exemption.
Therefore, the Commission is authorized by law to grant this exemption request.IZ.The Re uested Exem tions Will Not Present Undue Risk to the Health and Safet of the Public The evaluation of"no undue risk" considers such factors as the type of plant operation contemplated, the length of time the exemption would be in effect, the existence of alternative means of compliance or compensatory measures, and other safety factors.The results of the evaluations considering these factors are discussed below.Containment Air Lock Testin Exem tion Re uest 10CFR50, Appendix J, Paragraph III.D.2(b) details three explicit air lock testing requirements.
In the proposed amendment to St.Lucie Unit 1, Technical Specification 4.6.1.3, items a, b, and c comply with Appendix J requirements with one exception.
Appendix J, Paragraph III.D.2(b)(ii)requires that"Air locks opened during periods when containment integrity is not required by the plant's Technical Specifications shall be tested at the end of such periods at not less than Pa.".Whenever the plant is in Mode 5 or 6 CONTAINMENT>
VESSEL INTEGRITY is not required.Therefore, if an air lock is opened during either of these conditions, paragraph 1ZZ.D.2(b)(ii)requires that an overall air lock leakage test at not less than Pa be conducted prior to entry into Mode 4.This requirement is excessively restrictive since.it requires a termination of containment entries while preparing to leave Mode 5 until the air lock that was opened and operated in Mode 5 or 6 is tested pursuant to paragraph IIZ.D.2(b)(ii).Primary Containment entries during Mode 5 are important to ensure that surveillance requirements and minor maintenance activities are completed.
The requirements of paragraph IIZ.DE 2(b)(ii.)would apply even if the six month testing requirement of paragraph ZII.D.2(b)(i)had been satisfied.
Subsequent containment entries while in Mode 5 would require retesting of the air lock uti.lized.
Access to containment during Periods when CONTAINMENT
.VESSEL INTEGRITY is required by plant Technical Specifications is governed by paragraph ZIZ.D.2(b)(iii).The existing air lock doors are so designed that a full pressure test at Pa of an entire air lock can only be performed after strongbacks (structural bracing)have been installed on the inner door.This is because the pressure exerted on the inner door during the test is in a direction opposite to that of force experienced during a postulated accident and the locking mechanisms are not designed to wi.thstand such reverse forces..Installing strongbacks, performing the test, and removing the strongbacks, is a cumbersome process requiring at least 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> during which access through the air lock is prohibited.
The Appendix J periodic 6-month test requirement of paragraph ZII.D.2(b)(i)and the 3-day test requirement of paragraph ZZI.D.2(b)(iii)provide assurance that the air lock will not leak excessively if no maintenance which could affect the ability of the air lock to seal has been performed on the air lock and if the air lock is properly engaged and sealed.An exempti.on from paragraph ZZI.D.2(b)(ii)of Appendix J is requested since the proposed amendment to Techni,cal Specification (FPL letter L-86-4 12, dated October 10, 1986)is substantially as safe as the requirement itself.This exemption is included as a part of the NRC's CE Standard Technical Specifications approved December 31, 1981, and is consistent with current regulatory practice and poli.cy.Because of the proposed Techni.cal Specification surveillance requirements, the requested exemption involves a de facto requirement for an air lock seal test in lieu of the ZIZ.D.2(b)(ii)test.Appendix J, Paragraph III.D.2(b)(ii.i)already allows an air lock seal test in lieu of a simi.lar required air lock test at a pressure of not less than, Pa.Thus the functional equivalence of these tests under similar.circumstances has been recognized.
PPL proposes an alternative'est to be conducted during those periods when CONTAIN-MENT VESSEL INTEGRITY is not required by the Plant Technical Specifications and pri.or to entering Mode 4.The alternative test consists of testing the seals of the inner and outer doors by pressurizing the area between the seals and verifying an acceptable leakage rate.Zf, however, maintenance has been performed on the air lock since the last successful test performed pursuant to paragraph IZZ.D.2(b)(i), an overall air lock test will be performed.
It is concluded that there is reasonable assurance against undue air lock leakage provided under the exemption and no material increase in the probability or extent of air lock leakage is to be expected.Therefore, there is no signi'ficant increase in the probability of higher post-accident offsite or onsite doses related to the exemption and no significant increase in environmental impact beyond that experienced without an exemption.
As a result, this exemption will not present undue risk to the health and safety of the public.The Re uested Exem tion Will Not Endan er the Common Defense and Securit The requested exemption will have no impact on the common defense and security.In conclusion, the standards of 10CFR50.12(a)
(1)are met for the specific exemption.
10CFR50.12(a)
(2)In accordance with 10CFR50.12(a)
(2), the Commission will not consider granting an exemption unless special circumstances are present.Special circumstances in which the Commission believes it would be reasonable to grant an exemption are identified in Sections 50.12(a)(2)(i)through (vi)of the revised final rule.The following evaluations pertain to each of these criteria.50.12(a)(2)(i)-"Application of the regulation in the particular circumstances would be in conflict with other rules or requirements of the Commission." The specific exemption request discussed herein is not applicable to the special circumstance of Section 50.12(a)(2)(i).50;12(a)(2)(ii)-"Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." 4 Application of this special circumstance shows that application of the regulation is not necessary to serve the specific purpose.of the regulation.
~i~'The Containment Air Lock leakage rate testing is performed to ensure CONTAINMENT VESSEL INTEGRITY.
CONTAINMENT VESSEL INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses.The restriction, in conjunction with the leakage rate limitation, will limit the site boundary radiation doses to within the limits of 10CFR Part 100 during accident conditions.
3 The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure.As noted above, and in the previous discussion of"no undue risk", the application of the requirements of 10CFR50, Appendix J, Paragraphs ZII.D.2(b)(ii)is not necessary to serve the underlying purpose of these regulations.
This is true since the alternatives presented limit the postulated accident doses to within the 10CFR100 guidelines.
Therefore, the special circumstances of Section 50.12(a)(2)(ii)apply to these specific exemption requests.50.12(a)(2)(iii)-"Compliance would result in undue hardship or other costs that are significantly in excess of those incurred by others similarly situated." This special circumstance is intended to provide equitable treatment to all applicants and licensees.
As noted in the discussion of the Containment Air Lock test exemption request, undue hardships or unnecessary difficulties, in the form of excessive restrictions to Containment access and the cumbersome process of installing/removing strongbacks on the inner door, would result from literal compliance to 10CFR50, Appendix J, Paragraph ZZZ.D.2(b)(ii).Such literal compliance to this Appendix J requirement would not result in any measurable difference in protection to the public health and safety relative to the protection afforded if this exemption is granted.In addition, similar exemptions to these requirements have been granted by the NRC for the Grand Gulf Nuclear Station, Fermi Unit 2, and Salem Nuclear Generating Station.Exemption requests from this requirement have been filed by Perry Nuclear Power Plant, Nine Mile Point Unit 2, Seabrook and the Clinton Power Station.Therefore, with respect to the Containment Air Lock test exemption, the special circumstance of Section 50.12(a)(2)(iii)applies.Furthermore, compliance to this requirement would result in undue hardship and cost through reduced operational flexibility and unwarranted.
delays in power ascension over the life of the plant in excess of those incurred by other similar facilities that have received exemption from the subject Appendix J paragraph.
Performance of the leakage rate tests required by paragraph ZZI.D.2(b)(ii)takes approximately 14'ours per air lock and requires installation of a strong.back device on the insid'e air lock door (Test pressuie applied inside the air lock tends to unseat this door because it is de'signed to seal with accident pressure from inside containment).
This evolution can potentially occur several times during a refueling outage and ultimately can delay mode change on start up.
50.12(a)(2)(iv)-"The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption." The above discussions
'on the Containment Air Lock leak rate test exemption support the basis for this special circumstance.
In the exemption request, the design and/or alternative testing is substantially as safe as the requirements themselves.
Therefore, the special circumstance of Section 50.12(a)(2)(iv)applies to this specific exemption.
50.12(a)(2)(v)"The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation." This special circumstance does not apply to these exemption requests since it is for the operating lifetime of St.Lucie Unit l.50.12(a)(2)(vi)-"There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption." There is not present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption.
REATTACHMENT II)'ETERMINATION OP NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no signif icant hazards consideration are included in the Commission
'regulations, 10 CFR 50.92.These regulations state that no significant hazards consideration are involved if the 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.Each standard is discussed as follows: (1)Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the, probability or consequences of an accident previously evaluated.
The air lock configuration
'or current method of testing is not being changed.Therefore, the PSAR analysis for accident probability, malfunction type, accident type, and consequence of failure has not been affected.(2)Use of the modified specification would not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment will result in no changes to the plant's procedures, structures, systems, mode of operation or components.
No additional tests or experiments not described in the FSAR are necessary to implement the proposed change.(3)Use of the modified specification would not involve a significant reduction in a margin of safety.The margin of safety for Technical Specifications has not been reduced since acceptance criteria will remain unchanged.
Based on the above, PPL has determined that the amendment request does not (1)involve a significant increase in the probability or consequences of a accident previously evaluated, (2)create the probability of a new or different kind of accident from any accident previously evaluated, or (3)involve a significant reduction in a margin of safety;and therefore does not involve a significant hazards consideration.
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