L-94-102, Application for Amend to License DPR-67,revising TS 3.5.2 for ECCS by Removing Option That Allows HPSI Pump 1C to Be Used as Alternative to Preferred Pump for Subsystem Operability

Application for Amend to License DPR-67,revising TS 3.5.2 for ECCS by Removing Option That Allows HPSI Pump 1C to Be Used as Alternative to Preferred Pump for Subsystem Operability

ML17228A575
Person / Time
Site:	Saint Lucie
Issue date:	05/23/1994
From:	Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17228A576	List: L-94-102, Application for Amend to License DPR-67,revising TS 3.5.2 for ECCS by Removing Option That Allows HPSI Pump 1C to Be Used as Alternative to Preferred Pump for Subsystem Operability ML17228A575 ML17228A577
References
L-94-102, NUDOCS 9406010224
Download: ML17228A575 (21)

Text

ACCELERATED DIS UTION DEMONS TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9406010224 DOC.DATE: 94/05/23 NOTARIZED: NO FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power

& Light Co.

AUTH.NAME AUTHOR AFFILIATION SAGER,D.A.

Florida Power

& Light Co.

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

SUBJECT:

Application for amend to license.DPR-67,revising TS 3.5.2 for ECCS by removing option that allows HPSI Pump 1C to be used as alternative to preferred pump for subsystem operability.

DISTRIBUTION CODE:

A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal:

General Distribution NOTES:

DOCKET 05000335 D

A RECIPIENT ID CODE/NAME PD2-2 LA NORRIS,J INTERNAL: ACRS NRR/DORS/ONDD NRR/DRPW NRR/DSSA/SRXB O~~B.CB REG FILE 01 EXTERNAL'RC PDR COPIES LTTR ENCL 1

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1 RECIPIENT ID CODE/NAME PD2-2 PD NRR/DE/EELB NRR/DRCH/HICB NRR/DSSA/SPLB NUDOCS-ABSTRACT OGC/HDS3 NSIC COPIES LTTR ENCL 1

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 22 ENCL 20 D

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PP May 23, 1994 L-94-102 10 CFR 50.90 Florida Power@ Light Company, P.O. Box128, Fort Pierce, FL34954-0128 U. S. Nuclear Regulatory Ccemission Attn: Document Control Desk Washington, D. C.

20555 Re:

St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment Pursuant to 10 CFR 50.90, Florida Power 5 Light Company (FPL) reguests to amend Facility Operating License DPR-67 for St. Lucie Unit 1.

The amendment will revise Technical Specification 3.5.2 for Emergency Core Cooling Systems (ECCS) by removing the option that allows High Pressure Safety Injection (HPSI)

Pump 1C to be used as an alternative to the preferred pump for subsystem operability.

HPSI pump 1C is an installed spare which is not recpired to be maintained in an operable status, and this change is being requested to upgrade the ECCS operability requirements consistent with actual plant operating needs.

It is requested that the proposed amendment, if approved, be issued by January 31, 1995.

Attachment 1 is an evaluation of the proposed TS changes.

Attachment 2 is the "Determination of No Significant Hazards Consideration."

Attachment 3 contains a copy of the appropriate TS pages marked-up to show the proposed changes.

The proposed amendment has been reviewed by the St. Lucie Facility Review Group and the Florida Power

& Light Company Nuclear Review Board.

In accordance with 10 CFR 50.91 (b)(1),

a copy of the proposed amendment is being forwarded to the State Designee for the State of Florida.

Please contact us if there are any questions about this submittal.

Very truly yours, D. A., ager Vice P esident St.

ie Plant DAS/RLD/kw DAS/PSL N1125-94 Attachments Occ. g~e next page I

an FPL Group company 9406010224 940523 PDR ADOCK 05000335 P', PDR

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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment L-94-102 Page 2

cc:

Stewart D. Ebneter, Regional Administrator, Region II, USNRC.

Senior Resident Inspector, USNRC, St. Lucie Plant.

Mr. W.A. Passetti, Florida Department of Health and Rehabilitative Services.

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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment L-94-102 Page 3

STATE OF FLORIDA

)

)

COUNTY OF ST.

LUCRE

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ss.

D. A. Sager being first duly sworn, deposes and says:

That he is Vice President, St. Lucie Plant for the Nuclear Division of Florida Power 8 Light Company,'he 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.

ger STATE OF FLORIDA COVmr OF S

. l-ClC.L(-

The foregoing instrument was acknowledged before me this day of

, is~

by D.A.

ager, who is persona y

own to me and who did ake an oath.

KR<LnJ LAE~

Name of Notary Public My Cmxnission expires

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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment EVALUATIONOF PROPOSED TS CRDQKZS

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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment L-94-102 Attachment 1

Page 1 of 3 Florida Power and Light.Company (FPL) proposes to change the St.

Lucie Unit 1 Technical Specifications (TS) for Emergency Core Cooling Systems (ECCS).

Limiting Condition for Operation (LCO) 3.5.2 will be revised to delete the optional use of High Pressure Safety Injection (HPSI)

Pump 1C as an alternative means of determining B-train ECCS subsystem operability.

FPL has determined that this spare pump option should be removed from the facility TS to ensure consistency with actual plant operatic needs.

The ability to meet required ECCS performance capabilities and the St.

Lucie Unit 1 safety analyses remain unchanged by this proposal.

It th p

tht' t,

"(

CCB subsystem shall include HPSI pump A and the second ECCS subsystem shall include either HPSI pump B or C)."

The calculated cooling performance of the St. Lucie Unit 1 ECCS during postulated loss-of-coolant accidents (LOCA) conforms to the criteria set forth in 10 CFR 50.46.

Plant safety analyses demonstrate that the required performance is achieved with a single operating ECCS subsystem (train).

The minimum complement of components which must function is one high pressure and one low pressure safety injection pump and associated piping and valves, in conjunction with three safety injection tanks.

To ensure that sufficient emergency core cooling capability will be available in the event of a

LOCA, assuming the loss of one ECCS subsystem through any single-failure consideration, LCO 3.5.2 requires two independent and redundant ECCS trains to be operable during Operational Modes 1,

2, and 3 (with pressurizer pressure z

1750 psia)

The A-train includes HPSI pump 1A which is powered by the 4160V AC Emergency Bus 1A3.

The B-train includes HPSI pump 1B which is powered R>y the 4160V AC Emergency Bus 1B3.

A third high pressure

pump, HPSI 1C, is an installed spare which can be permanently aligned to the "B"

HPSI header.

ECCS design provided for energizing this pump via the 1AB "swing-bus" only when powered from

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St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment L-94-102 Attachamxt 1 Page 2 of 3 1B3

and, when in this design electrical configuration, the appropriate Engineered Safety Features actuation signals provided the pump with an auto-start capability.

The St.

Lucie Unit 1

safety analyses,

however, do not take credit for HPSI pump 1C in the evaluation of accidents and transients which involve the ECCS.

HPSI pump 1C is only required to be operable when it is employed in lieu of the preferred B-train pump, HPSI pump 1B, to fulfillthe operability requirements of LCO 3.5.2.

Economic decisions related to safe plant operation and maintenance resulted in rendering the 1C HPSI pump obsolete in that safety significance, operational enhancements, or other potential plant needs do not warrant continuation of the burden associated with maintaining a spare HPSI pump in an operable status.

The associated HPSI-1C piping is presently isolated with administratively controlled, locked closed, isolation valves; and supporting electra.cal components for the pump have been deactivated.

FPL has rarely exercised the option of using the 1C HPSI pump in lieu of the 1B pump to meet the requirements of TS 3.5.2.a, and has no plans to do so in the future.

Plant operating experience has shown that the flexibilityprovided by LCO 3.5.2 to utilize 1C HPSI pump as an option to satisfy, in part, the ECCS operability requirements does not justify the burden of maintaining this pump in an operable status.

To ensure that the facility TS remain consistent with actual plant operating

needs, FPL has determined that the option to use 1C HPSI pump in lieu of 1B HPSI pump should be removed.

Deleting the entire parenthetical statement from TS 3.5.2.a corresponds to the similar high pressure safety injection pump specification for St. Lucie Unit 2.

Removing the subject option does not change the minimum complement of safety injection equipment that is required for safe operation of the facility. Deleting the installed spare injection pump from consideration as an alternative component for operability does not diminish previously evaluated ECCS performance capabilities.

Since credit is not taken for HPSI pump 1C in the St.

Lucie Unit 1

accident and transient

analyses, the assumptions, initial conditions, or the results of such analyses willnot be influenced by the proposed TS revision.

lh 1

St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment L-94-102 Attachment 1

Page 3 of 3 The proposed amendment willdelete the TS reference to a component that is not used for plant operation and is not required for accident or transient rru.titration.

The plant safety analyses are not altered by this LCO revision and the functional capability and performance levels of ECCS equi nt required for safe operation of the facility are not changed.

Therefore, FPL considers the proposed change to TS 3.5.2.a to be acceptable.

St. Luoie Unit 1 Docket No. 50-335 Proposed License Amendment DEiTZZMIHKTIONOF NO SIGNIFICANT EGARDS CONSIDEATION

Jt It4 r.

H

St. Lucie Unit 1 Docket No. 50-335 Proposed License Amendment L-94-102 Attachu~t 2

Page 1 of 2 DLT&KMINATIONOF NO SIGNIFICANT EiAZARDS CONSIDERATION Pursuant to 10CFR50. 92, a determination may be made that a proposed license amendment involves no significant hazards consideration if operation of the facilityin 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 proposed license amendment willremove the option of using High Pressure Safety Injection Pump 1C (HPSI-1C) to satisfy, in part, the Emergency Core Cooling System (ECCS) operability requirements specified in Limiting Condition for Operation (LCO) 3.5.2.

HPSI-1C is an installed spare pump that is not required to be operable unless it is being used zn place of the preferred B-train ECCS high pressure pump.

The required functional response of the ECCS or the required availability of the minimum equipment necessary to accomplish the ECCS safety function willnot be changed by removing the spare pump option from the Technical Specifications.

The calculated coolie performance of the St. Lucie Unit 1 ECCS during postulated acct.dents conforms to the criteria set forth in 10 CFR 50.46 and the ability to achieve this required performance, including considerations of single-failure criteria, is independent from optional use of HPSI-1C.

Therefore, operation of the facility in accordance with the proposed amendment will not involve a

significant increase in the probability or consequences of an accident previously evaluated.

(2)

Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or chfferent kind of accident fram any accident previously evaluated.

The proposed amendment will not change the physical plant or the modes of operation defined in the facility license.

Eliminating

4 Vy lh

St. Luaie Unit 1 Docket No. 50-335 Proposed License Amendment L-94-102 Attachment 2

Page 2 of 2 the option for the licensee to utilize HPSI-1C in place of the preferred B-train ECCS high pressure pump does not involve the addition of new or different types of equipment to the previously analyzed ECCS.

Equipment important to safety will continue to perform their safety functions as previously analyzed and willnot be affected by this proposed amendment.

Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind, of accident from any accident previously evaluated.

(3)

Operation of the facili+ in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

Removing the option to employ the installed spare HPSI pump 1C in lieu of the preferred B-train pump to determine ECCS operability-only removes an operational flexibilitythat has rarely been used by the licensee.

St. Lucie Unit 1 accident analyses do not take credit for an installed spare

pump, the minimum complement of safety injection equipment required for safe operation of the facility and that is required by LCO 3.5.2 is not changed, and the results of plant accident and transient analyses are not influenced by this proposed amendment.

The proposed change does not alter the bases for any Technical Specification related to the establishment of, or maintenance of, a nuclear safety margin.

Therefore, operation of the facilityin accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

Based on the discussion presented above and on the supporting Evaluation of Proposed TS

Changes, FPL has concluded that this proposed license amendment involves no significant hazards

'onsideration.

St. Luaie Unit 1 Docket No. 50-335 Proposed License Amendment ST.

ZUCIE UNIT 1 MRK233-UP TECHNXCAL SPECIFICATION PAGE Page 3/4 5-3