ML17227A729

Documents Request for Temporary Waiver of Compliance from TS 4.6.1.1.a.1, Containment Vessel Integrity Until Emergency TS Amend Submitted.Waiver Would Suspend 31-day SR to Verify That All Penetrations Closed by Manual Valves

ML17227A729
Person / Time
Site:	Saint Lucie
Issue date:	02/12/1993
From:	Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-93-042, L-93-42, NUDOCS 9302190228
Download: ML17227A729 (8)

Text

ACCELERANT DOCUMENT DIST VTION SYSTEM REGULATO INFORMATION DISTRIBUTION TEM (RIDS)

,f', ) '4 ACCESSION NBR:9302190228 DOC.DATE: 93/02/12 NOTARIZED: NO DOCKET FACIL:50-335-St. Lucie Plant, Unit 1, Florida Power 6 Light Co. 05000335 AUTH. NAME AUTHOR AFFILIATION SAGER,D.A. Florida Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Documents request for temporary waiver of compliance from TS 4.6.1.l.a.l, "Containment Vessel Integrity" until emergency TS amend, submitted. Waiver would suspend 31-day SR to verify that all penetrations closed by manual valves.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR t ENCL C7 SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA PD2-2 PD NORRISgJ INTERNAL: ACRS NRR/DET/ESGB NRR/DOEA/OTSB11 NRR/DST/SELB 7E NRR/DST/SICB8H7 NRR/DST/SRXB 8E NUDOCS-ABSTRACT 0GEHB OGC/HDS3 ~REG g~ Ol EXTERNAL: NRC PDR NSIC NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL ~49 ~

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P.O. Box 128, Ft. Pierce, FL 34954-0128 February 12, 1993 L-93-042 10 CFR 50.36 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

RE: St. Lucie Unit 1 Docket No. 50-335 Tem orar Waiver of Com liance This letter documents a request of the Nuclear Regulatory Commission (NRC) for a Temporary Waiver of Compliance of Unit 1 Technical Specification 4.6.1.1.a.l., "Containment Vessel Integrity." This waiver is necessary until an emergency technical specification amendment is submitted by Florida Power and Light company (FPL) and approved by the NRC.

Specifically, this waiver would suspend the 31 day surveillance requirement to verify all containment vessel penetrations are closed by manual valves, blind flanges, or deactivated automatic valves secured in their positions inside containment.

possible to perform the surveillance on all the required It is not penetrations at power because some are inaccessible. All other Technical Specification requirements will remain in effect.

On February 11, 1993 a telephone conversation between FPL and the NRC regarding FPL letter L-93-005 "Reply to Notice of Violation,"

dated January 20, 1993 was held. The result of this conversation was a new interpretation for FPL of what valves constitute containment isolation valves. This new interpretation adds many new penetration components which would need to be verified per our current technical specifications on unit 1. Some of these new components are inaccessible or are in areas of high radiation fields. A temporary waiver of compliance is necessary to avoid dose to those employees who would be required to check these valves until an emergency technical specification change is submitted by FPL and approved by the NRC.

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RE: St. Lucie Unit 1 Docket No. 50-335 Tem orar Waiver of Com liance Page two The emergency technical specification change will be submitted to delete the requirement to check penetration components inside the containment every 31 days and is valid for cycle 11 only.

Following the submittal of the emergency change, a technical specification amendment will be submitted that will revise the unit 1 technical specifications to be like the unit 2 technical specifications. The technical specifications for Unit 2 do not requ.':re +he sur'eillance of valves inside containment every 31 days.

As compensatory measures FPL will:

1. Inform all station operators via the night orders of the need to maintain strict and absolute control over entries into the containment.

2. Brief all Unit 1 containment entry teams prior to entry concerning the importance of ensuring containment penetration isolation valves are left in their required position.

The safety significance and the potential consequences associated with this proposed request are minimal. The bases for this conclusion are:

1. Following Unit 1's last refueling, during COLD SHUTDOWN, all valves, flanges and capped test connections were verified to be closed or installed prior to entry into MODE 4 where CONTAINMENT INTEGRITY is required. These conditions were verified using system valve lineup procedures, local leak rate post test valve lineups and the containment integrity surveillan e valve lineup hich existed at that time.

Additionally, a recent visual inspection was conducted of all accessible containment vessel penetrations. Many of the systems contained herein are flooded or high energy systems which if breached would be detected either through instrumentation showing fluid leakage into the containment or increased radiation levels. Neither of these conditions exist.

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RE: St. Lucie Unit 1 Docket No. 50-335 Tem orar Waiver of Com liance Page three

2. Containment access is restricted physically by locked hatches and annunciated in the control room when any containment hatch is opened. During this cycle entries into Unit 1 containment have been restricted to anomaly inspections, 2 per month, that inspect the accessible areas of containment for any unusual conditions. Unit 1 containment was also accessible during a brief outage to replace a pressurizer code . afety valve. The scope of wo k during this outage was limited and configuration control on all plant systems was controlled through the equipment clearance order procedure or the locked valve deviation log. Neither the anomaly inspections or the outage activities reduced the effectiveness of CONTAINMENT INTEGRITY. The probability of a valve misalignment is small. J

3. NUREG-1432 "Combustion Engineering Standard Technical Specifications" page B 3.6-29, states it is appropriate not to perform a surveillance of isolation valves inside containment every 31 days "since these valves and blind flanges are operated under administrative control and the probability of their misalignment is low."

4. The compensatory measures described above will maintain additional level of assurance that containment integrity is an preserved.

Florida Power and Light has determined that this request does not involve a significant hazards consideration.

1. Operation of the facility in accordance with the proposed w 'ver would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The compensatory containment entries measures associated with strict control of and the assurance of current valve position described above maintain an assurance that containment integrity is preserved. Therefore, the probability or consequences of an accident previously evaluated has not increased.

2. Operation of the facility in accordance with the proposed waiver would not create the possibility of a new or different kind of accident from any accident previously evaluated.

No changes to the physical plant have occurred which would create the possibility of a new or different kind of accident.

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RE: St. Lucie Unit 1 Docket No. 50-335 Tem orar Waiver of Com liance Page four

3. Operation of the facility in accordance with the proposed waiver would not involve a significant reduction in a margin of safety.

The penetration components inside containment are operated under administrative control and the entries into containment are restricted. Compensatory actions associated with the briefing of contai~iment entry teams ensures the probability of misalignment is low. Therefore, there is no reduction in a margin of safety.

Suspension of this 31 day surveillance does not involve irreversible environmental consequences. This temporary waiver of compliance does not result in a physical change to the plant or a change in the procedures used to operate the facility. Therefore, issuance of this waiver will not place the plant in a condition that compromises the health and safety of plant personnel or the general public.

This Temporary Waiver of Compliance was reviewed by the Facility Review Group on February 12, 1993.

Very truly yours, g 4. J'y6'EN

~P Pg D~Sager Vice President St. Lucie Plant DAS/JWH/kw DAS/PSL g862-93 cc: Stewart D. Ebneter, Regional Administrator, Region Senior Resident Inspector, USNRCg St. Lucie Plant II, USNRC