L-79-329, Forwards Supplemental Response to Re NUREG-0578 short-term Requirements.Implementation Schedules for Many Requirements Improved
| ML17339A314 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/21/1979 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| L-79-329, NUDOCS 7911260328 | |
| Download: ML17339A314 (24) | |
Text
REGULATORY INFOHHATION DISTRIBUTION SYSTEH (RIOS)
ACCESSION iNBR; 7911260328 JOG
~ DATE: 79/11/21 NOTARI: NO FACIL: ~0 Tur key Point Planti Unit 3r Florida Power and Light C
0 251 urkey Point Plant>
Uni t 4F Florida Power and Light C
AUT AUTHOR AFF ILIATION UHRIGF ll ~ E ~
F l oride Power 8 Light Co, REC IP ~ NAHE HEC IP IEN T AFF ILI A T IOiV EISENHUTiD ~ G ~
Division of Operating Reactors
SUBJECT:
Forwaras supplemental response to 790913 ltr re NUREG 0578 short term requirements, Implementation schedu)es for many requirements improved.
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PLORIDA POWER h LIGHT COW'IPANY iso'i+aber 21, 1979 L-79-329 Office of Nuclear Reactor Regulation Attention:
IL-.. Darrell G. Eisenhut, Acting Direc==r Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear iver. Eisenhut:
Re:
Turkey Point Units 3
4 Docket Nos.
50-250 6 50-251 NUREG-0578 Short Term Re uirements Pursuant to T1r. Denton's letter of October 30, 1979 and subsequent telephone conversations with members of the NRC Staff, Florida Power 6 Light Company has re-evaluated its response to :our letter dated September 13, 19!9.
Based on the foregoing and
.; ving additional time available in the interim to more clea"1: define schedules regarding the purchase and installation of ha dware nece sary to meet the requirements of NUREG-0578, FPGL has supplemented its response to your September 13th lette".
Our supplementary response is attached to this letter, wh'. is also intended to serve as a response to Hr. Denton's lette".
Very truly yours,
( Q Q~vc,-j Robert E. Uhrig Vice President Advanced Systems 6 Technology REU/D.'-:a/cph Attacn.-.,e-.. s cc:
Yi=..Ta";:es P.
O'Re 'ly, Region II 7911260 3+5'EOP'...
5ER'iii~IG?
PL-
ATTACHt1ENT 1 Re:
Turkey Point Units 3 8 4 Docket Nos.
50-250 5 50-251 NOREG-0578 Short Term Re uirements As described below, the implementation schedules for many of the NUREG-0578 short term requirements have.been improved in comparison with the schedules initially presented in our letter dated October 22, 1979 (L-79-. 293)-
Nherever
- possible, scheduled plans have been advanced.
Please understand that the schedules herein represent our best estimate of the earliest possible implementation dates, given the constraints of manufacturers'bility to meet delivery schedules, limited manpower resources throughout the industry, and system load requirements relative to the operation of three nuclear units on the Florida Power 5 Light, Company (FPL) grid-Procurement and manpower constraints (as explained in greater detail in ) prevent implementation of a few of the NUREG-0578 short-term requirements until after January 1,
1980 (January-February ime frame).
Since 1977, the FPL systemwide winter demand peaks have approache" and sometimes exceeded the summer demand peaks.
Given the certainty of a major winter peak, r
it is unavoidable that the short-term NUREG-0578 modification schedule be closely coordinated with the overall FPL load management projections for 1980.
Corsideration of procurement and manpower exclusive of load management would not accurately represent the situation that must be considered relative to installation of the HUREG items.
For proper assessment FPL must consider all three items and their overall effect on FPL customers and the Florida
economy given the simultaneous shutdown of three nuclear plants (Turkey Point Units 3 8 4, and St. Lucie Unit 1) during January and February.
Turkey Point Unit 3 is scheduled to refuel during the period December 2, 1979 to February 1, 1980-FPL load management projections of total system capability and South Florida area capability show that outages of Turkey Point Unit 4 and/or St.'ucie Unit 1 in addition to Turkey Point Unit 3 would cause serious deficiencies in our ability to generate the expected winter loads.
For example, if St. Lucie Unit 1 is removed from service concurrent with Turkey Point Unit 3, there will be a projected systemwide deficiency of 489 the and a South Florida area deficiency of 90 the (the South Fl,orida deficiency is significant from the standpoint of system stability).
If both St. Lucie Unit 1 and Turkey Point'Unit 4 are removed from service concurrent witn,Turkey Point Unit 3, there will be a projected systemwide deficiency of 1185 Hw and a
South Florida area deficiency of 786 fbi.
In accordance with standard operating practices mandated by the National Energy Reliabili'y Council, a
"single contingency alowarce"'has been factored into (1) th= sys emwide projections to allow for the loss of the next largest unit and (2) the South Florida projections to allow for the loss of the Andytoim-Orang River 500 kV transmis
'on line.
It should be noted that these figures also assume peaking of all ro".mally available gas turbines.
The shor-.falls in generation caused by concurrent HUREG-0578 shutdowns would lead to selective, rotating outages within the FPL service area.
ile believe that this can be justifiably avoided by maintaining the current p'i:
i 9-outage schedules for St-Lucie Unit 1 and Turkey Point Unit 4,'ince our improved
modification schedule shows that almost all NURFG-0578 short-term requirements requiring a plant shutdown can be met by January 1, 1980.
The only items of.
this type for which we cannot fully meet the short-term date involve direct indication of valve position (2.1.3.a),
and subcooling meters (2.1.3.b).
Furthermore, the interim operation period beyond the critical January-February period would be minimal because St. Lucie Unit 1 is scheduled for a refueling outage beginning March 30, 1980 and a Turkey Point Unit 4 outage is tentatively scheduled for late April, 1980.
Concurrent or overlapping outages during the Spring are acceptable from a load management standpoint.
Finally, if any unscheduled outages of sufficient duration were to occur during the interim period, we would use that time to work on uncompleted items that required plant shutdown, given the availability on-site of necessary material.
ATTACHMENT 2 Re:
Turkey Point Units 3 8 4 Docket Nos.
50-250 8 50-251 NUREG-0578 Short Term Re uirements 2-1.3.a Direct.Indication of Valve Position The Turkey Point Units 3 and 4 primary system relief and safety valves will be provided with direct position or flow indication devices that meet the functional requirements of iAUREG-0578,'tem
- 2. 1.3.a.
Action has been initiated to implement this requirement:
(1)
Purchase orders have been placed for the ne essary material and equipment.
(2)
Completion of the engineering design by our Architect/Engineer (A/E) is p"armed for December 14, 1979.
(3)
Equipment delivery at the plant, based on the manufacturer's promise
+o deliver, is scheduled to be completed by December 28, 1979.
(4)
Complete implementation of this requirement is planned for Unit 3 during the refueling outage scheduled to begin about December 2, 1979.
(5)
Complete Unit 4 implementation of this req -:"ment is scheduled for approximately April 1980, bas c on justification provided in Attachment l.
- 2. 1-'3-b Instrumentation for Inade uate Core Cooling Subcooling meters will be installed in the Turkey Point Units 3 and 4 Control Room.
The meters will continuously display the margin to saturation in terms of either temperature or pressure through the use of a selector switch.
Action has been initiated to implement this requirement:
(1)
A vendor has been selected and advised of our decision to purchase subcooling meters.
(2)
Some of the required material is available at the plant site.
{3}
Purcnase orders have been placed for the remainder of the necessary material and equipment.
(4)
The engineering design by our A/E is scheduled for completion by December 28, 1979.
(5)
Equipment delivery at the plant is scheduled to be completed by January 1, 1980.
This is the best available delivery date based on negotiation with the manufacturer o
the subcooling meter.
(6)
Complete implementation of this requirement for Unit 3 is scheduled for February 22, 1980, based on a required
, installation time (to pull cable and connect equipment) of approximately 4 weeks.
This date extends beyond the refueling outage as currently scheduled and represents the only short-term requirement requiring plant shutdown that could presently cause an implementation problem for Unit 3.",l(e will make every effort to advance the schedule so that it falls within the refueling outage.
(7)
Complete Unit 4 implementation of this requir:~. ent is scheduled for approximately April 1980, based on justification provided in Attachment 1.
2-1-5-a Dedicated H
Control Penetrations Turkey Point Units 3 and 4 have redundant purge ccnnections which are indeoendent of he large containment penetrations.
- However, we have rot concluded our engineering review to determine if the design criteria specified in HUREG-0578, item 2. 1. 5.a are met.
This review will be completed and FPL will provide a plan description which meets the intent of the NUREG-0578 requirements by January 1, 1980.
Completion of any required modification is planned by January 1,
r 1981.
2.1.6.a S stems Inte rit for Hi h Radioactivit A program is being developed to reduce leakage from systems'outside containment that could contain highly radioactive fluids during a'erious transient or accident.
The appropriate systems have been identified and procedures are being prepared for approval, which will implement the leak reduction program.
The program for systems containing liquids will include visual inspection of systems.
under
- pressure, pressure decay techniques currently used for local leak rate testing, and measurement of makeup rate to a system while maintaining a constant system pressure.
For systems containing
- gases, the short term program will include bubble testing, pressure decay techniques, and radioisotopic detection techniques-Implementation of the program o'n Unit 4 is planned or January 1, 1980.
Unit 3 will be in refueling shutdown during December,
- 1979, and January 1980; therefore, the program is planned for implementation in conjunction with other'outage work,.with planned completion prior to unit startup.
2.1.6.b Plant Shieldin Review The A/E is performing the required design review as follows:
(1)
The PAID's and piping drawings for the systems expected to operate during post accident recovery have be'en marked-up.
The following areas are being reviewed for personnel access:
A.
Main Control Room B.
Component Cooling Pump Room C.
Passageways in the Auxiliary Building D.
Pipe. and Valve Room E.
Boric Acid Batching Room F.
Sample Room G.
Charging Pump Room H.
Area between Auxiliary Building and Refueling llater Storage Tank (3)
The shield ng review for systems normally required for post accident operation will be complete by January 1, 1980.
The systems in this phase are:
A.
Containment Sump Recirculation Line
B.
Low Head Safety Injection C.
High Head Safety Injection D.
Sampling System (4)
The systems not previously considered to operate after an accident will require a more extensive study and the review will not be complete until April, 1980.
The reason for the longer schedule is partially the result of a lack of clarity in NUREG 0578 as to which systems are to be considered.'irst, a clear definition of systems or portions of systems required will be developed.
This in-depth review may show
- that, due to corrective actions initiated in response to other NUREG 0578 items, some of the systems under current consideration may not require operation-Next, specific radiation source terms must be developed for modeling of these systems.
(5)
After development of specific system source terms, radiation doses may then be calculated.
The last step in the review is to develop a realistic approach to any shielding problems that
may arise.
Many of these systems were never considered to carry highly contaminated fluids and may not lend themselves to shielding.
Thus, there is a need for a realistic approach to this problem.
(6)
For the above technical
- reasons, combined with manpower resource limits, the shielding review for systems not previously considered to operate after an accident cannot be completed until April, 1980.
(7)
Any additional shielding that may be needed as a result of the shielding review will be installed on a schedule that cannot be developed until completion of the review.
Me do not have sufficient information at this time to make a firm schedular commitment,
- however, we intend to make every reasonable effort to meet the January 1,
1981 date.
2.1.7.a Automatic Initiation of Auxiliar Feed (1)
As stated in our responses dated April 24, 1979 and June 18, 1979 to IE Bulletin 79-06A, the auxiliary feedwater system is automatically initiated, however, the feedwater regulator valves are modulated by operator action from the control room to maintain steam generator level.
Normal practice and established procedures dictate that an operator (as a primary and essential function) monitor and maintain steam generator level(s) duri ng transients or accidents.
The operator
assigned to maintain steam generator level(s) does not have any other concurrent dutie's during an accident or transient until after the steam generator level(s) are stabilized.
(2)
In order to provide fully automatic flow initiation, the auxiliary feedwater control valves will be automatically opened to a predetermined position after a short time delay sufficient to enable the turbine driven auxiliary feed pump to attain full speed.
(3)
Design of the modification will proceed upon satisfactory completion of the analyses.
A control grade design is scheduled for completion by January 11, 1980-(4)
Given the availability of off-the-shelf control grade components, delivery at the plant site is planned for January 11, 1980.
(5)
Implementation of the control grade modification can be completed by February 15, 1980 for both Units 3 and 4 since plant shutdown is not required.
(6)
The automatic time delayed opening of the auxiliary feedwater system discharge
- valves, meeting safety grade requireme~ts, will be implemented by January 1, 1981.
2.1.7.b Auxiliar Feed Flow Indication (1)
Control grade indication will be provided by installing a
back-up nitrogen supply system to augment the existing pneumatic instrument loops on the steam generators.
(2)
The control grade design modification is sch'eduled for completion by December 7, 1979.
(3)
Implementation of the control grade modification will be completed by January 1,
1980 for both Units 3 and 4 since plant shutdown is not required.
(4)
Implementation of the safety grade system is scheduled for completion by January 1, 1981.
2.1.8.a Post Accident Sam ling (1)
A generic design for automatic sampling and analysis, including the additional shielding, can be completed by our A/E by January 1, 1980.
We anticipate the need for a major modification.
(2)
Since development of procedures and plant modifications logically follow the design review, they are scheduled to begin approximately January 1,
1980.
0 (3)
We will make every reasonable effort to meet the January 1,
1981 modification date.
- 2. 1.8.b High Range Radiation Monitors FPL is procedding with the design and procurement of high range in-containment radiation monitoring instrumentation and effluent monitoring instrumentation, but we do not have sufficient information at this time to make a firm commitment regarding scheduled implementation of these modifications.
Since Unit 3 is scheduled for a routine refueling outage during the Spring of 1981, we intend to make every reasonable effort to implement the Unit 3 modifications at that time.
Unit 4 is tentatively scheduled for steam generator replacement beginning in the Fall of 1980 and extendi ng into the Summer of 1981, which would accommodate the Unit 4 instrumentation modifications.
- However, steam generator replacement could be deferred until a later date, in which case a revised instrumentation modification schedule would have to be developed for Unit 4.
Since the January 1, 1980, procedural requirements related to the monitoring of noble gases, radioiodi ne, and particulate effluents was not contained in HUREG-0578, we are just beginning our effort to comply.
Given the short time frame and our short-term manpower limits, we can only approximate an April 1, 1980, completion date.
We will make every reasonable effort to advance that date as much as possible.
10
2.1.8.c Im roved In-Pl ant Iodine Instrumentation Based on the best available equipment procurement
- schedule, we can have a permanent installation by June of 1980.
Associated training and procedures are being developed in parallel with procurement to the greatest practicable
- degree, however, they could not be finalized until approximately two months beyond the installation date (August, 1980).
If required during the interim period, we can draw air samples through a charcoal filter, purge the noble gases bypassing air over the charcoal, and analyzing for Iodine on a GeLi detector.
- 2. 1.9 Anal sis of Desi n
& Off-Normal Transients
& Accidents (1)
Transient and Accident Analysis:
No change from initial response.
(2)'ontainment Pressure Monitor:
(3)
Containment Mater Level Honitor:
(4)
Containment Hydrogen Monitor:
Items 2, 3, and 4 are being engineered by our A/E and our preliminary planning (assuming no equipment procurement prob'ferns) is for
installation by approximately April-Nay, 1981 for Unit 3 and during the 1980-1981 steam generator replacement for Unit 4.
If the steam
~
generator replacement is deferred, a revised schedule will be devel oped-(5)
RCS Venting:
The engineering design by our-A/E is scheduled for completion by December 21, 1979.
Since the details involving analysis, procurement, and installation remain to be resolved, we are unable to make a firm schedular commitment at this time.
Since Unit 3 is scheduled for a routine refueling outage duri ng the Spring of 1981, we intend to make every reasonable effort to,implement the Unit 3 modifications at that time.
Unit 4 is tentatively scheduled for steam generator replacement beginning in the Fall of 1989 and extending into the Summer of 1981, which would, accommodate the Unit 4 instrumentation modifications.
- However, steam generator replacement could be deferred until a later date, in which case a revised instrumentation modification schedule would have to be developed for Unit 4.
2.2.1.b Shift Technical Advisor The primary function of the Shift Technical Advisor (STA) will be one of assessment and diagnosis during accidents or abnormal transients.
He may be assigned other collateral duties that will not 12
interfere with his primary function. 'raining of technical advisors is scheduled to be completed by January 1, 1981, contingent on the availability of simulator training time.
FPL believes that the STA responsibility can be approp'riately discharged over the short term by utilizing an "on call" system as described in our original response.
Over the long term, FPL believes that upgrading of the shift supervisor responsibility to include the STA function is the best alternative.
Nevertheless FPL is endeavoring to establish an on-shift,technical, advisor program by January 1, 1980.
Establishing the on-shift technical advisor will require additional staff at the plant.
In this regard we are actively recruiting candidates from outside the company and screening in-house personnel.
If all STA positions are not filled by January 1, 1980, personnel from various corporate departments will be assigned to this position during the interim until all STA positions are formally filled.
Operational experience evaluation and assessment'ay be performed by the technical advisor or other functional organizations either on-site or at FPL's General Office.
At such time that the man-machine interface is improved as a result of such activities as improved control room design and/or operator qualification, FPL may elect to designate a qualified member of the operating shift to perform the accident/transient function.
13
2.2.2.b Onsite Technical Su ort Center (1)
The Instrument 8 Control Building will be used to house the Technical Support Center (TSC) by January 1, 1980.
(2)
Design details to upgrade the TSC to meet all requirements will be provided by our A/E as soon as possible in an effort to meet the January 1,
1981 implementation date.
14