ML17342A676

Application for Amends to Licenses DPR-31 & DPR-41,modifying Tech Spec Limiting Condition for Operation for Control Room Ventilation Sys to Allow Implementation of Mods to Satisfy NUREG-0737,Item III.D.3.4.Fee Paid

ML17342A676
Person / Time
Site:	Turkey Point
Issue date:	08/25/1986
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	Thompson H Office of Nuclear Reactor Regulation
Shared Package
ML17342A677	List: ML17342A676 ML17342A678
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM L-86-332, NUDOCS 8609020138
Download: ML17342A676 (23)

Text

REGULA AY lhlFQRMATION DISTR IBUTI SYBTEl'l (R IDS)

ACCESSION NBR: 8609020238 DOC. DATE: 86/08/25 NOTARIZED: YES DOCKET ¹ FACIL: 50-250 Turkey Point Planti Unit 3i Florida Paver and Light C 05000250 50251 Turkey Paint Plant> Unit 4i Florida Pounder and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION WOODY'. O. Florida Power 8c Light Co.

REC IP. NAI'lE RECIPIENT AFFILIATION THOMPSON> H. L. Division of Pressurized Water Reactor Licensing A (post 8

SUBJECT:

Application far amends to Licenses DPR-31 Zc DPR-42~ modifying Tech Spec limiting condition for operation For control room vent i l ation sf 5 ta al. loUJ imp cementation oF mod s to sat i sf g NUREQ-0737> Item III. D. 3. 4. Fee paid.

DISTRIBUTION CODE: A046D COPIES RECEIVED: LTR ENCL SIZE:

11+ 2-TITLE: OR Submittal: TMI Action Plan Rgmt NUREG-0737 8< NUREQ-0660 hlOTEB:

RECIPIENT CQPIEB RECIPIENT CO< IES ID CODE/NAI'IE LTTR ENCL ID CODE/NAME LTTR ENCL PNR-A ADTB 1 1 PWR-A EB 1 PNR-A EICBB 2 2 PWR-A FQB PNR-A PD2 LA 1 0 PWR-A PD2 PD 01 5 5 McDQNALDi D 1 PWR-A PSB 1 1 PWR-A RSB 1 INTERNAL: ADM/LFl'lB 2 0 AEOD/PTB 1 1 ELD/HDB4 0 IE/DEPER DIR 33 1 IE/DEPER/EPB 3 3 NRR BNR ADTB 1 1 NRR PAULBQN N. 1 1 NRR PWR-A ADTS 1 ADTB NRR/DSRO EMRIT 1 1 IL 04 1 RGN2 1 EXTERNAL LPDR 03 NRC PDR 02 NSIC 05 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 28

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. BOX 14000, JUNO BEACH, FL 3340B tn" ~i FLORIDA POWER & LIGHT COMPANY lItl 2 5 NQ L-86-332 Office of Nuclear Reactor Regulation Attention: Mr. Hugh L. Thompson, Jr., Director Division of PWR Licensing - A U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Thompson:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-25 I Proposed I icense Amendment Control Room Ventilation In accordance with IO CFR 50.90, Florida Power and Light Company (FPL) 'is submitting three signed originals and forty copies of a request to amend Appendix A of Facility Operating Licenses DPR-3I and DPR-4I.

The proposed amendment modifies the Technical Specification Limiting Condition for Operation for the Control Room Ventilation System to allow implementation of the modifications required to satisfy NUREG-0737 Item III.D.3.4, Control Room Habitability concerns. FPL will begin work on the modifications within 90 days of the implementation date specified in the license amendment.

The proposed change is described below and shown on the accompanying technical specification pages.

Pa es 3.4-6 3.4-7 (added)

The technical specification for the control room ventilation system (T.S. 3.4.7) is revised to permit the system to be inoperable for up to 45 days to implement the NUREG-0737, Item III.D.3.4, Control Room Habitability modifications.

The proposed amendment has been reviewed and approved by the Turkey Point Plant Nuclear Safety Committee and the Florida Power and Light Company Nuclear Review Board.

In accordance with IO CFR 50.9(b)(l), a copy of the proposed amendment is being forwarded to the State Designee for the State of Florida.

In accordance with IO CFR l70.I2(c), FPL Check No. 2143 for $ I50.00 is attached.

09020138 8b0825 PDR ADOCK 05000250I P PDR TCG3/022/ I PEOPLE... SERVING PEOPLE

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Mr. Hugh L. Thompson, Jr., Director Proposed License Amendment Control Room Ventilaton Page Attachment l provides an evaluation of the proposed action in light of the no significant hazards standards contained in 10 CFR 50.92.

Very truly yours, C. O. Woo Group Vi President Nuclear Energy COW/TCG/gp Attachments cc: Dr. J. Nelson Grace Regional Administrator, Region II Mr. Alan Schubert, Manager

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Public Health Physicist Dept. of Health 6. Rehabilitation Services l 323 Winewood Boulevard Tallahassee, FL 3230 I Harold F. Reis, Esq.

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That he is a Grou Vice President of Florida Power Bc Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

C. O. Woody Subscribed and sworn'o before me this doy of , 19'.

C 4 c NOTARY PUBLIC~ in and for the County of D'ade, State of Florida NOTARY PUBLIC STATE OF FLORIOA HY CONNISSION EXP SEPT I8,1989 ires. o oEO TH U GE ERA I S. UiD

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ATTACHMENT I SAFETY AND NO SIGNIFICANT HAZARDS EVALUATION Description of Amendment Request:

The proposed amendment modifies the technical specification Limiting Condition for Operation (LCO) for the control room ventilation system to allow implementation of modifications required to satisfy NUREG-0737, control room habitability concerns. NUREG-0737 NRC Task Action Plan Item lll.D.3.4, Control Room Habitability, required that licensees assure that control room operators will be adequately protected against the effects of accidental releases of toxic and radioactive gases, and that the nuclear power plant can be safely operated or shut down under design basis accident conditions (Criterion l9 - Control Room, of Appendix A, General Design Criteria for Nuclear Power Plants, to IO CFR Part 50).

FPL, in letters dated July 9, 'l98I, June 9 and July 22, l982, August 9 and November 3, l983, and April l7, l985 provided responses to the NUREG-0737 control room habitability concerns, and proposed modifications to meet the criteria identified in NUREG-0737, Item III.D.3.4. The NRC in safety evaluations dated November 25, l983 and May 8, l985 concluded that the control room ventilation system modifications proposed by FPL were acceptable.

Modification of the control room ventilation system to implement control room habitabililty requirements will require that the system be out of service for a period of up to 45 days. The current technical specifications specify that the control room ventilation system can be inoperable (during power operation) for a period of 3 I/2 days. A one time additional 45 day LCO in conjunction with the current 3 I/2 day LCO is necessary to permit implementation of the required modifications without forcing a dual unit outage.

Basis for No Significant Hazards Consideration Determination:

The Commission has provided standards for determining whether a significant hazards consideration exists (10 CFR 50.92(c)). A proposed amendment to an operating license for the facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(I) 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.

The operability of the control room ventilation system (see Figure I) ensures that: (I) the ambient temperature does not exceed the allowable temperature for continuous-duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnnel during and following all credible accident conditions.

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During the period the control room ventilation system will be inoperable, normal operation of the system (i.e. temperature/humidity control and maintenance of a positive pressure in the control room) will be minimally impacted by implementation of the modifications. Portions of the control room ventilation system duct work will be temporarily sealed while the emergency recirculation portion of the system is being modified. Failure of equipment associated with normal operation of the system would not be more likely during the modification period. Therefore, plant operation in accordance with the proposed extension of the LCO would not involve a significant increase in the probability of an accident previously evaluated, or create the possibility of a new or different kind of accident.

As noted above, the modification will primarily be confined to the emergency recirculation portion of the system, whose function is to mitigate the consequences of an accident by ensuring that the control room will remain habitable during and following design basis accident conditions. Under the current design, post-accident control room habitability is ensured by automatic actuation of the control room HVAC system to the emergency recirculation mode of operatio'n in response to a containment ventilation isolation signal. This results, in part, in automatic closure of the normal air intake damper D-l, starting of the recirculation supply fan V-29, and opening of dampers D-2, D-3 and D-I I. Under this confirguration, approximately 250 cfm of outside air makeup is obtained via dampers D-2 or D-3 to provide a positive control room pressure thereby minimizing the amount of unfiltered in leakage and ensuring an acceptable control room environment. Therefore, to ensure a commensurate degree of protection during the 45 day period required to implement the modifications, a temporary filtration system consisting of a high efficiency particulate air (HEPA) and charcoal filter unit, together with an air supply fan and interconnecting duct assembly will be installed as shown on Figure 2. The use of this system as an alternate means of maintaining control room habitabi lilty under accident conditions is considered acceptable for the following reasons:

I. Design requirements for the temporary filtration system, including system sizing, air flow requirements, and filter unit efficiency will be sufficient to ensure that radiation exposure to control room personnel under accident conditions will be less than 5 rem whole body, or equivalent to any part of the body, consistent with the requirements for the existing recirculation system and General Design Criterion l9 (GDC-l9) of Appendix A to IO CFR Part SO. Analyses performed to support use of the temporary filtration system have shown that for an expected system flowrate of 800 cfm, and filter efficiencies of 99, 95, and 95 percent for removal of particulate, elemental iodine and organic iodine respectively, the cumulative whole body dose for the 30-day period following a LOCA would be less than GDC-l9 limits assuming worst-case accident conditions.

2. Necessary system components including the filter unit supply fan and control room air intake damper D-l, will be powered from existing safety-grade plant busses thereby ensuring operability of the system under loss of offsite power conditions. In addition, the temporary system will be designed to operate continuously during the 45-day modification period without automatic actuation or control functions. Also, no manual actions are required to support system operation under accident conditions. Therefore, operability of the system as required to mitigate the effects of design basis accidents concurrent with a loss of offsite power is ensured.

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3. In the unlikely event of a filter unit failure during the 45-day modification period, a second, duplicate unit and associated supply fan will be available onsite and ready for installation to restore system operation. Should the temporary system be rendered inoperable as a result of equipment failure, system testing, or completion of recirculation system modifications, existing Technical Specification action statements for inoperability of the control room ventilation system will apply thereby ensuring safe plant operation in accordance with existing Technical Specification requirements.

4. Functional testing of the temporary system including the backup filter unit will be performed to demonstrate operability prior to use and after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. Testing requirements will be consistent with current Technical Specification surveillance requirements for the existing recirculation system and will include appropriate visual inspections, leak tests, and airflow distribution tests.

5. Installation of the temporary system will be performed in a controlled manner in accordance with existing Turkey Point procedures governing the implementation of plant design changes and modifications. Where necessary, appropriate quality control witness 'nd inspection requirements will be specified by engineering to ensure the acceptablity of the completed insta I l at i on.

6. Operator training will be 'conducted and temporary procedure changes implemented as necessary to support safe and reliable operation of the temporary filtration system. However, as noted in item 2 above, the system will be designed to operate continuously during the modification period and require no manual actions to support operation under accident conditions.

Therefore, necessary training and procedure changes will be minimal. Upon completion of the required system modifications and prior to removal of the temporary system from service, necessary procedure changes will be implemented to support use of the permanent control room HVAC system as shown on Figure 3.

On the basis of the preceding discussions, it can be concluded th'at use of the temporary filtration system to support plant operation-in accordance with the proposed Technical Specification Amendment will not involve a significant increase in the consequences of any accident previously evaluated, or involve a significant reduction in the margin of safety.

In addition, the Commission has provided guidance for the application of the criteria in IO CFR Part 50.92 (as specified above), by providing examples of amendments that are not likely to involve a signficant hazards consideration. The proposed Technical Specification change is similar to the format and intent of

~ example (vi) of the Examples of Amendments That Are Not Considered Likely to Involve Significant Hazards Considerations as presented in the Federal Register Notice of April 6, l983:

Example (vi): "A change which either may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan: for example, a change resulting from the application of a small refinement of a previously used calculational model or design method."

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Therefore, on the basis of the above discussion, operation of Turkey Point Units 3 and 4 in accordance with the proposed amendments would pose no threat to the public health and welfare, and would not involve a significant hazards consideration.

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ATTACHMENTTO LICENSE AMENDMENT AMENDMENTNO. FACILITYOPERATING LICENSE NO. DPR-3 I AMENDMENTNO. FACILITYOPERATING LICENSE NO. DPR-4 I DOCKET NO. 50-250 AND 50-25 I Revise Appendix A as follows:

Remove Pa es Insert Pa es 3.4-6 3.4-6 3.4-7 TCG3/022/3

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