ML17206A656

Requests Amend to App a of License DPR-67 Re Engineered Safety Features Response Time on Containment Isolation Function. Proposed Amend & Safety Evaluation Encl

ML17206A656
Person / Time
Site:	Saint Lucie
Issue date:	02/21/1979
From:	UHRIG R E FLORIDA POWER & LIGHT CO.
To:	STELLO V Office of Nuclear Reactor Regulation
References
L-79-44, NUDOCS 7902270305
Download: ML17206A656 (8)

Text

DOCKET 05000335REGULATO" INFORMATION DISTRIBUTION STEM (RIDS)A~1ACOESSION NBR: 7902270305 DOC~DATE: 79/02/21 NOTARIZED:

NO (FAC IL~50~335 ST~LUG IE'LANT g UNIT 1 P FLORIDA POI'IER 5 LIGHT CO~AUTH~NAME AUTHOR AFFILIATION UHRIG R~E FLORIDA PONER It LIGHT CO~t REC IP.NAME RECIPIENT AFFILIATION STELLOFVN OFFICE OF NUCLEAR REACTOR REGULATION

SUBJECT:

.REQUESTS AMEND TO APP A OF.LICENSE DPR 67 RE ENGINEERED SAFETY FEATURES RESPONSE TIME ON CONTAINMENT ISOLATION FUNCTION~PROPOSED AMEND 8 SAFETY EVALUATION ENCL~DISTRIBUTION CODE: A001S COPIES RECEIVED:LTR

• ENCL'IZE: 'TITLE: GENERALl DISTRIBUTION FOR AFTER ISSUANCE OF OPERATING LIC NOTES;~&CANC(~ddS;gACT ION: INTERNALS 0 REC IP.IENT ID CODE/NAME" 05 BC ding Xf g E 12 15 CORE'ERF BR 17 ENGR BR 19 PLANT SYS BR 21 EFLT TRT SYS COPIES LTTR ENCL 7 7 1 1 2 2 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME 02 NRC PDR 14 TA/EDO 16 AD SYS/PROJ 18 REAC SFTY.BR 20 EEB 22 BRINKMAN COPIES LTTR ENCL 1'1 1 1 1 1 1 1 1 1 1 1 gEXTERNAL:

03 LPDR 23 ACRS 1 1 16 16 04 NSIC.KB 26 1S78 II 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 38 ENCL 38 I~II 0 t P.O.BOX 013100, MIAMI, FL 33101 ygll4~kv~vo%FLORIDA POWER&LIGHT COMPANY February 21, 1979 L-79-44 Director of Nuclear Reactor Regulation Attention:

Mr.Victor Stello, Director Division of Operating Reactors U.S.Nuclear Regulatory Commission Washington, D.C.20555

Dear Mr.Stello:

Re: St.Lucie Unit 1 Docket No.50-335 Proposed Amendment to Facilit 0 eratin License DPR-67 In accordance with 10 CFR 50.30, Florida Power 8 Light Company submits herewith three (3)signed originals and forty (40)copies of a request to amend Appendix A of Facility Operating License DPR-67.The proposed amendment is described below and shown on the accompany-ing pages bearing the date of this letter in the lower right hand corner.Pa e 3/4'3-17 A note is added to Table 3.3-5 to clarify the Emergency Safeguards Feature (ESF)response time requirements on the containment isola-tion function.The proposed amendment has been reviewed by the St.Lucie Facility Review Group and the Florida Power 8 Light Company Nuclear Review Board.They have concluded that it does not involve an unreviewed safety questiqn.Florida Power 5 Light has determined that this is a Class III amendment in accordance with 10 CFR 170.22.A check in the amount of$4,000.00 is enclosed.Very truly yours, Robert E.Uhrig Vice President Advanced Systems and Technology, REU:TCG:cf Attachment cc: Mr.James P.O'Reilly, Region II Harold F.Reis, Esquire 2>0 3oHS PEOPLE~..SERVING PEOPLE TABLE 3.3-5 Continued ENGINEEREP SAFETY FEATURES RESPONSE TIMES INITIATING SIGNAL AND FUNCTION 3.Containment Pressure-Hi h a.Safety Injection (ECCS)b.Containment Isolation***c.Shield Building Ventilation System d.Containment Fan Coolers e.Feedwater Isolation 4..Containment Pressure--Hi

~>-Hi 1 a.Containment Spray RESPONSE TIME IN SECONDS 3P 0*/19 5**3P 5*/20 5*Ii P ,<3P P*/14 P**30 P*/1 7 Pk*<60.0<30.0"/18.5**

5.Containment Radiation-Hi' a.Containment Isolation***b.Shield Building Ventilation System 6.Steam Generator Pressure-Low a.Main Steam Isolation b.'eedwater Isolation 7.Refuelin Hater Stora e Tank-Low a.Containment Sump Recirculation

<30.5*/20.5**

<30.0*/14.0**

<6.9 60.0<91.5 TABLE NOTATION*~Diesel generator starting and sequence loading delays included.**~Diesel generator starting and'equence loading delays not incl'uded.

Offsite power available.

• • • Not applicable to containment isolation valve I-MV-18-3.

ST.LUCIE-UNIT 1 4'/4 3-17 2/2l/7 9 SAFETY EVALUATION Re: St.Lucie Unit 1 Docket No.50-335 Containment Isolation Valve Closure Times Introduction This evaluation"supports proposed changes to Technical Specifica-tion Table 3.3-5 on page 3/4 3-17.A note excluding valve I-NV-18-1 from the Emergency Safeguards Feature (ESF)response time require-ments on the Containment Isolation function is added to the Table.Discussion The purpose of this amendment is to correct an inconsistency between the requirements of Technical Specification 3.3.2.1 and Technical Specification 3.6.'3.1 with regard to containment isolation valve closure time.Specification 3.3.2.1 establishes the Engineered Safety Feature Actuation System (ESFAS)instrumentation channel response times re-quired for the ESFAS to be declared operable.'For the containment isolation function, per Table 3.3-5;the required response time is~20.5 seconds.Under the Technical Specification definition of"engineered safety feature response time", this means that a maximum of'0;5 seconds is allowed.for the time interval from when the mon-itored parameter (con'tainment pressure or containment radiation) exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its-safety function (i.e., the containment isolation valves travel to their required positions).

This implies that all containment isolation valves must close in less than 20.5 seconds, including sensor and circuit time delays.The requirements of'pecification 3.6.3.1 on containment isolation'valve isolation times appear to conflict with the ESFAS requirements of Specification 3.3.2.1'pecifical.ly, Table 3.6-2 lists an isola-tion time of 28 seconds for instrument air supply valve I-NV-18-1.

This is inconsistent with the.required response time of 20.5 seconds specified in Table 3.3-5.It is proposed that a footnote be added to Table 3.3-5 to exclude valve I-NV-18-1 from this requirement.

Evaluation Valve I-MV-18-1 is listed on Table 6.2-16 of the FSAR as one of three valves providing for containment isolation of the instrument air system.The other two valves are check valves I-V-18-957 located inside and outside of containment.

The original design basis for the containment isolation system, as stated in FSAR Section 6.2.4.1, uses check valves as automatic isolation valves outside of containment.

The design basis for penetrations in Class A 1, the penetration class for the instrument air system, as stated in FSAR Section 6.2.4, uses two check valves in series, one located inside and one outside of containment.

The check valves function as automatic isolation valves.Although valve I-MV-18-1 is provided with a CIS closure signal,no credit for.closure is assumed in the, FSAR accident.analyses.The NRC staff reviewed these design bases and in the St.Lucie Unit No.1 Safety Evaluation Report, dated November 8, 1974, in Sections 3.1 an'd6.2.4, stated'ts det'ermination that they met, the intent of the General Design Criteria.It should be further noted that the originally proposed plant tech-nical specifications provided by the FSAR listed.only the check valves for this penetration, which was in accordance with the system design bases.Following the adoption of'the Staff's Standard Tech-nical Specification format, I-MV-18.-1 was added to the CIS isolation valve list on the basis that it received CIS signal, not on the basis that its closure is required by the FSAR accident analyses.This valve provides additional isolation capability beyond that required by the plant's safety design basis.The check valves associated with I-MV-18-1 are seismic Class I.They are periodically leak tested, along with I-MV-18-1, in accordance with plant surveillance leak test procedures.

In summary, the plant's design basis used two check valves in series to achieve automatic containment isolation for the instrument air system penetration.

Valve I-MV-18-1 provides redundant isolation for this penetration.

Since the staff has reviewed this design basis and since valve I-MV-18-1 is not necessary to perform the containment isolation function, the modification of Table 3.3-5 to delete valve I-MV-18-1 from the response time requirements contained therein does not.constitute an unreviewed safety question.Conclusion Based on these considerations, (1)the proposed change does not in-crease the probability or consequences of accidents or malfunctions of equipment important to safety and does not reduce the margin of safety as defined in the basis for any technical specification, (2)there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3)such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment wilI not be inimical to the common defen'se and security or to the health and safety of the public.

~,~I STATE OF FLORIDA))COUNTY OF DADE)ss.Robert E.Uhrig, being first duly sworn, deposes and says: That he is a Vice President of Florida Power&Light Company, the Licensee herein;That.he has executed the foregoing document;that the state-ments made in this said 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.Robert.E.Uhrig Subscribed and sworn to before me this'day of l9 7V NOTARY PUBLIC, x and for the county of Dade, State of Florida Ny commission expires: NOTAUBLIC-STATE OF FLORIDA At LARGE'5'~Y COMMISSION

~EXPIRES MARCH 27, ABBE'.r ((',;~'ONDED THRU MAYNARD BONDING AGENCY i ll'f V 1~~~.%.f/h+h