ML17301A106

Application for Amend to License NPF-16,revising Tech Specs to Extend Subgroup Test Interval from 6 to 18 Months

ML17301A106
Person / Time
Site:	Saint Lucie
Issue date:	05/22/1984
From:	WILLIAMS J W FLORIDA POWER & LIGHT CO.
To:	EISENHUT D G Office of Nuclear Reactor Regulation
Shared Package
ML17215A409	List: ML17215A408 ML17215A410 ML17215A411 ML17301A106
References
L-84-133, NUDOCS 8405310309
Download: ML17301A106 (9)

Text

,~REGULATORY

<<FORMATION DISTRIBUTION SY EM (R IDS)ACCESSION NBR:8405310309 DOC.DATE: 84/05/22 NOTARIZED:

YES FACIL:50-389 St, Lucie Planti Unit 2i Florida Power 8 Light Co, AUTH~NAME AUTHOR AFFILIATION l)ILLIAMSi J.N, Florida Power 8 Light Co, RECIP~NAME RECIPIENT AFFILIATION EISENHUT~D.G.

Division of Licensing DOCKET 05000389

SUBJECT:

Application for amend to License NPF 16irevising Tee)Specs to extend subgroup test interval from 6 to 18 months, DISTRIBUTION CODE;A001S COPIES RECEIVED:LTR ENCL g~SI E: L,g/tlg TITLE: OR Submittal:

General Distribution NOTES: RECIPIENT ID CODE/NAME NRR ORB3 BC 01 COPIES LTTR ENCL 7.7 RECIPIENT ID CODE/NAME COPIES LTTR ENCL INTERNAL: ELD/HDS2 NRR/DL DIR REG FILE EXTERNAL.:

ACRS NRC PDR NTIS 04 09 02 1 0 1 1 1 1 1 1 6 6 1'1 1 NRR/DE/MTEB NRR/DL/DRAB NRR/DS I/RAB RGN2 LPDR NSIC 03 05 1 1 1 0 1 1 1 1 1 1 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 23 0 Cl if%fit'i*q~r R'i tl t'N li)I FLORIDA POWER&LIGHT COMPANY May 22, 1984 L-84-133 Office of Nuclear Reactor Regulation Attention:

Mr.Darrell G.Eisenhut, Director Di vi si on of L1 cens1ng U.S.Nuclear Regulatory Commission Washington, D.C.20555

Dear Mr.Eisenhut:

Re: St.Lucie Unit 2 Docket No.50-389 Proposed License Amendment Emergency Safety Features Actuation S stem Instrumentation

-Surveillance Re uirements In accordance w1th 10 CFR 50.90, Florida Power 5 Light Company submits herewith three s1gned originals and forty copies of a request to amend Appendix A of Facility Operating License NPF-16.This Amendment is submitted to extend the subgroup test 1nterval from six to 18 months.The Safety Evaluation accompanying this request demonstrates that the availability of a typical actuat1on channel (SIAS)is 1nsensitive to the chpnge in'he test intetval (0.03$change in avail abiity).In addition, the evaluation of the changed test interval demonstrates only a change in the avail ability of the Auxili ary Feedwater Actuat1on System (AFAS)by 0.02$.The proposed Amendment is described below and shown on the accompany1ng Technical Speci f1 cation pages.Pa es 3 4 3-22 and 3 4 3-23 The surveillance requirements on subgroup rel@testing have been changed from semi-annual to every refueling (eighteen months).In accordance with 10 CFR 50.92, we have determined that the proposed Techn1cal Specification Amendment involves no significant hazards consi der ati ons in that 1 t does not: I)10 CFR 50.92 c I Involve a s1gn1fi cant 1ncrease 1n the probability or consequences of an accident previously evaluated since the safety evaluation demonstrates that the extension of the test interval does not reduce the availability of the actuation channel in any significant amount (0.03%change in availability for ESFAS and 0.02', change for AFAS).Therefore the operation and avail ahility of the Emergency Safety Features Actuation System (ESFAS)-,Instrumentation remains the same as considered in all safety analyses.a ,~j~l c"""~',,3'EOPLE

~SERVING PEOPLE r~~+mh~yjrrur m~>Ii~Isrg~v'~ghragr~hyEW',nj' 1~I Office of Nuclear Reactor Regulation Attent1on:

Mr.Darrell G.E1senhut, Director Page 2 2)10 CFR 50.92 c 2 Create the possibil1ty of a new or different k1nd of accident from any accident previously evaluated s1nce there are no design changes proposed in this Amendment, and since the operation and avail ability of the ESFAS remains unchanged.

2)10 CFR 50.92 c 3 Involve a significant reduction in a margin of safety in that the availability of the ESFAS actuation channel is insensitive to the change in the test interval.The 0.0%and 0.025 change in availability of the channel does not 1nvolve any significant reduction 1n a margin of safety.In'addition, the proposed Amendment meets the'following examples of Amendments that are considered not likely to involve significant hazards considerations as listed in the Federal Register (Vol.48, No.67): Exam le iv: A relief granted upon demonstration of acceptable operat1on from an operating restriction that was 1mposed because acceptable operation was not yet demonstrated.

This assumes that the operating restriction and the criteria to be appl1ed to a request for relief have been established in a prior review and that it is justified in a satisfactory way that the cri teri a h ave been met.The proposed Amendment justifies the relief from the ESFAS subgroup rel~testing interval previously approved in the Technical Specifications.

The analysis demonstrates that the proposed changes resulted in virtually no change in the availability of the actuation channel.The analysis was performed using standard acceptable methodology as described in NUREG/CR-2300 (PRA Procedures Guides)and IEEE-STD 352-1975 (Guide for General Principles of Analysis of Nuclear Power Generating Station Protection Systems).Exes le vi: A change which either m~result 1n some increase to the probab1lity or consequences of a previously-analyzed accident or m@reduce 1n 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 applicat1on of a small refinement of a previously used calculational model or design method.The proposed Amendment would not result in reduct1on in the safety margin.The avail ability of the ESFAS channels are insensitive to the change in the test i nt cry al.The proposed Amendment has been reviewed by the St.Lucie Facility Review Group and the Florida Power 5 Light Company Nuclear Review Board.In accordance with 10 CFR 50.91(b)(l), a copy of the proposed Amendment is be1ng forwarded to the State Designee for the State of Florida.

Office of Nuclear Reactor Regulation Attention:

Mr.Darrell G.Eisenhut, Director Page 3 The proposed Amendment has been determined to be a Class III Amendment in accordance with 10 CFR 170.22, and a check for$4,000.00 will follow shortly.Very truly yours, i Group Vi ce Presi dent Nuclear Energy JWW/JEM/js Attachment cc: J.P.O'Reilly Regional Administrator, Region II U.S.Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atl anta, GA 30303 Harold F.Reis, Esquire Lyle Jerrett, Ph.D., Director Office of Radiation Control Dept.Health 8 Rehabilitative Services 1317 Winewood Boulevard Tall ahassee, FL 32301 P NS-L 1-84-177

'STATE OF FLORIDA COUNTY OF DADE SS~C.0.Woody, being first duly sworn, deposes and says: That he is Vice President Nuclear Operations of Florida Power 5 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.W y Subscribed and sworn to before me this 8 f~.1988.C 9 NOTARY PUBLIC, in and for the County of'-Dpde,', State of Florida.950TARY PUBLIC STATE OF FLORIDA='Y COY4ISSIOH EXP.FEB 14,1988'OROEO-THRU GEUERA!.IRS.URO.My,coITIhi ssi on expi res:

e , l~/F (J 4p)i,