IA-85-729, Further Response to FOIA Request for NRC Insp Rept & Related Records Re Evaluation of Auxiliary Feedwater Sys.Documents Listed on Encl App Available in Pdr.Search for Addl Document Continuing

Further Response to FOIA Request for NRC Insp Rept & Related Records Re Evaluation of Auxiliary Feedwater Sys.Documents Listed on Encl App Available in Pdr.Search for Addl Document Continuing

ML20203H152
Person / Time
Site:	Turkey Point
Issue date:	01/06/1986
From:	Grimsley D NRC OFFICE OF ADMINISTRATION (ADM)
To:	Weiss E HARMON & WEISS
Shared Package
ML20197K090	List: IA-85-729, Further Response to FOIA Request for NRC Insp Rept & Related Records Re Evaluation of Auxiliary Feedwater Sys.Documents Listed on Encl App Available in Pdr.Search for Addl Document Continuing ML20197K085 ML20197K118 ML20198A364 ML20198A368 ML20198A371 ML20203H152
References
FOIA-85-729 NUDOCS 8604290438
Download: ML20203H152 (2)

Text

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/ 'o,, UNITED STATES g.

! o NUCLEAR REGULATORY COMMISSION

j WASHINGTON, D. C. 20555 **k 5j

%,**.../

Jg 0 6 W Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan 2001 S Street, NW, Suite 430 IN RESPONSE REFER Washington, DC 20009 TO F01A-85-729

Dear Ms. Weiss:

This is in further response to your letter dated October 31, 1985, in which you requested, pursuant to the Freedom of Information Act (F0IA), copies of

, the NRC inspection report and related records regarding the evaluation of the auxiliary feedwater system at Turkey Point Units 3 and 4.

Copies of the 15 documents listed on the enclosed Appendix F are being placed in the NRC PDR in folder F01A-85-729 under your name.

The NRC has not completed its search for and review of documents subject to your request. We will respond as soon as those actions are completed.

Sincerely,

& $ /fn-w Donnie H. Grimsley, Director Division of Rules and Records Office of Administration

Enclosure:

As stated Bgg 42ge860106 WEISS-85-729 PDR

l Re: F01A-85-729

. APPENDIX F r

1. 10/16/79 Letter to R. E. Uhrig from D. G. Eisenhut; NRC Requirements'For Auxiliary Feedwater Systems At Turkey Point Plant Units 3 and 4.

(12 pages)

2. 12/24/81 Letter to R. E. Uhrig from M. Grotenhuis; Issuance of Amendment No. 75 to Facility Operating License No. DPR-31 and Amendment No. 69 to Facility Operating License DPR-41 for Turkey' Point Units 3 and 4. (23 pages)

3. 09/15/82 Letter to R. E. Uhrig from S. A. Varga; TMI Action Plan Item II.E.1.2, Auxiliary (Emergency Feedwater Systems) Automatic Initiation and Flow Indication. (24 pages)

4. 11/04/82 Letter to R. E. Uhrig from D. G. Mcdonald; Issuance of Amendment No. 89 to Operating License DPR-31 and Amendment No. 83 to Operating License DPR-4 for Turkey Points Units 3 and 4. (15 pages)

5. 01/31/83 Internal FPL memo _ to W. C. Miller from L. Goebel; AFW System Upgrage. (17 pages) al

6. 07/22/85 Slide Presentation - Turkey Point Plant Aux. ~Feedwater System'.

(5pages)

7. 07/23/85 Memo to H. Denton, et. al., from P. S. Tam; Daily Highlight -

Turkey Point Unit 3. (1 page)

8. 07/25/85 Memo to H. Denton, et. al. from D. G. Mcdonald; Daily Highlight -

Turkey Point Units 3 and 4 Part>21 Notification Relating to Main Steam Isolation Valve Closure Time. (6 pages)

9. 08/13/85 Operating Reactors Events Briefing (No. 85-13). (7 pages)

10. 09/16/85 Operating Reactors Events Briefing (No. 85-16). (10 pages) i 11. Undated Reportable Event No. 01531, Unevaluated Information. (1page)

,12. Undated Reportable Event No. 01532, Unevaluated Information. (1 page)

13. Undated . Reportable ~ Event No. 01534, Unevaluated Information. (1 page)

14. Undated Reportable Event No. 01555, Unevaluated~Information. (1 page).

15. 10/29'/85 Memo to Chairman Palladino from W. J. Dircks; re: 9/20/85

' letter from ACRS on Turkey Point. (5 pages)

, /

}

HARMON, WEISS Oc JORDAN.

2001 S ST R EET. N.W.

SulTE 430 WASHINGTON, D.G. cocoo TELEPHONE G All McGREEVY H ARMON (202)320 3500 ELLYN R. WEISS wtLLIAM S. JORDAN, all OlANE CURRAN DEAN R. TOUSLEY October 31, 1985 Mr. Joseph Felton, Director FREGOOM OF INFORM A HON Division of Rules and Records ACI M 7 "EI Of fice of Administration [QfQ-gj . [y U.S. Nuclear Regulatory Commission Washington, D.C. 20555 h //- -[8 RE: FREEDOM OF INFORf1ATION ACT REQUEST

Dear Mr. Felton,

Pursuant to the federal Freedom of Information Act, I h e reby request a copy of each of the following:

1. NRC's recent " system evaluation" of the auxiliary feedwater system at Turkey Point Units 3 and 4. This evaluation is more fully described in the attached article which appeared in the October 29, 1985 issue o f "Inside NRC".

2. All related documents including but not limited to reports, memoranda, notes, draf ts prepared by NRC staf f and/or contractors in connection with this system evaluation.

3. All documents prepared by Florida Power and Light and/or its contractors, employees or agents in connection with this system evaluation or in response to the evaluation.

Your response within ten days will be appreciated. ,

Very truly yours,

,w'f }'eD , u Ac,

,~ . ;a Ellyn R. Weiss ENC.

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w Inside NR.C An exclusive report on the U.S. Nuclear Regulatory Corninission iM Vol. 7. No. 22 - ( Atober 29,1985

~) PROTESTS NRC REVIEWS OF INPO-ACCREDITED TRAINING PROGRAMS The Institute of Nuclear Power Operations (INPO)is asking NRC Executive Director for Opera-tions William Dircks to stop the NRC staff from checking on utihty traimng programs after INPO has accredited them. INPO President Zack Pate has also wntien the NRC commissioners asking their help greining in the staff. The staff activities, Pate said, "are impedmg or undermming INPO efforts."

-, The NRC commissioners agreed last year not to pass new training rules for two years so INPO could prove that voluntary utihty efforts to meet INPO accreditation standards produced superior re-sults. The commissioners said, however, that the staff would monitor the situanon (INRC,1 April,13)

In July, INPO and NRC signed a coordination plan. Pate wrote:"INPO has cooperated fully with the NRC in :his area and recognizes the NRC's need to monitor trainmg progress." But some recent NRC actions, he said, "are not in keeping with the...coordmation plan."

Pate complained of staff actions in three areas. First, he said, the staff has distributed Nureg/CR-4344, " Instructional Skills Evaluation in Nuclear Industry Training." The document duplicates materi-al in two INPO documents but contains some different recommendations, he said, adding. "NRC issu-ance of documents that duplicate INPO training-related documents is specifically precluded by the coordination plan."

Second, without consulting INPO. NRC's Office of Nuclear Reactor Regulation (NRR) an-nounced it will conduct " post-accreditation reviews of(INPO) accredited training programs using new-ly developed criteria," Pate wrote. " Superimposing these reviews on the accreditation process and the performance-oriented inspections conducted by I&E (NRC Office of Inspection & Enforcement) and (Continurcf on pate 4]

C FIRST NRC ' SYSTEM EVALUATION' St AMS TURKEY POINT MAINTENANCE The first of NRC's new system evaluations, on the auxiliary feedwater (AFW) system at Florida i'ower & Light Co.'s (FP&L) Turkey Point-3 and -4, has resulted in a report harshly cntical of FP&Ils mamtenance, training modification design and testing, and quahty assurance at the plant. Ac-cc,rding to the report, a special NRC inspection team assessing the operational readiness of the AFW system found modifications made without analysis of their safety impacts, operators untrained in the system's peculiarities, design flaws that could lead to uncontrolled radiation releases in a steam genera-tor tube rupture or total loss of AFW flow control valves, a maintenance backlog that kept control room instruments out of service for months, and a maintenance training program suspended since March 1984 while the training department prepared programs to meet Institute of Nuclear Power Op-erations (INPO) accreditation requirements.

The inspection is the first of at least three system evaluations that the NRC staff plans to perform while developing new performance-based regulatory criteria. The other plants have not been named.

The shift is occurring as the NRC staff takes a tougher regulatory line after a series of plant mishaps blamed on poor plant management (INRC,14 Oct.,1). Ilesides forcing management attention to what NRC perceives as lingering maintenance problems at Turkey Point (INRC. 30 Sept.1) the staff will be using the inspection findings to develop new methods to get substantial changes at poorly managed plants.

For the inspection, NRC called in design and engmeering expert; from NRC headquarters and Region 11 and NRC contractors. They started with the AFW system as desenbed in the operating li-cense and then traced modifications, looking for design control, maintena ice and surveillance quality, operating procedures, and adequacy of testing, especially after modifications or maintenance in his let-e N INSIDE THIS ISSUE Cammissioners retect CPA L EQ deadline change - p5 NRC staff urtres Wugher safety goal plan -pt:

Rancho Seco restart taming in dout t -p5 ACRS members canicize indian Point ruhng -Pt 3 hatts Bar welding issues resurfacing - p6 O>manche Peak paint enemptain chauenged -pt 3 Antidrug poucy snagged on enforcement -p7 Assetsune ensists on applying backfit rule -pt5 Re,earch rmrients to aid plant oper_a_ewins -p9 f#~d year 0985 fines charted -pt 5-20

~ ~

e .F O ,

ter accompanying the inspection report, James Taylor, director of the Office of Inspection & Enforce-ment (IE), said 10 findings could result in enforcement action.

FP&L has not yet responded formally to the report, according to spokeswoman Stacy Shaw, but the utility has protested several findings. in the exit interview and in a subsequent Ictier (INRC,14 Oct.,19). Taylor noted that management began a " performance enhancement program" after receiving low ratings on the last SALP (systematic assessment of licensee performance) report, but said, "The in-spection team noted that performance in the functional areas of maintenance, surveillance testing, and design changes and modifications has not markedly improved." Taylor said he understood the utility "took prompt action...to address the team's safety concerns," adding NRC will follow up.

Specific findings from the report included:

-The safety grade backup air system for the non. safety grade instrument air system, vital to keeping AFW flow con:rol valves (and the system) operating, had never been functionally tested though it had been "substantially modified." A test showed op-rators had on'y six to seven mmutes, in-stead of 15 to 20 minutes, to valve in new nitrogen bottles to the backup system in the worst case. Re.

sponse would have been hampered by an incorrect annunciator response procedure, and the annuncia.

tor alarm set-point was halved without a safety evaluation. "The team concluded that the weaknesst identified .could have all contributed to a significant risk of a loss of AFW flow."

-The AFW system is shared by Turkey Point-) and -4, and its design basis requires that onc pump be able to remove decay heat from both units. Ilowever, operators must assure the correct divi- '

sion of flow between the units. Operatois were not trained in the situation and their procedures did not cover it.

-The AFW turbine steam supply isolation valves could not be shut from the control room if an AFW actuation signal was present. Operators had no training to recognize the signaPs override of con-trol room switches. "The team concluded that the lack of operator awareness that the steam flowpaths in question could not be isolated remotely from the control room could have resulted in an unnecessary and potentially significant radioactive release to the environment following a steam generator tube rup-t u re."

- Programmatic weaknessess" were found in maintenance. including "the consistent failure to evaluate the root cause of equipment malfunctions and to trend these failures to provide input to the preventive maintenance program," though key parts of the AFW system had experienced recurrent compcnent failures.

(

- Formal classroom training sessions for maintenance technicians had been discontinued in Au-gust 1984. Licensee management stated th:t maintenance training had been discontinued to dedicate training resources to developing training materials required to support INPO accreditation of the main.

tenance training program....A very limited amount of on-the-job training and vendor supplied training ,

had been conducted since the decision to discontinue classroom training."

- Over half of the I&C (instrument & control) technicians that conduct surveillance tests (15 of 27 at the time of the inspection) had an average ofless than 6.5 months of experience at Turkey Point.

He electrical and mechanical maintenance groups have also recently experienced high turnover rates among their technicians."

- Management controls did not exist to ensure that safety related maintenance activities were performed by qualified personnel.. Maintenance procedures generally lacked detail. Complex safety re-lated maintenance activities were often considered to be within the scope of the ' skill of the trade

• and therefore not requiring procedures. . Post. maintenance testing requirements were typically not included as part of electrical and I&C plant work orders (PWOs)."

-The apparent result was "a large backlog of safety related PWOs throughout both units."

Steam jet air ejector process radiation monitors had been out of service about six months, the unit 4 containment sump high level annunciator had been out since December 1984 and two of four post-acci- l dent sump level me,nitors out since February, and several area radiation monitors on both units were l i

out of service for greater than six months. Both units had leaking power operated relief valves (porvs) and unit 4's block valves also leaked, resulting in elevated temperatures in the common discharge pipe downstream of the pressurizer safety relief valves. As a result of the last, all three unit 4 control room annunciators continuously showed alarms, impairing operators' ability to recognize relief valve failures. l

- During a system walkdown, the drain lines on the turbine casings and the exhaust silencers l were noted to be hot. Water was flowing from the drains on the A and C turbines. The steam supply ,'

isolation valves for the A and C turbines were leaking and allowing steam to reach the turbines even i. -

though the valves were closed....The associated steam supply valves on umt 4 also appeared to be lea-king.. he 11 turbme did not appear to have any leakage from its steam supply valves....No current 2- INSIDE N.R.C. - October 25,1985

s . ~ . % . . es- _ s ..~ .e ,

' PWOs were noted on the leaking steam supply valves." , l

• -Seismic qualification "was not being properly maintained," with control air lines not proper y anchored and a temporary scaffolding erected above all four instrument racks for both flow transmitters so that a collapse could have failed all AFW.

" Programmatic weaknesses" were found in the design ch'ange process. "He engin (i' often did not provide post-modification testing requirements.... Modifications were install detailed design analysis.... Design bases for safety related systems were difficult to retrieve found the utility " frequently base (d) design changes on engineering judgment that the ne bounded by the original design analysis. Documentation justifying the engineering judg did not exist." lt "Four of six AFW steam supply isolation valve motor operators

-At least part ai lly as a resu , d protection for were changed from AC to DC motors without adequate design analysis. Motor l overloa i d to the new DC motors was not properly sized. Further, the new power cables were not proper The y s ze ensure adequate operating voltage for the motor operators in the event of a loss of off-site p .

licensee had not performed any cabic sizing calculations to support this design l change."

d

-Petentials for common mode failures were introduced by design changes. Common re ays an hmit switches were put into redundant Train A and B flow control circuits and design of nitrogen backup systems could fail redundant control room annunciator circuits. h

-Safety related station batteries were modified but no calculations were done to show t e ne

' ' ones could meer the design basis and plant procedures and technical specifications were not c recognize the new batteries' different requirements. the prop-

- Excessive

" reliance was placed on operator action instead of design features to ensure er functioning of the AFW system."

- A" review of the corporate and site quality assurance (QA) auditing activities revealedfthat these audits, as implemented, neither had identified nor were capable of identifying quality concerns o a technical and operational nature" like those NRC found. "Both the corporate vendor audit and  !

plant audit programs were designed to assure that QA programs met NRC requirements a commitments from a programmatic basis only.. (which) meant that FP&L management was not re-ceiving important feedback on the quality of activities affecting the safe operation of the plant."

Several industry sources said FP&L was objecting to some of the report's conclusions i and pres

( to have them changed. They said industry groups are concerned about the apparent aew militancy n the NRC staff and will try to get the NRC commissioners or friendly members of Congress to inter-vene.

In developing performance indicators, NRC is also conducting special maintenance program re-views at seven plants. William Russell of the Office of Nuclear Reactor Regulation said NRC is ahea m developing performance indicators in the maintenance area since staffers have already been plants to determine where industry initiatives are working and where NRC action is needed (IN Aug.,1). Turkey Point is also on that list, with a review scheduled for later this year, along with Caro Ima Power & Li?

• Cols Brunswick and Arkansas Power & Light Co.*s Arkansas Nuclear One. Pro-gram reviews has dready been done at Northeast Utilities

• Millstone. Toledo Edison Co.*s Davis-Besse, Sacramento Municipal Utility District's Rancho Seco, and Wisconsin Public Service Corp.'s Kewaunee.

Region 11 Administrator Nelsori Grace noted INPO and the Nuclear Utility Management'& Ilu-man Resources Committee (Numarc) want NRC to stay out ot mana;;ement areas and said he agreed NRC should not be managing plants. But, he said,"We can and must touch on those areas, to the ex-tent that all of our (inspection) findings must be laid at the doorstep of top management....The buck stops there."-Margaret L kan and Eric Lindeman. Washington MERITS OF USER FEE SCHEME TO BE RESOLVED BY HOUSE-SENATE CONFERENCE The merits of a proposed scheme by which NRC would be required to collect user fees to offset 50% ofits authorized budget will be battled out by House and Senate conferees when a budget confer-ence begins meeting this week. The House was expected to approve by the end of last week its version '

of the budget reconciliation bill, which includes the user fee scheme. Since the proposal is not included in the Senate version of the bill,it will first be considered by that body in conference.

The conference is expected to cominue for at least a week. so it is uncertain when the user fee

{

provision will be considered. In the meantime. industry lobbyists are working to kill the provision, questioning the basis for setting budget recovery at 50%. Fighting in the industry's corner is Rep. Dan Rostenkowski(D-Ill.), chairman of the llouse Ways & Means Committee, who argued before the Rules Committee that the user fee is really a tan and so must be considered by his committee first. The 3

' INSIDE N.R.C - Octoba 28,1985

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3. Vtrify t'at the AFa' puegs in your plar:t will supply, the necessary e-( a flOCLEAR f '3 aas REGULATORY . C.OMMISSION 4

he steam generator (s) as determinee ty itses 1 and 2 s, i 7 aweto m c.

flow t v

., ,. ;t'!sta g ypt a'Jove Co' sidering a s1 gle failure. Ident*fyphe rgin in sisfr.g # " **I

• the pc3 flow to allowjfer pur.p recirculat4n flow seal leakage and ppy wear.

I L

Dr. Robert E. Uhrig, Vtce-President Advanced Systens and Technology i

f Florida Po=er and Light Company P. O. Son 529100

[ <

Miamt. Florida 33152 l1

Dear Dr. Uhrtg:

1. $U8 JECT: NRC REQUIREMENTS FOR At;4LIARY FEEDWATER SYSTEMS AT TUREEY POINT PLANT,

• i g }

i UNITS 3 AND 4 The purpose of this letter is to advise you of our requiren.nts for the

.)

' availlary feedwater systems at the subject facility. These requirements were identified durtog the course of the ffl4 Su11ettn3 and 3*ders Task

% force review of operating reactors in Itght of the accident at Three Mile I Island, Unit 2.

' ,I Enclosure 1 to this letter identiftes each cf the requirent ts ap Itcable bO to the subject fac111ty. These requironents are of two typi s. (1 geu ric g )j requirements applicable to most Westinghouse-destfned opera.Ing p ants, and (2) plant-spectf f c requirenents appitcable only to the subj ect fact 11ts.

h  %

f Enclosure 2 contains a generic request for additional infor4ation regarding aust1tary feedwater system flow requirements.

4 The designs and procedures of the sdject factitty should be evaluated against the applicable requirements specified in Enclosure 1 to determine the degree to which the facility Currently Conforos to these requirements. The results k/

I i of this evaluation and an associated schedule and coursitment for implementation of required changes or actions should be provided for IftC staff review within j

thirty days of receipt of this letter. Also, this schedule should indicate your date for sdaittal of information such as design changes, procedure changes or Technical Spectftcation changes to be prvvided for staff review. You may also l

'g. provide your response to the items in Enclosure 2 at that time.

In addition to the requirements identified in thf s letter, other requirements which may be applicable to the sdject fact 11ty are espected to be generated of the Eu11etins and Orders Task Force. Such requirenants are those resulting from our review of the less-of-feedwater event and the small break loss-of-coolant accident as described in the Westinghouse report WCAP 9600,

• Report on Small l

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Dr. Robert (, 'Jhrig -2* , . . .

- ' * * .gn .

Robert [. Uhrf g t;u- .* 8 W Flortsa Power and Lf ght Company 3

'reak Accidents for Westinghouse N555 System." Our spectffe concerns include systems reltability (other than the auxiliary feedwater system), analyses.

guideltees and procedures for operators, and operator training. cc: Mr. senert Lowenstein, tsquf re Lowenstein. Newman. 8els and Aselrad We plan to identify, in separate correspondence, the requirenen's resulting 1025 Connecticut Avenue. N.W.

from the additional itens from the Bullettns and Orders Task Force revfew. Suite 1214 Washington, D. C. 20036 Sincerely.

Environmental and tirban Affairs Lfbrary p Florida International University Mient. Flortea 33199 924 NN Mr. Norman A. Coll. Isqufre Carrell G. (flenhut. Acting Director Olvisfon of Coerating Reactors Steel. Hector and Davis Of fice of Nuclear Reacter Regulation la00 Southeast First ustional Sank futiding

Enclosures:

lttest. Florida 33131 As stated Mr. Henry Yaeger. Plant Manager Turkey Pofnt Plant Florida Power and Light Company P. O. 80s 013100 Mtasf. Florida 33101 Mr. Jack Shreve Office of the Public Counsel Room 4. Molland Butlefag Tallahassee. Floride 32304  ;,

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E-293

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(NCtosung 1 operated valves assectated with CST's are locked open. A secondary I.lg (w) TuesEY POINT UNITS 3 & 4 water supply comes from the non-selseic Category 1 water troasment AUXILIAtf ffEDW47tt $YSTEMS systee. An addittenal feedwater s@ ply can be provided free the mala feeenater syntes of the adjacent Units 1 & 2 (non-nuclear power System Descefption plant).

K.16.1 I.16.1.1 Confleveatton-overall Oesion The aumf1fary feeowatee system (AFVS) for the Turkey Point plant X.16.1.2 Commenents - Desfon. Classificatten (Units 3 & 4),as shown in Figure 1.conststs Of three steam turbine the AFVS to designed according to _setsetc Category I requirements.

delven pumps, f.e. , one pump normally alf gned to each unit and the The AFVS to classiffed as en engineered safety related system and its third pump to a shared standby for efther unit. Each pump normally assectated instrumentation and controls are designed according1'y.

delfvers 600 gpa (9 2775 ft head) feedinater to the three stese generators ($G) in each unit. Also, the control roce operator can X.16.1.3 Power Sources manually direct flow from any pump to all three stese generators of The turbine defven pu ps are supp11ed with steam from the main steam either unit.Under a design basis accident, only one pmp would be Ifne of either er both units upstream of the MSIV. The operator required in order to cool the plant down to a condftton where the RHR normally selects the steam supply from the Unit thfCh has lost fte system can be put inte operation to contfnue the safe plant shutdown normel feedwater supply. The turbinee have en atmosphere exhaust.'

process. Steam can also be supplied from the Unit having nereal feceseter supply and from an euzfilary steam syntes connectfen te Units 1 & 2.

Primary water supply for the AFWS comes from the selsele Category I The turbine driven puap steen supply ifne has a normally closed AC condensate storage tanks (C$T) of both units. Each CST has a capacity motor operated valve in sortes with a norme11y closed DC solenefd air of 250.000 gallons with a minimum reserved storage capacity of operated valve. Na pump discharge contret valves are DC solenefd 165,000 gallons of deetneralf sed water. With this quantity of water, operated afr valves.

the Itcensee indicated that the unft can be kept at hot standby conditten for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> and then cooled to 350*F, at which potnt the x.16.1.4 Instrumentatten and Conteel RHR systee can be put in service, or the unit Can be kept at het X.16.1.4.1 Centrois

• standby condition for about 23 additional hours. All the manually The steam generator water level is manually controlled by the centrol reos operater using either one of the DC solenete operated air valves.

E-2'A i

. .is -

4 3

X.16.1.5 Testing Local manual operetton of these valves can be performed on less of The Turkey point Units 3 and 4 Technical Spectftcattens require the compressed air. The AN pump feedwater discharge rate is always greater than the turbine steam consumption when the steam pressure is followl tutig d W mi% f&W mh

1) Monthly test of each aux 111ary feeeeeter pg to run for 15 etnutes higher than 120 pstg. When the stese eressure is reduced to 120 pstg*

and verify a flow rate of 600 gue to the steam generators.

the RHR systee is started and the AN pumps are shut down.

2) Tests of aust11ary feedwater discharge valves during the monthly pump tests.

X.16.1.4.2 Information avellable to Operator

3) Tests of steam supply and turbine pressure valves during senthly Low water level in the Condensate storage tank will alane and annunCiste in the esta control room. In addition. AN flow Indication, SG water puep tests.

r levet, and Contret valve posttlen indtCatton are provided in the These tests are designed to verify the operability of the aunt 11ery control room. I feeeneter system and its ability to respond properly when required

.-.s X.16.1. e. 3 Tattiatina Stenals for Automatte Operetten X.16.1.6 Technteel Specificattens All three A N pumps will automatically start by any of the following The Turkey point Units 3 and 4 Technical Specificettens provide,for signals from etther etnttr the following lietting condittens for operatten with respect to the (a) safety injection Ant 11ery Feeeneter System:

(b) tow-tow water tevel in any of the three steam generators 2 .

1) Two out of three ANS pumps must be operable for single nur.1eer (c) less of voltage en both 4160v buses unit operatten.

s (d) less of both main feeenater pumps.

2) Three out of three AW5 pumps must be operable for dual nuclear unit operetten.

Any one of these signals wl11 aise automatically open the normally closed meter operated and air operated valves in sortes which 1selate the main steam line from the steam supply header of each AN pump turbine. Air to operate the A N contre) valves to the steam generators hhe Itcensee advised that the type of perledic (monthly) testing perfereed for the ANS includes full flew path dischange to the SG's, ts supplied when the stese supply valves commence opening. The ANS t.o., e single actuation of ANS and delivery to SG's while power is being produced, can aise be started manue11y in the contret room er from the 1ecal station.

E-295

" ~#~ ~ ~ - - - - _ - - _ _ _ _ _ _ .

__ p 5 8

3) The condensate storage tent eust contain a sinfeue of The perfedic tasting practice followed involves full flew path testing 185.000 gallons of water, to the steam generators. This type of testing for of gue11ty le that

4) Systes pfptng, interlocks and valves must be operable. f t yfelds an advantage en detectability of valves that eight be af sposittened through human errors.. . Also, the ANS senual valves are If any of the above condf tf ens cannet be met within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the locked open and this practice further reduces the chance of inadvertent reacter must be shut down and the reacter coolant temperature must be closure through human error.

reduced to less than 350*F.

Several unlikely coenen mode vulnerabflitfes were fdentffled that I.16.2 eelfabfttty Evaluation afght serve to 11 sit the ave 11ebf11ty of the hfghly redundant Turkey I.16.2.1 Doetaant Falture Modes Pefnt AN5; their ultfeate fopect should be further considered in a The ANS stop1tffed flow diagram for Turkey Pefnt Unf t 3 is titus- longer tfee assessment. These were:

trated in Ffgure 1. This ANS design reflects 6 redundant. hfghly e) The possible cessen sharing of the lube oil coeting by the shared, system between Unfts 3 and 4 Operetten of any one of the service (city) water system which is DC powered, three steam turbine defven pumps would be espected to result fn b) The potentf a1 for coenen df sabitng of Unit #3 and/or #4 ANS by successful decay heat removal free either Units 3 or 4 Accordingly, e sfnf te fattere of the connecting pfptng between the headers in the success erf terton selected for this reltabflf ty evaluation was: the AN5 pusy discharge and steam supply paths.

Fallure of ANS is insufficient ANS flow from one AFh5 pump to 2 of 3 steam generators in one unit. LON with Only Onstte AC Avaflable The impact of shared emergency diesel generatore (EDG) and thefr The following fatfure modes were found to doetnate the semand una-alla- contrfbutten to the unavalletf11ty of the Turkey point ANS tore blitty of the Turkey Point ANS. estfested to be very sea 11. The steam edelssten valves to the tertine pups are AC operated.but ef ther of the two EDG's operating would LON with offsite AC Available sufffee to operate at least one er more of the three AC valves in 0-The Turkey Point A N S was found to be highly redundant in that there each header in Unit 3 and 4. Further, the himmen can serve es backup a

was no obvf eus single faults (active components, manual valves or to open these valves ff for some reaseg the AC or DC valves in efthar human errors) tdentif f ed that dominate the availability of the ANS. Unit 3 or 4 steam aestssion header fafled to operate e?octrically.

O E-296

. wA o *

.h 7

e The doetnant faults appear to rematn sfeitar to those discussed for 1.16.3 Recomendations for this plant the preceeding LOFw transient event.

The short-term recomendatlons (both genertC. denoted by G5. and plant.

specific) Identified in this section represent actions to leprove AFW torv itn onir oc avatiable system reliability that should be implemented by January 1.1980, or as as noted above the steam aemission valves are AC operated in Turkey soon thereafter as is practicable. In general, they favolve upgrading of point units e3 and es. The do=Inant fault centributten for this TechnlCal speciflCattons or establishing procedures to avoid or mitigate event was assessed to be fatture of tne human to open at least oae of potential system or operator failures. The long-ters ($oth generic, the steam adelssion valves by local manual action. The Itcensee denoted by GL. and plant-specific) recomendations identified in this sec.

estimated that such actions cov1d be accompitshed within about tion involve system destsi evaluations and/or modifications to improve AFW 10 minutes. systes reliability and represent actions that should be loplemented by January 1. 1981. or as soon thereafter as is practicable.

X.16.2.2 petEtoleDeceadeaciesidentified IJ6.3.1 Short-Term one dependency identtfled was the AC dependency for the steam admission j, Re cependation $5.] . The 11Censet should propose modiffCations to the valves that.for the event facluding complete less of Ac.would requfra Technical s'pecifications to liett the time 'eriod p that one 'MW system local manual action to initf ate the A/V5. ptse and its associated flow trafn and essentfal fastrumentation can be inoperable.

several addfttenal dependencies were fdentified that should be consf dered further.but en a longer term Consf deration as to thef r .eutage tfee 11mft and subsequent actlen 11ee should be as ultimate impact en the AFV5. These were (a) the potential for common required in current Standard Technical Specifications; f.e. 72 lubricatten cooling faults in the service (city) water system and (b) hours and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, respectively, the potential for common disab1tng of the AFV5 due to breaks In the single Ifne in the AFWS discharge headers and in the steam supply Recommendetten C5 The Itcensee should lock open sin 01 e 2.

headers to all turbfne driven AFW pump turbines.

valves or multiple valves in serfes in the AFV system pump suction pipfng and lock open other single valvas or multiple valves in serf es that could interrupt all AFV 81sw. Monthly inspectfens should be performed te vertfy that these valves are

, E-297 I~' _1[N,NN w.J.,o . ~~.; C N,*T'N ~ ~ * - - - - ~ ~ - - - ~ ~ ~ ~ ~

e 10 8

nquind fo ng a c m of a ating cunent me locked and in the Open posttlen. these faspectfens should be wpecy Weh sWd b esWM & mnua% WaW proposed for incerporated into the survetilence requirements of and contro111pg the system under these conditions. Stace the the plant Techatcal spectftcattens. See Recommendation CL-2 fe, water for cooling the lobe oli for the turbine-driven pump may the longer tore resolutf on of thf s concern. be dependent on alternating current power, desty or procedural C "F' ' ""*" # # " **

secomumendation C5-a Emergency procedures for transferrf ag to

3. practicable. Untti this fs done, the energency procehres should alternate sources of AN s'upply should be provide for an indfvfdual to be stationed at the turbine driven available to the plant operators. These procedures should " " #

include criterta to infore the operators when. and in what order, the transfer to alternate water sources should take place. The following cases should be covered by the procedures: untti alternating current power is restored. Adequate lighting The case nn which the prfmary water supply f s net "

taitta11y available. 1he procedures for thf t case stations for manual Inttfation and control of the Ad system should e

should include any operator actfens required to protect also be provided If senual inttfatton and control of the AN system the AN systes pumps against self-damage before water is needed. (see Recommendetton GL-3 for the l'onger term resolution flow is inttfated; and, of this concern).

The case in which the primary water supply to bef ag Recommendation GS The Itcensee should confire flow path aveff a6ftfty 5.

depleted. The procedure for this case should provide of an AFW system flow trafn that has been out of service to perform for transfer to the alternate water sources prfor to periodic testing or maintenance as follows:

drafning of the primary water suppfy. .

Procedures should be implemented to require an operator s to determine that the AFV system valves are properly

a. seco=nendation CS The as-butit plant should be capeole of aligned and a second operator to independently verify providing the required AN flow for at least two hours from one that the valves are properly aligned. ,

AW pump train independent of any alternsting Current power ,

source. If manual A W systee Initiatfen Of flow Cortrol if E-298 t

f

I 12 .

11 should be implemented so that a single fatture in the .

The Itcensee should propose Technical Specifications manual circuits will not result in the loss of systas to assure that prier to plant startup fellowing an funCilon.

estended cold shutdown, e flow test would be perfereed The alternating current m tar-driven pumps and valves te verify the normal flow path from the primary A N in the aux 111ary feedwatar system should be included The flew system water source to the steam generators. in the automatic actuadest (staultanous and/or sequential) test should be conducted with AN system valves in of the load's to the amargency buses.

their normal alf gnment. The automatic initiation signals and circuits shall be designed so that their failure will not result la the 6.

a,co===endation cs-T - The iteensee should vert fy that the automatic loss of sanual capability to intiate the AN system start AN system signe e and associated circultry are safety-grade. free the Control roce.

If thls cannot be vertf ted. the AN systee auwatic fnf tf ation system should be modffled in the short-ters to meet the functional Additional Short Tere Recosamendations X.25.3.2 For the longer ters, the automatic requirements 11sted below. The following additional short ters recommendations resulted free the initiation sfgnals and circuits should upgraded to meet safety-grade staff's Lessons Learned Task Force review and the Bullettne & Orders -

requirements as indicated in Recommendatten ct-5. Task Force revlev of AFW systems at Babcock & W11cou-designed operating The design should provide for the automatic fattfatfon plants s@ sequent to our review of the AN systes desigfs in h and of the avutitary feedwater systee flow. C-E-designed operating plants. They have not teen examined for The automatic initiatfon sfgnels and circuits should specific applicability to ths facility.

be designed so that a etngle fa11ere will not result Receaunendation - The licenses should provide redundant level 1.

in the loss of austitary feedwater system function.

indications and low level alares in the contre) room for the Testability of the intiation signals and circuits AN systes primary water supply to allow the :merator to anticipa.e shall be a feature of the design. the need to make up water or transfer to an alternate water The inittation signais and ctreutts should be powered

. supply and prevent a low pianp suction pressure condittpa free from the emergency buses. The low level alare setpoint should allow at least occurring.

Manual capability to inttfate the aunt 11ery feedwater 20 minutes for operator actions, assuming that the largest system from the control room should be retained and capacity AN pump is operating.

E-299 mm

- -a q ,

~ - - - - w o ne . e , - ..

b- . . .

o 13 14

2. Recommendation - fhe Ifeensee should perform a 72-hour endurance operetton, should propose Technical Spectffcations to provide that test on all MV system pumps, if such a test or contf nuous a dedicated indivfdual who is in communication with the control room perfed of operation has not been accomplished te date. Fellowing be stationed at the manual valves. Upon instruction from the control the 72-hour pump run, the ousps should be shut down and cooled room, this operator would re-align the valves in the AFW system train down and then restarted and run for one hour. Test acceptance from the test mode to its operational altgrument.

Criteria should fnclude demonstrating that the pops reeafn with i

I design lielts with respect to bearing / bearing ett temperatures and vibration and that pump room ambient conditfons (temperatures, X.16.3.3 teno-Teve humidity) do'not exceed environmental qualification Italts for Long-term recosamendettens for faproving the system are as follows:

safety-related equipment in the room. I- Reco'emendatton St. At least one AFW system pump and its

3. Recomendatton - The l'censee should implement the following associated flow path and essential instrumentation should auto-requirements as speelffed by Item 2.1.7.6 on page A-32 of natically inttf ate AFV system flow and be capable of betag operated f NtJREG-0$78: Independently of any alternating current pouer source for at least i

i

• $afety-grade Indication of auallf ary feedwater flow to two hours. Conversion of direct current poner to alternaltag current each steam generator shall be provided in the control room.

• l The ausfilary feedwater flow instrument channels shall be 2.

l aecommendetten - GL The Itcensee should h ade the AAf powered from the meergency buses consistent utth satisfying system automatic tattf atten stonela and circuits te meet safety-grade the emergency power diversity requirements for the aust11ary reoutrementa.

feedwater systne set forth in Aust11ary Systems 8 ranch Techn-nical position 10-1 of the $tandard Review plan, Section 3. Recommendatten - The AAf pump dfscharge Ifnes and turbine driven Ani 10.4.9."

1 pump steam supply ifnes for each unit com6fne into single.lfans through

) 4. Reconnendation - Licensees with plants which require local manual which all water and steam respectively from either unit must flow. 4 j realtgrenent of valves to conduct periodic tests on one AFB systen pipe break in either of these single flow paths would cause loss of the I train ad which have only one remaining AFW trate available for capabilf ty to provide ATW flow to all the steam generators of one unf t.

The Ifeensee should evaluate the censequences of a E-300

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. t . .

e * ,

15 5

,,,5 j _

postulated pipe break in these sections of the AN discharge or zas steam supply, assuntng a concurrent single actf re failure and jE ~~~~~

. 3 ~ *h

1) detemine any AFJ system modifications or procedures necessary - II . ,Og>ho u 5 ,2]f {}[ gy II

,a a, E to detect and Isolate the break, and direct the required AN flow to the steam generators before they boll dry or 2) describe how y , l II#

the plant can be brought to a safe shutdown condition by use of A

gr 3 2:

e-SE

!@!N'h'f *8 2

/* h -

other available systems following such a postulated pipe break. O 37 3 g > "5 {5 7

=.

1 2 8:f

<- <1 32 y

$ * . ls .a a b -a b .- VI s s;

o-s, secomendation_ . The tube ott cooling of the three turbine driven sig g ,

[ f AN pumps is prowl 4ed from a comon source; namely the service (city) ., j " " "

l f

- o o g lg g water system. The Itcensee should evaluate this cooling water system d 3 3)[hN / ** I todetermineifthtrearepotential,coaronmode(electricalor g2 l 3l I O I!)

mechanical) fatturts that Could disable the lube oil Cooling for all TE E m I 'E E three turbine driven pumps. The licensee shouls provide the results

• 2 g g of the evaluation and 1) indicate any system modifications or procedures Ie k *) 1 1

,pp necessary to prevent a commen mode failure of the lube all cooling .

3 3 3 .j d

< 3 33 3IlIS 3 g 8 system or 2) provfde infomation that demonstrates that the turbine *

• j O n g

• 3 . 3 J driven AN pugs can operate for at least two hours without tube oli A 3

/gg Er, 55 . . E cooling water and independent of AC power. = J a u g

h.3 33h ,

i 0_a 1-

. I 3_Of!}3y3 i 33hz 3 s . ._ 1 co ao u 3 f.:

4i.= s3 l- lEu 5,$"2, !B "l 8 v5 m-ou 2,ll o.> as n.ss

lg 3 2 2 2 X XCWa?

> :9=

E-301 l

-. - , . .w-.a . .. ..n_,,,_ _

.._.. = . . . .-. .. n - [-

.1

m. . .-

(NCLOSURE 2 2

Bests for Aust1tary Feedwater .

System Flou Recuirements

- Maalmum RC5 pressure (PORY or safety valve actuation)

As a result of recent staff reviews of operating plant Aamillary Feed. . Fuel temperature or damage limits (DNS. PCT. matteus fuel r water Systems (ANS), the staff concludes that the design bases and central tesperature) criteria provided by licensees for establishing AN5 requirements for . RC5 cooling rate limit to avoid oncessive coolant shrinkage flow to the steam generator (s) to assure adequate removal of reactor . Minimum steam generator level to assurd sufficient stema decay heat are not well defined or documented. generator heat transfer surface to remove decay heat and/or cool down the primary system.

We require that you provide the following AN5 flow design basis infor.

mation as app 1tcable to the design basis transients and accident con. 2. Describe the analyses and assumptions and corresponding technical ditions for yoJr plant. justification used with plant condition considered in 1.a. above including:

1. a. Identify the plant transient and acefdent conditions considered

a. Mastmum reactor power (including instrument error allowance) in establishing ATW5 flow requirements includf ag the following at the time of the initiating tra? stent or accident.

events:

1) Less of Main Feed (LMN) b. Time delay free inttf ating event to reactor trip.

2) LPfw w/ loss of offsite AC power

c. plant parameter (s) which initiates AFW5 flow and time delay

3) LPFW w/ loss of onsite and offsite AC power between initiating event and introduction of AN5 flow fato

4) plant cooldown steam generator (s).

$) Tsrbine trip with and without bypass

6) Main steam Isotation valve closure d. Mfnfmum steam generator water level when initiating event

7) Main feed ifne break occurs.

81 Main steam itne break *

e. Initial steam generator water inventory and depletion rate before s

9) Small break LOCA and after AFW5 flow commences = identify reactor decay heat

10) Other transient or accident conditions not listed above .

rate used.

b. Describe the plant protection acceptance criteria and corres.

pondleg technical bases used for each initiating event identi.

ffed above. The acceptance criteria should address plant lief ts such as:

t E-302

h' 3

4

f. Maxinum pressure at which steam is released fran steam generator (s) 3, f, g and against which the AN pump must develop sufficient hesd. gy, g g above considerfng a single fatture. Identify the margin fa stafag

g. Minimum number of steam generators that must receive AN flow; the pump flee to allow for peg recirculation flow, seal leakage e.g.1 out of 27, 2 out of 47 and pump wear.

h. RC flow conditten - continued operation of RC pops or naturel circula tion,

f. Mastmum AN f nlet temperature.

J. Following a postul.ated steam er feed line break, time delay assumed to tsolate break and direct AW flow to fntact steam generator (s). AFV pump flow capacity allowance to accomodate the time delay and maintain stalmum steam generator water level.

Also identify credit taken fo1r primary system heat removal due to blowdown.

k. Volume and maxtmian temperature of water in main feed ifnes between steam generator (s) and AN5 connection to main feed itne.

1. Operating conditton of steam generator normal blowdown following

' inttf ating event.

I m. Primary and secondary systen water and metal sensible heat t

used for cooldown and AN' flow stateg.

n. Time at hot standby and time to cooldow:t RCS to RNA systes cut in temperature to size AN water source inventory.

l t

i .

l l

E-303 r- - .. .. . . _ . _ _ , , ,_

.s . G f * *p:24tcy 'o UNITED STATES 8 ~ ,% NUCLEAR REGULATORY COMMISSION

.I WASHINGTON, D. C. 20S55 v p

' **"* December 24, 1981 l

Docket Nos. 50-250 and 50-251 Gl d <

Dr. Robert E. Uhrig, Vice President l

Advanced Systems and Technology Florida Power and Light Company .

Post Office Box 529100 Miami, Florida 33152 l

Dear Dr. Uhrig:

The Commission has issued the enclosed Amendment No. 75 to Facility Operating License No. OPR-31 and Amendment No. 69 to Facility Operating License No.

DPR-41 for the Turkey Point Plant Unit Nos. 3 and 4. respectively. The I amendments consist of changes to the Technical Specifications in response to your application transmitted by letter dated April 13, 1981.

These amendments change the Technical Specifications to confom with our Bulletins and Orders Task Force review of the Auxiliary Feedwater System following the Three Mile Island accident.

Copies of the Safety Evaluation and the Notice of Issuance are also enclosed.

• h ncerely,

)

h44 dl b

Marshall Grotenhuis, Project Manager 1 Operating Reactors Branch No. I l Division of Licensing E

Enclosures:

• 1. Amendment No. 75 to DPR-31

2. Amendment No. 69 to DPR-41

~

3. Safety Evaluation

4. Notice of Issuance cc w/ enclosures:

See next page l

l F/2.

..l ,

f_ M%df I h ',

,v 5ww w -,,-

N [

l

g 7590-01 f

UNITED STATES NUCLEAR REGULATORY COMMISSION i DOCKET NOS. 50-250 AND 50-251 FLORIDA POWER AND LIGHT COMPANY j NOTICE OF ISSUANCE OF AMENDMENT TO FACILITY OPERATING LICENSES

(

The U. S. Nuclear Regulatory Comission (the Comission) has issued j Amendment No. 75 to Facility Operating License No. DPR-31, and Amendment j No. 69 to Facility Operating License No. DPR-41 issued to Florida Power i

and Light Company (the licensee), which revised Technical Specifications i 4

for operation of Turkey Point Plant, Unit Nos. 3 and 4 (the facilities) j

~~

located in Dade County, Florida. The amendments are effective as of the date of issuance. j The amendments change the Technical Specifications to conform with the i O Comission's Bulletins and Orders Task Force review regarding Auxiliary Feedwater Pump requirements following the Three Mile Island Accident. f The application for the amendments complies with the standards and  !

requirements of the Atomic Energy Act of 1954, as amended (the Act), and' i , the Comission's rules and regulations. The Commission has made appropriate l findings as required by the Act and the Commission's rules and regulations  :

1 in 10 CFR Chapter I. which are set forth in the license amendments. Prior ,

i public notice of these amendments was not required since the amendments do not l involve a significant hazards consideration.

i f l $ SN mm , -

z-

,,.w. ,w . . - _ , , _ . .--,,.-._.____--_.-.-r m.__,__--., , ~ . . . _ , , .,,.,,,-,,,--m,._,

, , _ . , - . . . . . _ , , , , . _ , ,.,,-,,,,.w-,,, - . , _ . . - - , . . . , _ , - . . .

, ,,.t .

7590-01 2

The Commission has determined that the issuance of these amendments will not result in any significant environmental impact and that pursuant to 10 CFR 151.5(d)(4) an environmental impact statement or negative decla-ration and environmental impact appraisal need not be prepared in connection with issuance of these amendments.

For further datails with respect to this action, see (1) the application j for amendments dated April 13, 1981, (2) Amendment Nos. 75 and 69 to License Nos. DPR-31 and DPR-41, and (3) the Commission's related Safety Evaluation.

.- All of these items are available for public inspection at the Comission's l Public Document Room,1717 H Street, N. W., Washington, D. C. and at the Environmental and Urban Affairs Library, Florida International University, Miami, Florida 33199. A copy of items (2) and (3) may be obtained upon  !

O . request addressed to the U. S. Nuclear Regulatory Comission. Washington, D. C. 20555, Attention: Director Division of Licensing.

Dated at Bethesda, Maryland, this 24th day of December,1981.

- 1 F6RTHENUCLARREGULATORYCOMMISSION  ;

,, i9 i 3

h4

\ Steven .'Varga' hief ,

< Operating React Branch No. 1  :

Division of Licensing l A

l i

t l

r Rcbert E. Uhrig ,

- Florida Power and Light Company cc: Mr. Robert Lowenstein, Esquire Mr. Jack Shreve ,

Lowenstein, Newman, Reis and Axelrad Office of the Public Counsel 1025 Connecticut Avenue, N.W. Room 4 Holland Building ,

Suite 1214 Tallahassee; Florida 32304  :

Washington, D. C. 20036  ;

Environmental and Urban Affairs Library Department of Environmental Florida International University Regulation e Miami, Florida 33199 Power Plant Siting Section State of Florida i i

Mr. Norman A. Coll, Esquire 2600 Blair Stone Road Steel, Hector and Davis Tallahassee, Florida 32301 ,

1400 Southeast First National  ;

Bank Building [

Miami, Florida 33131 1 -

i Mr. Henry Yaeger, Plant Manager

.. Turkey Point Plant i Florida Power and Light Company i P. O. Box 013100 , 3 Miami, Florida 33101 l Honorable Dewey Knight  ;

, County Manager of Metropolitan  ;

1 Dade County  :

titami, Florida 33130  !

i Bureau of Intergovern. mental Relations  !

560 Apalacbee Parkway Tallahassee, Florida 32304  :

Resident Inspector Turkey Point Nuclear Generating Station [

U. S. Nuclear Regulatory Commission [

, Post Office Box 1207  ;

Honestead, Florida 33030 l Regional Radiation Representative  ;

i EPA Region IV l 345 Courtland Street, N.W. .

Atlanta, Georgia 30308  ;

i l l i

i e.. . . . ... . . . ... . . . . . ... . .

e

~

o, UNITED STATES 1 y } NUCLEAR REGULATORY COMMISSION

.  ; E WASHINGTON. D. C. 20655 s.,.....J FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-250 TURKEY POINT PLANT UNIT NO. 3 AMENDMENT TO FACILITY OPERATING LICENSE

- Amendment No. 75 License No. DPR-31

1. The Nuclear Regulatory Comission (the Comission) has found that:

- A. The application for amendment by Florida Power and Light Company (the licensee) dated April 13, 1981, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; , ,

B. The facility will operate in ecnformity with the application, O' the provisions of the Act, and the rules and regulations of the Comission; C. There is reasonable assurance (1) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations; D. The issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public;

, and E. The issuance of this amendment is in accordance with 10 CFR Part i 51 of the Comission's regulations and all applicable requirements l have been satisfied.

4

. . h e\ 2 2 i f_A=l A A -

G MEig,dLadN W w 7' l

l .- -

l

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-31 is hereby amended to read as follows:

(B) Technical Specifications l The Technical Specifications contained in Appendices A and B, as revised through knendment No. 75, are hereby incorporated in the license. The licensee shall r operate the facility in accordance with the Technical i Specifications.

3. This license amendment is effective as of the date of its issuance.

FD ULATORY COMMISSION THENUCf I i 2/[0ttly 8 EV;eveh A. nrga,fChie

' Operating Reactors r nch No. 1 Division of Licensin

Attachment:

lA Changes to the Technical i V Specifications i

Date of Issuance: December 24, 1981 4

5 i

• / 'o UNITED STATES

! n NUOLEAR REGULATORY COMMISSION 5 .I WASHINGTON, D. C. 20555

%,...../

FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT PLANT UNIT NO. 4 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 69 License No. DPR-41

1. The Nuclear Regulatory Commission (the Commission) has found that:

_ A. The application for amendment by Florida Power and Light Company (thelicensee)datedApril 13, 1981, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act') and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in confomity with the application, h the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (1) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements ,

have been satisfied.

?

I 4

' 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachmer.t to this license amendment, and paragraph 3.8 of Facility Operating License No. DPR-41 is hereby amended to read as follows: ,

(B) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 69, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION .

1 ,

'O i

eve '(darga,Che anch No.1 Operating Reactors Division of Licensi (3

Attachment:

,V Changes to the Technical

' Specifications Date of Issuance: December 24, 1981 1

! i ii .

~

ATTACHMENT TO LICENSE AMENDMENTS AMENDMENT NO. 75 TO FACILITY OPERATING LICENSE NO. OPR-31 AMENDMENT NO. 69 TO FACILITY OPERATING LICENSE NO. DPR-41 DOCKET NOS. 50-250 AND 50-251 Revise Appendix A as follows:

Remove Pages In'.ert Pages 3.8-1 3.8-1 3.8-2 B3.8-1 83.8-1 d

O 4

Y 1

l 3.8 STEAM AND POWER CONVERSION SYSTOiS Applicability: Applies to the operating status of the steam and power conversion systems.

Objective: To define conditions of the steam-relieving capacity and auxiliary feedwater system.

Soecification: 1. When the reactor coolant of a nuclear unit is heated above 350*F the following conditions must be met:

I

a. TWELVE (12) of its steam generator safety valves snall be operable (except for testing). g

b. System piping, interlocks and valves directly I associated with the related componer.ts shall be operable.

c. Its condensate storage tank snali contain a minimum of 185,000 gallons of water.

d. Its main steam stop valves shall be operable and l 1

capable of closing in 5 seconds or less.

2. The iodine-131 activity on the seccndary side of a steam j generator shall not exceed 0.67 Ci/cc.

3. During power operation, if any or the conditions of 3.8.1 l or 3.8.2 cannot be met within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be shut down and the reactor coolant temperature reduced below 350*F. ,

4. The following number of incependent steam generator  !

auxiliary feedwater pumps and associated flow path shall be operable when the reactor coolant is heated above l 350*F: j w

a. Single Nuclear Unit Operation Two auxiliary feedwater pumps capable of being powered  ;

from an operaole steam supply. '

i

b. Qual Nuclear Unit Operation Three auxiliary feedwater pumps capable of being '

powered from an operable steam supply. ,

5. During power operation, if any of the conditions of 3.8.4  ;

cannot be met, the reactor shall be shut down and the  ;

reactor coolant temperature reduced below 350'F, unless l one of the following conditions can be met; ]

I I s Amendment Nos. 75 & 69 3.8-1 t

a. For single unit operation with one of the two required auxiliary feedwater pumps inoperable, restore the inoperable pump to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the reactor shall be shut down and the reactor coolant temperature reduced below 350*F within the next 12 -

hours,

b. For dual unit operation witn one of the three required auxiliary feedwater pumps inoperable, restore the inoperable pump to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or a reactor shall be shut down and its reactor coolant temperature reduced below 350*F witnin the next 12

{ hours. .

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b) i 1

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Amendment Nos. 75 & 69 3.8-2

E

,- B3.8 BASES FOR LIMITING CONDITICBS FOR OPERATIOH, STEAM AND PCWER CONVERSION SYSTEMS -

In the unlikely event of complete loss of electrical power to the nuclear units, decay heat removal will be assured by the availability of the steam-driven auxiliary feedwater pumps and steam discharge to the atmosphere via the steam generator safety valves and power relief valves.(1) The operability of the auxiliary feedwater system ensures that the Reactor Coolant System can be cooled down to less than 350* F from normal operating conditions in the event of a total loss of off-site. power. Each steam driven auxiliary feedwater pump is capable of -

delivering a total feedwater flow of 600 gpm to the entrance of the steam cenerators. This capacity is sufficient to ensure that adequate feedwater flow is availiable to remove decay heat and reduce the Reactor Coolant System temperature to less than 350'F when the Residual Heat Removal System may be placed into operation. The minimum amount:of -

water in the condensate storage tanks is established from FSAR Figure 9.11-1, and meets safe shutdown requirements. (2) '

The limit on secondary coolant iodine-131 specific activity is based on a postulated release of secondary coolant equivalent to the contents of three steam generators to the atmosphere due to a net load rejection.

, The limiting dose for this case would result from radioactive iodine .

. in the secondary coolant. 1-131 is the dominant isotope because of l its low MPC in air and because the other shorter lived iodine isotopes cannot build up to significant concentrations in the secondary coolant '

under the limits of prinary system leak rate and activity. One tentn of the iodine in the ' secondary coolant is assu ed to reach the site

(~} boundary making allowance for plate-out and retention in water droplets.

The inhalation thyroid dose at the site boundary is then: .

Dose (Rem) = C V B OCF X/Q 0.1 Where: C = secondary coolant I-131 specific activity

= 1.34 curies /m3 (uC!/cc) or 0.57 Ci/m3, each unit V = equivalent secondary cool 8 = Breathing rate = 3.47x10m3 gnt/ sec. volume released = 214 m3 X/Q = atmospheric dispersion parameter = 1.54x10-4 sec/m 3 0.1 = equivalent fraction of activity released DCF = Dose conversion factor, Rem /Ci o The resultant thyroid dose in less than 1.5 Rem. -

References (1) FSAR - Section 10.3 ,

(2) FSAR - Section 14.2.5 ,

( ,

Amendment Nos. 75 & 69 B3.8-1 8 m

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1. nan UNITED STATES

! o NUCLEAR REGULATORY COMMISSION

{ -l wasuincTON. D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 75 TO FACILITY OPERATING LICENSE NO. OPR-31 AND AMENDMENT NO. 69 TO FACILITY OPERATING LICENSE NO. DPR-41 FLORIDA POWER AND LIGHT COMPANY TURKEY POINT PLANT UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251 l

I. INTRODUCTION By letter dated April 13, 1981 the Florida Power and Light Company (the licensee) submitted a request to modify the Technical Specifications '

..- for the Turkey Point Plant Unit Nos. 3 and 4. The amendments would change the Technical Specifications to conform to our Bulletins and Orders Task Force review following the Three Mile Island Accident. The requirements of this Task Force regarding Auxiliary Feedwater System were set forth in our letter dated October 16, 1979. The licensee responded on December 20, 1979 July 22,1980 and January 14, July 23,1981, in addition to the April 13,1981 amendment request. As noted in the following evaluation 1

j O =a resPoas = r aat co P 1 t aa so or our revi w is aat co iP t -

Those items for which additional information is necessary to complete our review will be specifically requested from the licensee in & separate ,

letter. ,

II. BACKGROUND [

. The Three Mile Island Unit 2 (TMI-2) accident and subsequent investigations ,

i and studies highlighted the importance of the Auxiliary Feedwater System  !

(AFWS) in the mitigation of transients and accidents. As part of our

, assessment of the TMI-2 accident and related implications for operating  ;

plants, we evaluated the AFW systems for all operating plants having nuclear steam supply systems (NSSS) designed py Westinghouse (NUREG-0611) or Combus- ,

tion Engineering (NUREG-0635). Our evaluations of these system designs are  !

contained in the NUREGs along with our recommendations for each plant and the concerns which led to each recommendation. The objectives of the evalua- +

tion were to: (1) identify necessary changes to AFW system design or related  !

procedures at the operating facilities in order to assure the continued safe j operation of these plants, and (2) to identify other system characteristics i of the AFW systems which, on a long term basis, may require system modifica-  ;

tions. To accomplish these objectives, we:

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(1) Reviewed plant specific AFW system designs in light of current regulatory requirements (SRP) and, (2) Assessed the relative reliability of the various AFW systems'under various

loss of feedwater transients (one of which was the initiating event of TMI-2) and other postulated failure conditions by detemining the potential for AFW system failure due to common causes, single point vulnerabilities, and human error.

We concluded that the implementation of the recomendations identified during i this review can be expected to improve the reliability of the AFW systems for each operating plant.

The following plant specific recomendations did not apply to this plant: GS-3, 1

GS-8, GL-1, GL-2, and GL-4. The basis for these recomendations can be found in Appendix III of NUREG-0611 and the system description which determined the-basis for not applying these recomendations can be found in Section X of NUREG-0611.

III. IMPLEMENTATION OF OUR RECOMMENDATIONS 4 A. Short Term Recomendations

1. Recomendation GS The licensee should propose modifications to the

! Technical Specifications to limit the time period that one AFW system pump and its associated flow train and essential instrumentation can

be inoperable. The outage time limit and subsequent action time

1 should be as required in current Technical Specifications; i.e., 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, respectively.

The licensee responded in a letter dated December 20, 1979, and agreed to submit a proposed Technical Specification amendment to include the

, outage time limit and subsequent action time as stated in the Stand- l ard Technical Specifications; i.e., 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. l w The proposed Technical Specification was submitted in a letter dated

~

April 13,1981. We have reviewed the licensee's response to this recom-mendation and conclude that it meets the requirements of this recomen-dation and is therefore acceptable. The proposed Technical Specifi-  !

cation has also been reviewed and found acceptable. It is hereby I incorporated into Appendix A of the licenses for the Turkey Point Units. l l

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2. Recomendation GS The licensee should lockopen single valves or multiple valves in series in the AFW system pump suction piping and lock open other single valves or multiple valves in series that could interrupt all AFW flow. Monthly inspections should be performed to verify that these valves are locked and in the open position. These inspections should be proposed for incorporation into the surveillance requirements of the plant Technical Specifications.

The licensee responded in a letter dated December 20, 1979, stating that the AFWS operability is verified on a monthly basis in accordance with Technical Specification 4.10 by starting the AFW pumps and establishing flow to the steam generators. Valves that could affect AFW flow are locked open and their positions are verified monthly by i procedure as specified in the Technical Specifications. However, the steam admission valves to the AFW pump turbine are part of the AFW control system and cannot be locked open because that could activate the AFW system. The steam pressure control valves, located between the  :

steam admission valves and the AFW pump turbines, cannot be locked in

._ any position because they are part of the AFW control system. The 1 operability of these valves is tested monthly in compliance with  !

Technical Specification 4.10. l We have reviewed the licensee's response and conclude that it meets the j requirement of this recommendation and is, therefore, acceptable.  ;

h 3. Recommendation GS Emergency procedures for transferring to alter-nate. sources of AFW supply should be available to the plant operators.  ;

These procedures should include criteria to inform the operators when,  :

and in what order, the transfer to alternate water sources should take l pl ace. The following cases should be covered by the procedures- l (1) The case in which the primary water supply is not initially -

available. The procedures for this case should include any  ;

operator actions required to protect the AFW system pumps a against self-damage before water flow is initiated; and

!* (2) The case in which the primary water supply is being depleted.

i The procedure for this case should provide for transfer to the

! alternate water sources prior to draining of the primary water supply.

The lictnsee responded in a letter dated December 20, 1980, stating I that Turkey Point Units 3 and 4 share two safety grade condensate  !

storage tanks (CST) between the two units. Make-up water to the CST l can be provided from non-safety grade equipment such as the condenser  ;

hot well, the primary water storage tank or the fire main system. The i

, licensee further stated that a non-safety grade 500,000 gallon deaerated  ;

water storage tank is being constructed and will be available to supply

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J[ the CSTs.

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l We find the licensees response incomplete in that the procedures the operators are to follow in the two cases required by this recommen-  !

dation are not mentioned. Further the use of the 500,000 gallon  !

i deaerated water storage tank is not spelled out. The AFW sources l of water are appropriately restricted by Technical Specifications +

1 (3.8.1c and 3.8.3) which spell out the minimum volume of water  !

which must be available to the AFW pumps (185,000) and the action j to take should the supply drop below the 185,000 gallons. }

i

4. Recommendation GS The as-built plant should be capable of providing  !

I the required AFW flow for at least two hours from one AFW pump train l independent of any alternating current power source. If manual AFW l system initiation of flow control is required following a complete f loss of alternating current power, emergency procedures should be i established for manually initiating and controlling the system under  !

these conditions. Since the water for cooling the lube oil for the l i turbine-driven pump may be dependent on alternating-current power,  ;

4 design or procedural changes shall be made to eliminate this dependency  !

as soon as practicable. Until this is done, the emergency procedures  !

should provide for an individual to be stationed at the turbine-driven  :

l pump in the event of the loss of all alternating current power to  !

1 monitor pump bearing and/or lube oil temperatures. If necessary, this l operator would operate the turbine-driven pump in an on-off mode until  ;

alternating current power is restored. Adequate lighting powered by j direct current power sources and communications at local stations for  ;

manual initiation and control of the AFW system should also be provided l

@ if manual initiation'and control of the AFW system is needed. (See 1

Recomendation GL-3 for the longer term resolution of this concern.) ~

i The licensee responded in a letter dated December 20, 1979, stating i that the as-built AFWS is capable of providing required flow for at  !

. least two hours from one AFW train independent of any AC power source after AFW initiation. No manual operation is requred L upon loss of AC power because the steam control and AFW discharge control system have r a nitrogen backup for operation of air control valves. Service water l i" used for cooling the turbine driven pumps lube oil is supplied by  !

gravity feed. The licensee stated that procedures would be prepared

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. to describe how to assure at least two hour supply of lube oil cooling l water in the event of loss of all AC power. The licensee also proposed i to install a sound powered phone line from the AFW pumps to the control i room. The modifications are planned to be completed during 1981. In  !

conjunction with this modification DC lighting will also be installed at the AFW pump location.

We have reviewed the licensee's response and conclude that it meets 4

the requirements of the recomendation and is therefore acceptable.

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5. Recommendation GS The licensee shculd confirm flow path avail-ability of an AFW system flow train that has been out of service i to perform periodic testing or maintenance as follows:

(1) Procedures should be implemented to require an operator to determine that the AFW system valves are properly aligned and a second operator to independently verify that the valves are properly aligned.

(2) The licensee should propose Technical Specifications to assure

' that prior to plant startup following an extended cold shutdown, a flow test would be performed to verify the normal flow path from the primary AFW system water source to the steam generators.

The flow test should be conducted with AFW system valves in their normal alignment.

l The licensee responded in a letter dated December 20, 1979, stating j -_

that a proposed Technical Specification amendment will be provided to specify performing a flow test to verify the normal flow path. In addition, valve position will be determined by an operator and verified by a second operator and incorporated into the appropriate procedures.

l-i The proposed Technical Specification was submitted by letter dated -

4 April 13,1981. We have reviewed the licensee's response to this recommendation and conclude that it meets the requirements of this

, ((}

reconmendation and is therefore acceptable. The proposed Technical Specification has also been reviewed and found acceptable. It is hereby incorporated into Appendix A to the licenses for the Turkey Point Plant.

1 6. Recommendation GS The licensee should verify that the automatic

] start AFW system signals and associated circuitry are safety-grade.

i If this cannot be verified, the AFW system automatic initiation system l should be modified in the short-term to meet the functional require-

! '.* ments listed below. For the longer term, the automatic initiation l signals and circuits should be upgraded to meet safety-grade require-i ments as indicated in Recommendation GS-5.

. (1) The design should provide for the automatic initiation of the auxiliary feedwater system flow.

(2) The automatic initiation signals and circuits should be designed

so that a single failure will not result in the loss of auxiliary feedwater system function.

i i

(3) Testability of the initiation signals and circuits shall be a ti feature of the design.

(4) The initiation signals and circuits should be powered from the emergency buses.

(5) Manual capability to initiate the auxiliary feedwater system from the control room should be retained and should be implemented so l

that a single failure in the manual circuits will not result in the loss of system function. ,

]

(6) The alternating current motor-driven pumps and valves in the 4

auxiliary feedwater system should be included in the automatic

• actuation (simultaneous and/or sequential) of the loads to the emergency buses.

(7) The automatic initiation signals and circuits shall be designed '

so that their failure will not result in the loss of manual capability to initiate the AFW system from the control room. l The licensee responded in a letter dated December 20, 1979, stating that the as-built system is safety grade with one exception. The actuation of the pressure regulating valves for steam supply to the AFW pump turbines is not designed in accordance with the single failure criterion. However, the licensee committed to modify the system to O meet the single failure criterion.

We conclude that the licensee's response meets this Short Term Recommendation (control grade) and is therefore acceptable. However, f the proposed modification of pressure regulating valves actuation to 4

meet the single failure criterion (safety grade) is still under review.

l This review will be reported in a supplement to this report.

j B. Additional Short Term Recommendations

1. Recommendation - The licensee should provide redundant level indi-I cations and low level alarms in the control room for the AFW system primary water supply to allow the operator to anticipate the need to make up water or transfer to an alternate water supply and prevent a low pump suction pressure condition from occurring. The low level.

alarm set-point should allow at least 20 minutes for operator actions, assuming that the largest capacity AFW pump is operating.

1 i

The licensee responded in a letter dated December 20, 1979, stating  ;

that redundant level indicators and low level alams for the AFWS primary water supply (CSTs) will be provided in the control room, f The setpoint of the existing non-redundant low level alarm has been l adjusted to allow at least 20 minutes for operator action assuming l the largest capacity AFW pump is operating. The setpoint of the  ;

second, to be added, low level alarm will be similarly adjusted when

' it is installed.  ;

i We have reviewed the licensee's response to this recomendation and conclude that it meets the requirements of this recommendation and - i it is therefore acceptable.

2. Recommendation (This recommendation has been revised from the original t recomendation 'in NUREG-0611 - The licensee should perform a 48-hour  !

endurance test on all AFW system pumps, if such a test or continuous l period of operation has not been accomplished to date. Following the a 48-hour pump run, the pumps should be shut down and cooled down and l then restarted and fun for one hour. Test acceptance criteria should  ;

include demonstrating that the pumps remain within design limits with i respect to bearing / bearing oil temperatures and vibration and that i pump room ambient conditions (temperature, humidity) do not exceed  !

environmental qualification limits for safety-related equipment in the i h room.  !

The licensee should provide a summary of the conditions and results of  ;

the tests. The summary should include the following: (1) A brief r description of the test method (including flow schematic diagram) and l l how the test was instrumented (i.e., where and how bearing temperatures  ?

weremeasured). (2) A discussion of how the test conditions (pump flow,  ;

head, speed and steam temperature) compare to design operating conditions. l (3) Plots of bearing / bearing oil temperature vs. time for each bearing of each AFW pump / driven demonstrating that temperature design limits were not exceeded. (4) A plot of pump room ambient conditions do not exceed environmental qualification limits for safety-related equipment j in the room. (5) A statement confiming that the pump vibration did not exceed allowable limits during tests. [

By letter dated January 14, 1981, the licensee provided the results of the 48-hour endurance tests for the AFW pumps. The test was con-ducted according to conditions specified in the recommendation. Data  !

on the bearing oil temperature for each pump-driver indicated that the design temperature limits were not exceeded during test. Data on i I

pump environment indicated that ambient conditions did not exceed the

. environmental qualification limits for the AFW pumps. Pump vibration }

data taken during the test demonstrate that the allowable limits for the AFW pumps were satisfactory during any of the testing.  :

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We have reviewed the licensee's response and conclude that it meets this recommendation and is, therefore, acceptable.

j

3. Recomendation - The licensee should imp.ement the following require-ments as specified by Item 2.1.7 b on page A-32 of NUREG-0578:

, " Safety-grade indication of auxiliary feedwater flow to each steam generator shall be provided in the control room. The auxiliary feedwater flow instrument channels shall be powered ,

from the emergency buses consistent with satisfying the emer-gency power diversity requirements for the auxiliary feedwater system set forth in Auxiliary Systems Branch Technical Position l 10-1 of the Standard Review Plan, Section 10.4.9."

In'a letter dated November 21, 1979, the licensee committed to provide i control grade indication and safety grade indication. .

I We have reviewed the licensee's response regarding the control grade modi- I

_- fication and conclude that it meets the requirements of this recommendation  :

and is therefore acceptable. The safety grade modification is still under l review. This review will be updated in a supplement to this report. l 4

4. Recommendation - Licensees with plants which require local manual j realignment of valves to conduct periodic tests on one AFW system ,

train, and there is only one remaining AFW train available for opera- l h tion,should propose Technical Specifications to provide that a dedi-cated individual who is in comunication with the control room be i l

stationed at the manual valves. Upon instruction from the control room, this operator would realign the valves in the AFW system train l

from the test mode to its operational alignment. l The licensee responded in a letter dated December 20, 1979, indicating I that a proposed Technical Specification amendment to enhance the '

current specification on AFWS surveillance tests will be submitted to i

!' NRC for review.

3 To date the proposed Technical Specification has not been received. We l will rev,iew the proposed Technical Specification when it becomes available l and provide our evaluation in a supplement to this SER input.  !

j C. Long Term Recomendations i 1. Recomendation GS At least one AFW system pump and its associated {'

flow path and essential instrumentation should automatically initiate '

AFW system flow and be capable of being operated independently of any l AC power source for at least two hours. Conversion of DC power to AC i power is acceptable.

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8- -9 l In a letter dated July 20, 1980, the licensee stated that the as-built AFWS in Turkey. Point Units 3 and 4 relies on the operation of AC motor operated steam admission valves to supply steam to the AFW turbine driven pumps . However, the licensee has comitted to make design modification

! to the steam supply valves. Two of the three valves will be converted

to DC power operated.

j. .

We have reviewed the licensee's response to this recommendation and

1. conclude that it meets the requirement of this recommendation and is '

ji therefore acceptable.

i

2. Recomendation GL The licensee should upgrade the AFW system auto-lq matic initiation signals and circuits to meet safety-grade requirements.

The licensee responded in a letter dated December 20, 1979, stating

that the as-built system is safety grade with one exception. The

. actuation of the pressure regulating valve for steam supply to the AFW pump turbine is not designed in accordance with the single failure

! criterion. The licensee committed to modify the system to meet the >

4 single failure criterion.

The licensee's safety grade automatic initiation system design is still h, under review. This review will be reported in a supplement to this report. i

(

3. Recommendation - The AFW pump discharge lines and turbine driven AFW  !

pump steam supply lines for each unit combine into single lines through

! which all water and steam respectively from either unit must flow. A i pipe break in either of these single flow paths would cause loss of the ,

capability to provide AFW flow to all the steam generators of one unit. ,

i The licensee should evaluate the consequences of a postulated pipe break >

, in these sections of the AFW discharge or steam supply, assuming a '

i , concurrent single active failure and (1) determine any AFW system modi-  !

fications or procedures necessary to detect and isolate the break, and i j .

direct the required AFW flow to the steam generators before they boil I dry or (2) describe how the plant can be brought to a safe shutdown f condition by use of other available systems following such a postulated  ;

pipe break. j i

The licensee in a letter dated December 20, 1979, stated that operating i procedures will be in place by 1981 to provide direction to the operations '

! regarding isolation of AFWS steam supply lines or_ feedwater line piping i

! breaks. Procedures regarding unit shutdown using other available means j

, will also be in place by 1981. In conjunction with the proposed i operating procedures, steam and feedwater piping modifications are 4

being developed by the licensee to ensure redundancy in the common AFW  !

discharge header and the common steam supply header to the AFW pump  !

turbine. The modifications are planned during the Unit 4 steam generator  ;

replacement outage, currently scheduled to begin in the fall of 19C2. }

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We require the licensee to provide details of the proposed piping modification being developed to provide redundancy in the discharge header and comon steam supply header. We will review the information  !

when it becomes available and provide a supplement to this SER input. l j

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4. Recomendation - The lube oil cooling of the three turbine driven AFW pumps is provided from a comon source, namely the service (city) t water system. The licensee should evaluate this cooling water system i to detemine if there are potential comon mode (electrical or mechan-  !

ical) failures that could disable the lube oil cooling for all three i i turbine driven pumps. The licensee should provide the results of the  !

evaluation and (1) indicate any system modifications or procedures l

- necessary to prevent a conmion mode failure of the lube oil cooling l system or (2) provide information that demonstrates that the turbine  !

i driven AFW pumps can operate for at least two hours without lube oil I

cooling water and independent of AC power. [

i The licensee responded in a letter dated December 20, 1979, stating

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- i that the AFW pump lube oil cooling system will be modified to provide  !

lube oil cooling water from the AFW pump discharge.  !

i We have reviewed the licensee's response and conclude that it meets {

the requirements of this recommendation and is therefore acceptable.  ;

D 5. Basis for AFWS Flow Requirement - In our letter dated October 16, 1979, I

j we requested the licensee to respond to Enclosure 2, regarding the AFWS Flow design basis. The licensee has not yet responded to this d

recomendation. We will provide our evaluation of their response in ,

a supplement to this report. l IV. ENVIRONMENTAL CONSIDERATION We have determined that the amendments do not authorize a change in effluent l

. types or total amounts nor an increase in power level and will not result  ;

in any significant environmental impact. Having made this~ determination, we  !

s have further concluded that the amendments involve an action which is insig-nificant from the standpoint of environmental impact and, pursuant to 10 CFR l 551.5(d)(4), that an environmental impact statement or negative declaration l and environmental impact appraisal need not be prepared in connection with  :

the issuance of these amendments. {

V. CONCLUSION We have concluded, based on the considerations discussed above, that: (1) l because the amendments do not involve a significant increase in the probability  !

or consequences of accidents previously considered and do not involve a signifi-cant decrease in a safety margin, the amendments do not involve a significant 1

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. significant hazards consideration (2) there is reasonable assurance that  :

the health and safety of the public will not be endangered by operation in the proposeo manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of these amendments will not be inimical to the comon defense and security or to the health and safety of the public.

Date: December 24, 1981 l

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i SEP 151982 Distribution: . l Docket File t NRC PDR

Local PDR -

Docket Nos. -

s ht CParrish .

i DMcDonald  !

OELD i RS Dr.' Robert E. Uhrig. Vice President hgE 1)

Advanced Systems and Technology Florida Power and Light Company RSIC ~'-- *

Post Office Box 529100 8#8Y  ;

, Miami, Florida 33152 l i

Dear Dr. Uhrig:

RE: T!!! ACTION PLAN ITE!! II.E.1.2 AUXILIARY (EMER3ENCY FEEDWATER SYSTEMS)

, .- AUT0!RTIC INITIATION AND FLOW INDICATION r-j NUREG-0737 Item II.E.1.2 requires that the Auxiliary Feedwater Systems '

(AFWS) in pressurized water reactor facilities be upgraded where necessary  ;

to ensure safety grade automatic initiation and flow indication. We have  !

reviewed your submittals for Turkey Point. Units 3 and 4, in relation to ,

i "...'

the long term safety grade requirements for the automatic initiation and flow indication of the AFWS. l Based on our review, we have concluded that the automatic initiation and  !

flow indication portions of the AFWS comply with the long term safety grade l requirements and are acceptable. ,, j The enclosed Safety Evaluation Report provides the details of our review.

l l Sincerely. l l griginal sisneaw j

^ S.4.varga

! Steven A. Varga Chief l Operating lteactors Branch f1  ;

Division of Licensing  !

Enclosure:

Safety Evaluation Report ec: See next page

• l f -l5 y 3 '., '? ,

@ M $?SigL F/3 1 . - - - - _. ---- .----__-- -

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Robert E. Uhrig Florida Power and Light Company . , j James P. O'Reilly l cc: Harold F. Reis. Esquire Lowenstein, Newman, Reis and Axelrad Regional Administrator - Region II l 1025 Connecticut Avenue, N.W. U. S. Nuclear Regulatory Commission j Suite 1214 ,

101 Marietta Street - Suite 3100  ;

Washington, D. C. 20036 Atlanta, Georgia 30303 i l

Environmental and Urban Affairs Library Florida International University

. , Miami, Florida 33199  ;

i Norman A. Coll Esquire ~

Steel Hector and Davis "'-

- 1400 Southeast First National Bank Building i

- Miami, Florida 33131 . .  ;

6 Mr. Henry Yaeger, Plant Manager I Turkey Point Plant p

.- Florida Power and Light Company -

l P. O. Box 013100 ,

j Miami, Florida 33101 Mr. Jack Shreve - '

Office of the Public Counsel Room 4. Holland Building

{) Tallahassee, Florid: 32304 Administrator  !

Department of Environmental Regulation i

, Power Plant Siting Section *

! State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Resident Inspector  !

} Turkey Point Nuclear Generating' Station i U. S. Nuclear Regulatory Commission l j Post Office Box 1207 Homestead, Florida .33030  !

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[ SAFETY EVALUATION TURKEY POINT UNITS 3 & 4 AUXILI ARY FEEDWATER

AUTOMATIC INITIATION kND FLOW

• INDICATION ACTION PLAN ITEM II.E.

1.2 INTRODUCTION

AND

SUMMARY

To improve the reliability of Auxiliary Feedwater Systems (AFWS) at pressurized

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water reactor (PWR) facilities, the staff is mquiring licensees to upgrade the system where necessary to ensum safety grade a'utomatic initiation and flow indication. The criteria for this upgrading.are contained in NUREG-0737 (Clarifications of TMI Action Plan Requirements)Section II.E.1.2.

The evaluation of the Turkey Point AFWS design was performed for the NRC by Franklin Research Center (FRC) as part of a technical assistance contract pro- l gram. The results of the FRC e' valuation are reported in the attached Technical b

Evaluation Report (TER - CS257 - 273/284).

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} Based on our review of the FRC TER and subsequent conversations with the licensee, we conclude that the AFW automatic initiation and flow indication designs are f

' acceptable.

EVALUATION j The attached TER provides a technical evaluation of the electrical, instrumentation, and control design aspects of the Turkey Point Units 3 & 4 AFWS with regard to auto-matic initiation and flow indication. The AFWS flow path to each steam generator contains two normally closed flow control valves (one train "A" valve and one train "B" valve) in parallel. Both valves are comanded to open ori an

, , automatic start signal. As flow increases above the setpoint (400 gpm per steam generator), AFUS flow controllers (one per valve) modulate the valve pcsitions to mui isisi mai si sm - w

maintain desired flow. These valves fail closed on loss of air or electrical powe r.

As noted on page 8 of the TER, if all of the flow controllers are set for zero flow, no AFWS flow will be initiated to the steam generators on an automatic 4 start signal. This is, in effect, a bypass of the AFWS automatic start signal.

There is no annunciation of this condition provided in the control room. The 400 gpm

] setpoint is administrative 1y established as part of Operating Procedure #202.1 4 (Reactor Startup-told Condition to Hot Shutdown Condition).

If all of the flow controllers were set at zero flow, the operator would be able i

i to detect this via the AFWS flow indication (one flow channel per steam generator)

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! and the flow controller output signals (although this is indirect indication of - -

C:.:- valve position). One of the first priorities of the operator is to verify that  !

AFWS flow to the steam generators has been established. If the operator failed to diagnose this situation (i.e., all discharge valves closed), a low steam 4

generator water level alarm would sound in the control room, after which the c'p erator would still have sufficient time to determine the situation and take the necessary actions to establish flow. Based on the above, the staff finds this aspect of the Turkey Point AFWS design to be acceptable. l i

The Turkey point AFWS design uses three turbine driven pumps which are shared between units. As noted in the TER there is no diversity of pump power supplies, however, since there are multiple sources of steam for these pumps which must l

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- 3-be available in accordance with the Turkey Point Technical Specifications, the Auxiliary Systems Branch (ASB) has found this arrangement to be acceptable.

Page 7 of the TER lists a channel bypass provided for periodic testing of the AFWS and for removal of a channel fmm service for maintenance purposes. It is stated in the TER that placing a channel in bypass changes the coincidence logic from two-out-of-three to two-out-of-two,to accomplish an AFWS automatic start.

This was based on a description of this bypass contained in Florida Power & Light (FPL) Company Letter L-81-36' dated February 3,1981. In actuality, this is not a bypass since removing a channel from service places that channel in

,- the tripped condition, thereby changing the. coincidence logic from two-out-of-three to one-out-of-two. FPL should amend the February 3,1981 letter to accurately describe how the AFWS actuation logic is affected when a channel is removed from O servi ce. In addition, the conclusion portions of the TER (pages 9 and 13) indicate that contml room annunciation of these " bypasses" should be, but is not, provided.

It is our understanding, following telephone conversations with the licensee (Florida Power and Light - FP&L), that annunciation (both alarm and light indication) is automatically provided whenever a channel is placed in the tripped condition. Based on the above, we find this design aspect to be acceptable.

We have reviewed the Turkey Point Units 3 & 4 Technical Specifications regarding surveillance requirements for the AFWS instrument channels (used for both automatic start and flow indication) and the automatic actuation logic. Based on conversations with FP&L during which they stated that Item 24 (Logic Channels) of Table 4.1-1 (Minimum Frequencies for Checks, Calibrations, and Test of Instrument Channels) includes testing of the AFWS automatic actuation logic, we find the 9

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Turkey Point Technical Specification surveillance requirements concerning the AFWS to be acceptable.

The environmental qualification of safety related systems including AFWS circuits and components is being reviewed by the Equipment Qualf fication Branch as part of their review of licensee responses to " Guidelines for Evaluating '

Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors,"

issued to the licensee in NRR letter date'd March 5,1980.

In order to adequately determine from the control room the performance of the AFW steam generator level instrumentation is used, in addition to flow indication. .The  !

requirements for this steam generator level instrumentation are specified in I

" Instrumentation for Light-Water-Regulatory Guide 1.97 Revision 2 (R.G.1.97 '

() Cooled Nuclear Power Plants to Assess Plant and Envirens Conditions During and ,

Following an Accident"). The steam generator level instrumentation at Turkey

' Point should be in conformance with these requirements and implemented in accordance l

with the schedule for implementation of the referenced R.G.  ;

CONCLUSION Based on our review of the Franklin Research Center TER and subsequent conversatio l

with the licensee, we conclude that the Turkey Point Units 3 & 4 AFWS automatic l

initiation and flow indication systems complyv4th the staff's long term safety i

grade requirements, and therefore, are acceptable. t Principal Contributor: R. Kendall )

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TECHNICAL EVALUATION REPORT AUXlLIARY FEEDWATER SYSTEM AUTOMATIC .

INITjATION AND FLOW INDICATION (F-16, F-17)

FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 ,

NRC DOCKET NO. 50-250, 50-251 FRC FRORC7 N

"* FRC ASS!GNMENT 9 NRC TAC N O. 42324, 42325

.FRCTASX5 273, 284 NRC dONTRACT NO. NRCh3-75-118 Preparedby Author: J. E. Kaucher . l Franklin Research Center .

20th and Race Street FRC Group Leader: K. Tertner  ;

Philadelphia, PA 19103 O Preparedfor Nuclear Regulatory Commission j Washington, D.C. 20555 Lead NRC Engineer: R. Kendall June 18, 1982 l

This report was prepared as an account of work sponsored by an

^* agency of the United States Government. Neither the United States  ;

Government nor any agency thereof, or any of their employees,  ;

makes any warranty, expressed or implied, or assumes any legal  !

liability or responsibility for any third party's use, or the results of l such use, of any information, apparatus, product or process l; disclosed in this report, or represents that its use by such third party would not inf ringe privately owned rights.

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A Division of The FrankJin institute  !

N 8even Freewm Part-ey.PNo Pa ISIO3 (2t$14481000

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TER-C3257-273/284

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CONTENTS Section 7_itle g 1 INTRODUCTION . . . . . . . . . . . . . 1 1.1 Purpose of Review . . ."*. . . . . . . . 1 1.2 Generic Issue Background . . . .

. . . . 1 1.3 Plant-specific Background . . . . . . . . 2 2 REVIIN CRITERIA . . . . . . . . . . . . 3 3 TECENICAL EVALUATION . . . . . . . . . . . $

3.1 General Description of Auxiliary Feedwater System ., . 5 ,

3.2 Automatic Initiation. . . . . . . . . . 5 0 2.2.1 3.2.2 Eva1uation Conclusion

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3.3 Flow Indication . . . . . . . . . . . 3 i 3.3.1 Evaluation . . . . . . . . . . p 3.3.2 Conclusion . . . . . . . . . . 10 3.4 Description of Steam Generator Level Indication . . . 10 4 CONCLUSIONS . . . . . . . . . . . . . 13 5 REFERENCES . . . . . . . . . . . . . 14 9

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TER-C5257-273/284

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i Tnis Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear ' Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Operating Beactors) for technical assistance in support of NRC operating re' actor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRO.

Mr. J. E. Kaucher contributed to the technical preparation of this report through a subcontract with WESTE0 Services, Inc. ,

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, 1. INTRODUCTION 1.1 PURPOSE or REVIEW The purpose of this review is to provide a technical evaluation of the emergency feedwater systes design to verify that both safety-grade automatic initiation circuitry and flow indication are provided at Turkey Point Units 3 and 4. In addition, the steam generatgr, level indication available at these units is described to assist subsequent NRC staff review.

1.2 GENERIC ISSUE BACKGROUND A post-accident design review by the U.S. Nuclear Regulatory Commission (NRC) after the March 28, 1979 incident at Three Mile Island (TMI) Unit 2 has established that the auxiliary feedwater (AN) system should be treated as a safety system in a pressurised water reactor (FWR) plant. The designs of

{} safety systems in a nuclear power plant ate required to meet the general design critaris (GDC) specified in Appendix A of 10CFR50 (1).

The relevant design criteria for the AFW system design are GDC 13, GDC 20, and CDC 34. GDC 13 sets forth the requirement for instrumentation to monitor variables and systems (over their anticipated rartges of operation) that can affect reactor safety. GDC 20 requires that a protection system be designed to initiate automatically in order to assure that acceptable fuel design limits s're not exceeded as a result of anticipated operational occurrences. GDC 34 requires that the safety function of the designed system, that is, the residual. heat removal by the AFW system, can be accomplished even in the case of a single failure.

On September 13, 1979, the NRC issued a letter (2) to each pWR licensee.

that defined a set of short-term requirements specified in NUREG-0578 (31 It required that the AM system have automatic initiation and single failure-proof design consistent with the requirements of GDC 20 and GDC 34. In addition, AFW flow inoication in the control rooc must be provided to satisfy the require-ments set forth in CDC 13.

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. . TER-C5257-273/284 During the we'ek of September 24, 1979, seminars were held in four regions cf the country to discuss the short-term requirements. On October 30, 1979. -

cnother letter was issued to each PWR licensee providing additional clarifica-tion of the NRC staff short-term requirements without altering their intent (4).

Post-TMI analyses of primary system response to feedwater transients and l reliability of installed AFW systems also established that, in the long ters, the AFW system should be upgraded in acc*oidance with safety-grade require-ments.

These long-term requirements were clarified in the letter of september

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5, 1980 [5).

This letter in'corporated in one document, NUREG-0737 [6), all 2MI-related items approved by the commission for implementation at that time.

~~ section II.E.1.2 of NUREG-0737 clarifies th'e requirements for the APW system cutomatic initiation and flow indication. .

l F. 1.3 FLANT-SPECIFIC BACKGROUND d l In Reference 2, the NRC informed the Licensee, Florida Power and Light g j

Company (FPL),

that it would have to meet the requirements of NUREG-0578.

Reference 4 clarified and reiterated this requirement. f On November 21, 1979 [7), FPL replied to the two NRC letters on the cub 3ect of short-tera requirements.  ;

Comments in FPL's letter relative to the Ard system centered on interim control-grade automatic initiation and flow indication systems. [ ,

On January 14, 1980 [8), FPL provided detailed information on the Ani d: sign, citing specific items of Sections 2.1.7.a and 2.1.7.b of NUREG-0578 .

On February 3, 1981 [9), E FPL sent a letter to the NRC descricing proposed Ard system changes in detail.

on April 13, 1981 [10), m FPL submitted a revision to the Turkey Point

• 20thnical Specifications to the NRC Dire tor, Division of Licensing.

By letter dated Jaly 23, 1981 [11), F7L submitted additional information Ctnterning the Turkey Point Units 3 and 4 APW system.

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TER-C5257-273/284

2. REVIEh CRITERIh To improve the reliability of the AFW system, the NRC required licensees to upgrade the system, where necessary, to ensure timely automatic initiation when required. Tne system upgrade was to proceed in two phases. In the short tern, as a minimum, control-grade signals and circuits were to be used to automatically initiate the AN system. 'this control-grade system was to seat the following requirements of NUREG-0178,, Section 2.1.7.a (3):

• 1. The , design shall pr, ovide for the automatic initiation of the auxiliary feedwater system. -

2. The automatic initiation signals and circuits shall be designed so

, . that a single failure will not result in the loss of auxiliary feedwater system function.

3. Testability of the initiating signals and circuits shall be a feature .

, of the design.

, 4. Tne initiating signals and circuits shall be powered from the i

emergency buses. '

4 l 5. Manual capability to initiate the auxiliary feedwater system from the control room shall be retained and shall be implemented so that a i

single failure in the manual circuits will not result in the loss of I

systas function.

6. The ac actor-driven pumps and valves in the auxiliary feedwater system shall be included in the automatic actuation (simultaneous

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and/or, sequential) of the loads to the emergency buses.

! 7. The automatic initiating signals and circuits shall be designed so that their failure will not result in the loss of manual capability to initiate the AW systes from the control roca."

In the long tera, these signals and circuits were to be upgraded in accor-dance with safety-grade requirements. Specifically, in addition to the above requirements, the automatic initiation signals and circuits must have indepen-1 dent channels, use environmentally qualified cocponents, have system bypassed /

inoperable status features, and conform to control system interaction criteria, as stipulated in IEEE std 279-1971 [12).

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TEA-C3257-273/284 ThecapabilitytoascertaintheANsystemh>erformancefromthecontrol roca must also be provided. In the short tera, steam generator level indica-tion and flow measurement were to be used to assist the operator in maintaining the required steam generator level during AN system operation. This system was to meet the following requirements from NUREG-0578, section 2.1.7.b [3):

• 1. Safety-grade indication of auxiliary feedwater flow to each steam generator shall be provided in the control room.

2. The auxiliary feedwater flow 1nstrument channels shall be powered from the emergency buses consistent with satisfying the emergency power

• diversity requirements of the auxiliary feedwater system set forth in Auxiliary Systems Branch Technical Position 10-1 of the Standard Review Plan, Section 10.4.9 [13)."

The NRO staff has determined that, in the long tera, the overall flowrate indication system for Westinghouse plants must include either one A N flowrate indicator with one wide-range steam generator level indicator for each steam g-generator, or two flowrate indicators. The flowrate indication systen must be environmentally qualified, powered fees a highly reliable, battery-bacned non-class 1E power source, periodically testable, part of the plant's quality casurance program, and capable of display on demand.

The operator relies on steam generator level instrumentation and AN flow l

indication to monitor AN system performance. The requirements for this steam f

generator level instrumentation are specified in Regulatory Guide 1.97, Revision 2, " Instrumentation for I.ight-Water-cooled Nuclear Power Pirnts to Assess Plant and Environs Conditions During and Following an Accident * [14).

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3. TECHNICAL EVALUATION

! 3.1 GENERAL DESCP.IPTION OF TEE ACEILIARY FEEDWATER SYSTEM The auxiliary feedwater (AFW) systen at Turkey Point Units 3 and 4

, supplies water to' the seccndary side of the steam generator for reactor decay heat removal when normal feedwater sources are unavailable due to loss of of fsite power or other salfunctions. The system consists of three steaa turbine-driven pumps (600 gpa at 2775 feet of water) capable of supplying feedwater to any or all of the six steam generators in. the two units. All .

three pumps are interconnected on the discharge side to two common discharge lines, one line to each unit. These common discharge lines each branch into three supply lines for the three steam generators in each unit. The AFW lines i

j to each steam generator contain two normally closed, de, air-operated flow

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control valves in parallel. , ,

5 3.2 AUTOKATIC IF*TIATION ,

j 3.2.1 Evaluation  !

Auxiliary feecwater flow to the steam generators is automatically initiated when preset levels of any of the following parameters are exceeded

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Turbine-Driven Pumps .  ;

l 1. Safety, injection (2 of 3) [

{ 2. Low stema generator level in any one steam generator (2 of 3) i

3. Loss of voltage on both 4160 V buses I

4. Less of both main feedwater pumps, j t

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All initiating signals and circuits are supplied from redundant, Class 7

1E, vir.a1 power supplies, as is the control powe,r for all AFW valves. In addition, all ac-operated valves are automatically loaded onto the diesel

generators.

9 Tne normal valve configuration for the AFW system is all AFW pump suction valves open, discharge flow control valves closed, and the steam admission -

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TER-C5257-273/28 4 valves to the turbine-driven pumps closed. The steam admission valves to two of the three AW pcmps are being modified so that they are de-operated; thus, two of the AFW pumps will start independently of ac power availability.

Bowever, all three AFW pumps are turbine-driven, and the AFW system, therefore, does not meet the pump power supply diversity requirement. The AFW pumps discharge control' valves are de solenoid / air-operated valves. The air supply for all valves is backed by a seismically qualified nitrogen supply that -

cutomatically initiates on loss of nora.41, air supply.

The operation of any one AFW pump will provide the necessary capacity for removing decay heat to prevent overpressurization of the reactor coolant cystem and to maintain steam generator levels. All three APW pumps start upon cutomatic system actuation, and automatic isolation of a leaking steam generator is a design feature of the system and is provided by the main steam isolation system.

The primary source of water for the AFW system is the 250,000-g al,

) seismic Category 1, condensate storage tanks (CST) of both units. Sufficient water inventory (185,000 gal) is maintained in the tanks to bring the plant to hot standby, hold there for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />, and subsequently cool down to the residual heat removal system entry tamperature of 350*F. Indication of CST lovel is provided in the main control room, and annunciation and alarm of CST 15w water level is provided.

The backup water supply for the AFW system uses water from the plant water treatment system to resupply the CST: this method could not be used if the CST were not available. The Licensee further stated that a non-safety-grade l 500,000-gallon deserated water storage tank is being CCnstructed and will be available to supply the CSTs.

A review of initiation logic and wiring diagrams revealed no credible oingle malf unction that would prevent protective action at- the system level .

when required.

In, addition, the Licensee has stated that the design of the '

AFW system initiation logic meets IEEE std 279-1971 in that no single component failure will prevent the automatic start signal from being initiated, and the i

initiatang sagnals and circuits are powered from safety-grade power suppites.

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TEA-C5257-273/284 Manual operation of the ATW system is provided in the control room and at tne local station. Each control circuit is independent so that a single -

failure in one train will not affect the redundant train. In addition, the automatic initiating circuits are designed to be electrically independent from the control rooo manual start circuit so that the failure of the automatic initiating signals does not affect the ' control room manual capability of AFW pumps.

Mone of the protection signals fo,r the automatic initiation of AFW are used as control signals; consequently, there is no control and protection cystem interaqtion. ,

seismic requirements for the energency feedwater system were not considered in the single failure analysis because the NRC will address this issue separately. A detensination of whether components are qualified for cecident and post-accident environments was not conducted. The environmental qualification of safety-related systems, including AFW system circuits and compenents, is being determined separately by the NRO and is not within the scope of this review.

Review of the initiation circuit diagrams revealed no credible single malfunction that would prevent proper systes action when required.

The electrical isolation and physical separation of elements of the proposed auxiliary feedwater actuation systes design comply with the require-cents of NUREG-0578 [3] and IEEE sto 279-1971 [12].

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• Concerning bypasses, the Licensee has stated the following:

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Trio Cnannel Bypass - This bypass is provided for periodic testing of '

the system and to remove a channel from service due to a component failure. .l Tnis bypass is manually initiated and manually res:ved.

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Only one channel can be bypassed at a time, and the coincidence logic is 2 of 2 while in test.

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o The Licensee has stated that the system contains no operating bypasses. ,

The design of the AFW control valves is such that the initiation signal y

cperates a solenoid valve in series with the control air signal to each gg .... Frank!.n Res,earch Center eow.w. - m d

TER-CS257-273/284 control valve. There are no overrides in the control circuit for the solenoid valve s bowever, tie air signal to the control valve can be controlled .

automatically or manually by the operator in the control roca via hand indicating controllers mounted on the main contrcl consoles 3 and 4. This dasign allows for considerable operational flexibility, but in effect allows the operator to override an actuation signal by taking manual control of the flow control valves and thus does not meet the requirements of 1ZZZ Std 279-1971. The salient points are that where operating requirements cccessitate automatic or manual bypass of a protective function, the design thould be such that the bypass will be removed automatically whenever permissive conditions are not mets continuous indication of the bypass condition in the control room is required; .and a means for administratively controlling the bypass should be provided.

• l The AW pu=p discharge lines and turbine-driven AN pump steam supply lines for each unit combine into single lines through which all water and cteam,.respectively, from either unit must flow. A pipe break in either of these single flow paths would cause loss of the capability to provide AN flow to all the steam generators of one unit. The Licensee has agreed to develop Cperating procedures to provide direction to the operators regarding isolation cf AN system steam supply lines or feedwater line piping breaks. Steam and foedwater piping modifications are also being developed to ensure redundancy ,

in the common AN discharge header and the connon steam supply header to the .

A N pu=p turbines.

Tne Turkey Point Technical Specifications require that each AN pump be tasted once each month. A N flow is initiatrd by manually opening valves (from the control room) to admit steam to the A N pump turbine and therefore establish AN flow to the steam generators. Channel functional tests are

• req. aired at least once every 62 days, and initiating signals and circuits are '

tested during the integrated safeguards test performed during each refueling

• cutage. .

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TER-C5257-273/284 3.2.2 Conclusion It is concluded that the initiation signals, logic, and associated "

circuitry of the Turkey Point Units 3 and 4 m system comply with the long-term safety-grade requirements of section 2.1.7.a of NUREG-0578 (3) and the subsequent clarification issued by ,the NRC with the following exceptions:

o p unciation of channel bypasses, in the control reca, is not provided, o The manual bypass capability fo'r"bontrolling the ATW flow control valves,should be designed in accordance with IEEE sto 279-1971, to i provide automatic removal of the bypass when permissive conditions are not met, continuous indiction in the control roca of the bypass condition, and a means for administrative 1y controlling the bypass switch.

3.3 FIDW Ih*JICATION 3.3.1 Evaluation h Zach of the Ani pump headers to each steam generator is equipped with a flow transmitter with output indicated in the control room and locally at the Ant control valve location. In addition, wide-range, non-safety-grade steam generator level indication is provided. Both flow and level are continuously

• displayed in the control room.

i The AFW flow indication system is powered from the vital bus sytem, which is a Class 1E power source. The AFW flow signal is also used as an input to the Ani flow control system.

The Licensee has stated that the AFW flow indication system is part of .

the plant quality assurance program. i AFW flow indication system channel checks are performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> i cnd channel functional tests are performed monthly. Channel calibration is .

P2rformed each refueling outage. B The environmental qualification of flow measurement and indication cquipment is being reviewed separately by the NRC and is outside the scope of this review.

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It is concluded that the sensors, transmitters, indicators, and recorders ,

of the Turkey Points Units 3 and 4 AFW flow measurement system comply with the l j

requirements of Section 2.1.7.b of NUREG-0578 and the subsequent clarification issued by the NRC.  !

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3.4 DESCRIPTION

OF STEAM GENERATOR LEVEL INDICATION steam generator level instrumentation at Turkey Point Units 3 and 4 serves several purposes in addition to control room panel indication. There are three cafety-related measurement channels and two non-safety-related channels for cach of the three steam generators in each. nuclear unit. One non-safety-related channel in each steam generator employs a wide-range sensor for indication and recording only (one 3-pen recorder in the control room). Safety-related channels employ narrow-range sensors that provide signals for the following: ,

1. reactor trip, turbine trip, feedwater pump trip, and automatic initiation of ATW system based on low-low levels

2. turbine trip and feedwater pump trip based upon high-high levels

3. control of main feedwater flow control valves tbrough an isolation device.

The remaining non-safety-related channel in each steam generator is available as an alternate means for control of the main feedwater flow control valves.

All safety-related channels are powered from energency buses. All are independent and separated to the extent that cables are run in separate raceways.

Non-safety-related channels are powered from normal 120-Vac non-class 1E buses. ,

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Iow and high level alaras are provided on the main annunciator panels for cach stea= generator. i I

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Safety-related channels are checked every 31 days as part of engineered i safety features s'etuation system surveillance. Calibration is performed during scheduled refueling outages (12- to 18-month intervals). '

Separate control room panel indicators are provided for each safety- .

t related channel of measurement (nine for each nuclear unit). A selector switch permits the operator to record any one of the channels for each steam j generator. [

5 Table 1 lists the safety-related channels for all three steam generators  !

of each nuclair unit: Table 2 lists non-safety-related narrow-range instrumen- 1 tation for the three steam generators of each nuclear unit; and Table 3 lists i non-safety-related wide-range instrumentation for the three steam generators of each nuclear unit. ,

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TIR-C5257-273/284 Table 1 Sa fetv-Related Level l

Transmitter l Range '

Steam Instruments (inches of Generator Tag No. Channel water column) )

l 1 LT-474 I 30.13-138.22 1 LT-475 II ,

1 LT-476 II -

2 LT-4 84 II * *

~

2 LT-435 II * * '

2 LT-486 II *

• 3 LT-494 II * *

~

3 LT-495 II *

• 3 LT-496 II *

• Table 2

, Non-Safety-Related Level Steam Invel Instruments (Narrow Rance)

Transmitter Generator No. Range Safety (inches of Tag No. Channel water column) 1 LT-4 78 NSR 0-143 2 LT-488 *

• 3 LT-498 *

• Table 3 '

Non-Safety-Related Level Level Instruments (Wide Range)

Steam Transmitter

• Generator No. Range (inches of '

Tag No.

• water column)

• 1 LT-477 1 0-513 2 LT-487

• i i i 3 LT-4 97 . '

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't TER-C5257-273/284

4. CONOLUSIONS It is concluded that the initiation signals, logic, and associated circuitry of the Turkey Point Units 3 and 4 auxiliary feedwater system comply with the long-term, saf ety-grade requirements of Section 2.1.7.a of NUREG-0578

13) and the subsequent clarification issued by the NRO with the following exceptions:

o Annunciation of channel bypasses, in the control room, is not provided.

o The manual bypass capability for controlling the AFW flow control valves should be designed in accordance with IEEE Std 279-1971, to

-. provide automatic removal of the bypass when permissive conditions are not met, continuous indication in "the control roca of the bypass condition, and a means for administrative 1y controlling the bypass switch.

It is concluded that the sensors, transmitters, indicators, and recorders of the Turkey Point Units 3 and 4 AFW flow measurement system co= ply with the requirements of Section 2.1.7.b of NUREG-0578 and the subsequent clarification issued by the NRO.

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TER-CS257-273/284

5. REF7.RENCES

1. Code of Federal Regulations, Title 10, Office of the Federal Register, National Archives and Records Service, General Services Administration, Revised January 1,1980

2. NRC generic letter to all PWR licensees.

Subject:

Short-term Requirements Resulting from Three Mile Island Accident i NRC, September 13, 1979 '

3. NUREG-0578 TMI-2 Imssons Imarned Task Force Status Report and Short-tern Recommendations NRC, July 1979

{

4. NRO generic letter to all PWR licensees. Subject Clarification of Lessons Learned Short-tern Eaquirements

. NRO, October 30, 1979 -

5. WR generic letter to all FWR licensees.

Subject:

Short-tern Requirements Resulting from Three Mile Island Accident l NR , September 5,1980

6. NUREG-0737 Clarification of 'DiI Action Plan Requirements l NRO, November 1980

7. R. E. Uhrig (FPL)

Letter to D. G. Eisenhut (Division of Operating Reactora (DOR] NRO)

Subject:

Short-tern Requirements-FPL Responses November 21, 1979

8. R. E. Uhr'ig (TPL)

Letter to A. Schwencer (DOR, NRC) I

Subject:

Reply to NRC Recommendations 2.1.7.a and 2.1.7.h of NUREG-0578 January 14, 1980

9. R. E. Uhrig (FPL) I Letter to D. C. Eisenhut (DOR, NRC)

Subject:

Detailed Description of FPL Replies to NUREG-0578 -

l February 3, 1981

10. R. E. Uhrig (TPL) i Letter to D. G. Eisenhut (Director, Office of Nuclear Reactor l Regulation, Division of Licensing)

Subject:

Proposed Changes to the Technical Specification for ,

Turkey Point Units 3 and 4 April 13, 1981 I g .... Frankhn a ww .#Res,earc.h w ,.a %Center I

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TER45257-273/284

11. R. E. C. rig, (FPL) 14tter to S. A. Varga (DOR, NRC) *

Subject:

Responses to Questions Raised in Reference 14 July 23, 1981

12. IEEE Std 279-1971

• Criteria for Protection Systems for Nuclear Power Generating Stations" .

Institute of Electrical and Electronics Engineers, Inc., New York, NY

13. NUREG-75/087 Standard Review Plan, Section 10.4.9, Rev.1 NRO

14. Regulatory Guide 1.97 (Task RS 917-4)

Instrumentation for Light-Water-Cooled Nuclear Power Plants to  !

Aasess Plant and Environs Conditions' During and Pollowing an Accident, Rev. 2 l NRO, December 1980 l O i i

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I' g t *Frank!in W st n Research

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a UNITED STATES NUCLEAR REGULATORY COMMISSION C I WASHINGTON, D. C. 20S55

'++ , , , , . # November 4,1982 Docket Nos. 50-250 and 50-251

- Dr. Robert E. Uhrig, Vice President

Advanced Systems and Technology I

Florida Power and Light Company Post Office Box 529100 l Miami, Florida 33152

Dear Dr. Uhrig:

The Comission has issued the enclosed Amendment No. 89 to Facility Operating i License No. DPR-31 and Amendment No. 83 to Facility Operating License No. l DPR-41 for the Turkey Point Plant Unit Nos. 3 and 4 respectively. The amendments consist of changes to the Technical Specifications in response to your application transmitted by letter dated May 6,1982.

These amendments change the Technical Specifications to conform with the Comission's Bulletins and Orders Task Force review regardino Auxiliary Feedwater Pump requirements following the Three Mile Island Accident.

The issuance of the enclosed amendments and the Safety Evaluation concludes our review of your responses to the September 21, 1979 letter and TMI Action Items II.E.1.1 and II.E.1.2 are complete.

Copies of the Safety Evaluation and the Notice of Issuance are also enclosed.

Sincerely, Im_

~

Daniel G. Mcdonald, Project Manager Operating Reactors Branch #1 ,

Division of Licensing ,

Enclo'sures:

1. Amendment No. 89 to DPR-31

2. Amendment No. 83 to DPR-41

3. Safety Evaluation

4. Notice of Issuance cc w/ enclosures:

See next page T

• w wy, , e 7 /

Robert E. Uhrig

. Florida Power and Light Company

(

cc: Harold F. Reis Esquire Mr. Jack Shreve Lowenstein, Newman, Reis and Axelrad Office of the Public Counsel 1025 Connecticut Avenue, N.W. Room 4 Holland Building Suite 1214 Tallahassee, Florida 32304 Washington, D. C. 20036 Administrator Bureau of Intergovernmental Relations Department of Environmental 660 Apalachee Parkway Regulation Tallahassee, Florida 33130 Power Plant Siting Section State of Florida Norman A. Coll, Esquire 2600 Blair Stone Road Steel Hector and Davis Tallahassee, Florida 32301 1400 Southeast First National Bank Building James P. O'Reilly Miami, Florida 33131 Regional Administrator - Region II U. S. Nuclear Regulatory Commission Mr. Henry Yaeger, Plant Manager 101 Marietta Street - Suite 3100 Turkey Point Plant Atlanta, Georgia 30303 Florida Power and Light Company P. O. Box 013100 Miami, Florida 33101 Mr. M. R. Stierheim County Manager of Metropolitan .i h Dade County Miami, Florida 33130 Resident inspector ,

Turkey Point Nuclear Generating Station '

U. S. Nuclear Regulatory Commission Post Office Box 1207 -

Homestead, Florida 33030 Regional Radiation Representative

. EPA Region IV 345 Courtland Street, N.W.  ;

Atlanta, Georgia 30308 j i

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\,....*/ l FLORIDA POWER AND LIfiHT COMPANY l i

DOCKET NO. 50-250 l i

TURKEY POINT PLANT UNIT NO. 3  !

I AMENDMENT TO FACILITY OPERATING LICENSE i f

Amendment No. 89 License No. DPR-31 l

1. The Nuclear Regulatory Comiission (the Commission) has found that: ,

i A. The application for amendment by Florida Power and Light l Company (the licensee) dated May 6,1982, complies with  !

the standards and requirements of the Atomic Energy Act of l 1954, as amended (the Act) and the Commission's rules and j regulations set forth in 10 CFR Chapter I; '

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of j the Commission, i

0- C. There is reasonable assurance (1) that the activities authorized

)

by this amendment can be conducted without endangering the health  !

and safety of the public, and (ii) that such activities will be l conducted in compliance with the Comission's regulations; 6 D. The issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public-

)

and i E. The issuance of this amendment is in accordance with 10 CFR Part l

~

51 of the Commission's regulations and all applicable requirments -

have been satisfied.

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2. Accordingly, the license is amended hy changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-31 is herehy amended to read as follows:

(B) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 89 . are herehy incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance.

F0 k THE NUCLEAR EGULATORY COMMISSION

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Y e iY, h Operating Reactors B ch #1 Division of Licensing

Attachment:

Changes to the Technical Specifications Date of Issuance: November 4,1982

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$2 recg'o UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION

'I WASHINGTON D. C. 20555 FLORIDA POWER AND LIGHT COMPANY

! DOCKET NO. 50-251 TURKEY POINT PLANT UNIT NO. 4 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 83 License No. DPR-41

'l . The Nuclear Regulatory Commission (the Comission) has found that:

A. The application for amendment by Florida Power and Light Company (the licensee) dated May 6,1982, complies with

,_ the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. Tne facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of ,

the Commission; O C. There is reasonable assurance (1) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be j

conducted in compliance with the Comission's regulations; D. The issuance of this amendment will not be inimical to the common I defense and security or to the health and safety of the public; I and

- E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Cocaission's regulations and all applicable requirenents have been satisfied, 4

i I

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Facility Operating License No. DPR-41 is hereby amended to read as follows:

(B) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 83 , are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance.

FOR THE NUCLE / REGULATORY COMMISSION

[h ['i L

l even arga, h'ef perating Reacto B anch (1 Division of Licens

Attachment:

Changes to the Technical Specifications Date of Issuance: November 4,1982

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ATTACHMENT TO LICENSE AMENDMENTS AMENDMENT NO. 89 TO FACILITY OPERATING LICENSE NO. DPR-31 AMENDMENT NO. 83 TO FACILITY OPERATING LICENSE NO. DPR-41 DOCKET NOS. 50-250 AND 50-251 Revise Appendix A as follows:

Remove Page Insert Page 4.10-1 4,10 1 o

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4.10 AUXILIARY FEEDWATER SYSTEM i

Applicability: '

Applies to periodic testing requirements of the auxiliary feedwater system.  ;

Objective:

To verify the operability of the Auxiliary Feedwater and its ability to respond properly when required.'  !

Specifications: 1. Each turbine-driven auxiliary feedwater pump shall be l

started at intervals not greater than one month, run for l

15 minutes and a flow rate of 600 gpm established to the steam generators. The monthly frequency is not intended j to require the test while at cold shutdown. The testing requirement is met by performing this test during startup subsequent to cold shutdown.

2. The auxiliary feedwater discharge valves shall be tested by operator action during pump tests.

-_ 3. Steam supply and turbine pressure valves shall be tested during pump tests.

4. These tests shall be considered satisfactory if control panel indication and visual observation of the equipment demonstrate that all components have operated properly. .

V 5. At ieast once per 18 months:

a. Verify that eachautomatic valve in the flow path actuates to its correct position upon receipt of each auxiliary feedwater actuation test signal. i

b. Verify that each auxiliary feedwater pump receives a start signal as designed automatically upon receipt of g each auxiliary feedwater actuation test signal.

[

- N.A. during cold or refueling shutdowns (only for the Unit at cold or refueling shutdown). The specified tests, however, shall be performed within one f surveillance interval prior to starting the turbine. [

F NOTE:

If any local manual realignment of valves'is required when operating the Auxiliary Feedwater pumps, a dedicat'ed individual, who is in communication with the control room, shall be stationed at the t auxiliary feedwater pump area. Upon instructions from the contial "'

room, this operator would realign the valves in the AFW system train to its normal operational alignment, i 2

4.10-Amendment Nos. 89 & 83 E -

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- Y 'o UNITED STATES I a

' I NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 i., /

....+

l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

_RELATED TO AMENDMENT NO. 89 TO FACILITY OPERATING LICENSE NO AND AMENDMENT NO. 83 TO FACILITY OPERATING LICENSE NO. DPR-41 l FLORIDA POWER AND LIGHT COMPANY TURKEY POINT PLANT UNIT NOS. 3 AND 4 4

DOCKET NOS. 50-250 AND 50-251 I. . INTRODUCTION

~

By letter dated May 6,1982, the Florida Power and Light Company (the licensee).

submitted Plant a request Unit Nos. 3 and to 4 modify the Technical Specifications for the Turkey Point The amendments would change the Technical Specifications to confonn Mile Island to the Bulletins and Orders Task Force review following the Three Accident.

Feedwater System were set forth in our letter dated OctoberThe requirement 16, 1979 j II. BACKGROUND s

The licensee has addressed this issue in their responses dated December 20, 1979 July 22,1980 and January 14, April 13 'and July 23, 1981.

responses and issued Amendment Nos. 75 and 69 on December We 24, reviewed 1981 basedtheir on our initial Safety Evaluation (SE).

for which an additional Technical Specification change and information wa necessary to complete our review. I t

of the auxiliary feedwater review were determined to be in 3 long tenn safety grade requirenents. The acceptability of this portion of the Auxiliary Steven A. VargaFeedwater System and dated Septenber 15, 1982 the SE were sent to the licensee in a letter from Ii III. IMPLEMENTATION OF OUR RECOMENDATIONS i

We have completed our review of the licensee's responses dated January 7. Hay 1

and June 9,1982 which address the open items identified in our initial SE.

i The results of the review and implementation of our recommendations are:

a e

4 B

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c e4.LOF' L'7 O

, 2 A. Recommendation GS-4 " Emergency procedures for transferring to alternate

, sources of AFW supply should be available to the plant operators. These

' - procedures should include criteria to inform the operators when, and in what order, the transfer to alternate water sources should take place.

The following cases should be covered by the procedures.

1. The case in which the primary water supply is not initially available.

The procedures for this case should include any operator actions required to protect the AFW system pumps against self-damage before water flow is initiated; and,

2. The case in which the primary water supply is being depleted. The procedure for this case should provide for transfer to the atlernate water sources prior to draining of the primary water supply."

Technical Specifications are in place which insure the minimum condensate storage tank level is 185,000 gallons. This quantity of water is suffi-cient to maintain a hot standby condition for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> and a subsequent cooldown to 350*F followed by initiation of the residual heat removal

~~ system. Alarms warn the operator of low level situations so that make-up flow can be established from alternate water supplies to the condensate storage tank. Procedures are in effect for initiation of makeup from the condenser hotwell, the primary water system or the service water system.

Thus, it is insured that water will always be initially available for  :

the AFW pumps.

Following automatic initiation of the auxiliary feedwater pumps, the a operator ascertains adequate condensate storage tank level, sufficient flow to the steam generators and notifies the Nuclear Turbine Operator to inspect the pumps for proper operation.  :

The minimum condensate storage tank level control and the emergency procedures to establish alternate water supplies, insure an adequate quantity of water is available to the pumps, for the case there the con-densate storage tank is being depleted.

We conclude that this recommendation is satisfactorily met.

B. Additional Short Term Recommendations

1. Recommendation " Licensees with plants which require local manual realignment of valves to conduct periodic tests on one AFW system train, and there is only one remaining AFW train available for operation, should propose Technical Specifications to provide that a dedicated individual who is in communication with the control room be stationed at the manual valves. Upon instruction from the control room, this operator would realign the valves in the AFW system train from the test mode to its operational alignment."o

. i I.

'F

~

3 By letter dated May 6,1982, the licensee submitted a proposed amendment to Technical Specification 4.10 which applies to periodic test requirements of the auxiliary feedwater system. The amended Technical Specification requires that:

"If any local manual realignment of valves is required when operating the Auxiliary Feedwater pumps, a dedicated indivi-dual, who is in communication with the control room, shall be stationed at the auxiliary feedwater pump area. Upon instructions from the control room, this operator would realign the valves in the AFW system train to its normal operational - '

alignment."

We conclude that the amended Technical Specification fulfills the requirements of the additional short term recomendation, pending approval of it by the Division of Licensing.

C. Recommendation "The AFW pump discharge lines and turbine driven AFW

- pump steam supply lines for each unit combine into single lines through which all water and steam respectively from either unit must flow.

A pipe break in either of these single flow paths would cause loss of the capability to provide AFW flow to all the steam generators of one unit. The licensee should evaluate the consequences of a postulated pipe break in these sections of the AFW discharge or steam supply

' I assuming a concurrent single active failure and 1) determine any AFW

_;g system modifications or procedures necessary to detect and isolate' the break, and direct the required AFW flow to the steam generators before they boil dry or 2) describe how the plant can be brought to a safe i shutdown condition by use of other available systems following such .

a postulated pipe break."  !

r The licensee has developed procedures regarding shutdcwn through the i use of alternate systems and regarding isolation os AFWS steam supply or feedwater line piping breaks. (

~,

The proposed AFW pipe modifications, described in the June 7,1982 letter in response to the above requirement, will provide sufficient i redundancy to eliminate the concern of a single pipe break disrupting feedwater flow to the steam generators. '

I

,- r 1

We conclude that this recommendation has been satisfactorily met. $i D. Basis for Auxiliary Feedwater System Flow Requirements  ;

i f

. The licensee was requested to supply Auxiliary Feedwater (AFW) design '

basis inftrmation in Ei. closure 2 of our October 16, 1979 letter. By i letter dated January 7,1982 the licensee supplied the AFW system flow design bases and criteria. I' I

l r

[

i l ___ . _ . .,

. . i

. The licensee verified that the AFW minimum flow rate requirements could  !

( be maintained under the following transient conditions:

1. Loss of main feedwater

2. Loss of main feedwater with concurrent loss of offsite AC power

3. Loss of main feedwater with concurrent loss of onsite and offsite AC power i

4. Rupture of a main steam line 1

5. Small break Loss of Coolant Accident (LOCA)

6. Turbine trip with and without turbine bypass valve i

7. Main steam isolation valve closure l t 8. Plant cooldown ,

9. Startup (Enclosure 3 of June 9,1982 letter) l Based on our review of the licensee's sulznittal, we conclude that the  !

AFW system can provide sufficient flow for heat removal requirements l following any design basis transient or accident with a concurrent worst i case single active failure.

l h E.

SUMMARY

f We have determined that the licensee has fulfilled all the requirements  !

necessary to confonn with the Comission's Bulletins and Orders Task Force review regarding Auxiliary Feedwater Pump requirements following the Three Mile Island Accident.

IV. ENVIRONMENTAL CONSIDERATION

[

We have determined that the amendments do not authorize a change in effluent  !

types or total amounts nor an increase in power level and will not result in i any significant environmental impact. Having made this determination, we have  !

further concluded that the amendments involve an action which is insignificant i from the standpoint of environmental impact and, pursuant to 10 CFR 551.5(d)(4).-  !

that an environmental impact statement or negative declaration and environmental  :

impact appraisal need not be prepared in connection with the issuance of these  !

amendments.

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'. 5-V. CONCLUSION We have concluded, based on the considerations discussed above, that:

(1) because the amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated, do not create the possibility of an accident of a type different from any evaluated previously, and do not involve a significant reduction '

in a margin of safety, the amendments do not involve a significant hazards consideration (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 the amendments will not be inimical to the common defense and security or to the health and safety of the public. '

Date: November 4,1982 O l I

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• 7590-01 K.

UNITED STATES NUCLEAR REGULATORY COMMISSION

. DOCKET NOS. 50-250 AND 50-251 FLORIDA POWER AND LIGHT COMPANY NOTICE OF ISSUANCE OF AMENDMENTS TO FACILITY OPERATING LICENSES The U. S. Nuclear Regulatory Commission. (the Comission) has issued Amendment No. 89 to Facility Operating License No. DPR-31, and Amendment No. 83 to Facility Operating License No. DPR-41 issued to Florida Power and Light Company (the licensee), which revised Technical Specifications for

! operation of Turkey Point Plant, Unit Nos. 3 and 4 (the facilities) located

,, in Dade County, Florida. The amendments are effective as of the date of issuance.

The amendments change the Technical Specifications to conform with the Commission's Bulletin and Orders Task Force review regarding Auxiliary Feedwater O

Pump requirements following the Three Mile Island Accident.

The application for amendments complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's

- rules and regulations.

The Comission has made appropriate findings as required by the Act and the Comission's rules and regulations in 10 CFR Chapter I, which are set forth in the license amendments. Prior public notice of these amendments was not required since the amendments do not involve a significant hazards consideration.

t The Comission has detemined that the issuance of these amendments will not result in any significant enviromental impact and that pursuant to 10 CFR 551.5(d)(4) an environmental impact statement or negative declaration and snvironmental impact appraisal need not be prepared in connection with issuance i

, of these amendments.

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f 7590-01 l

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1 For further details with respect to this action, see (1) the application for amendments dated May 6, 1982, (2) Amendment Nos. 89 and 83 to License Nos. DPR-31 and DPR-41, and (3) the Comission's related Safety Evaluation.

All of these items are available for public inspection at the Commission's Public Document Room,1717 H Street, N.W., Washington, D.C. and at the Enviromental and Urban Affairs Library, Florida International University, Miami, Florida 33199. A copy of items (2) and (3) may be obtained upon request addressed to the U. S. Nuclear Regulatory Comission. Washington, D.C.

20555, Attention: Director, Division of Licensing.

Dated at Bethesda, Maryland, this 4th day of November,1982.

F0lt ,THE NUC {AR REGULATORY COMMISSION 3

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f h VNgh,Ch Operating Reactors r nch #1 Division of Licensing I

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