L-80-418, Forwards Description of Cases Where Plans & Schedules Do Not Coincide w/post-TMI Requirements of NUREG-0737
| ML17209A492 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/23/1980 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 L-80-418, NUDOCS 8012300216 | |
| Download: ML17209A492 (13) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDE) i ACCESSION NBR ~ 80 123002'16 DOC ~ DATE! 80/12/23 NOT
<<IZED YES FACIL,:50 335 St+ Lucie Plant< Unit 1g Florida Power 8 Light'oB AUTH ~ NAME AUTHOR AFFILIATION UHRIGER ~ E, F 1 or i de Power f Light Co.
RECIP ~ NAME.
RECIPIENT AFFILIATION EISENHUTiD.G, Division of Licensing.
DOCKET 05000335'UBJECT
. Forwards descriiption of cases where) plans 8 schedules do not coincideI w/post-TMI requ)reeents of NUREG 0737 '
DISTRIBUTION CODE:
AOOIS, COPIES RECEIVEDILTR. ~NCL SIZEi Q'ITLE:
General Distribution for, after Issuance" of Operating License NOTES!
RECIPIENT" ID CODE/NAME" ACTION; CLARKp R ~
00 INTERNALS D/DIRPHUM FAC08 IS,E 06 11 REG FILE'1 COPIES LTTR ENCL" 13 13 1
1 2
2 1
0 1
1 RECIPIENT ID CODE/NAME DIRg DIV OF LIC NRC PDR 02'R ASSESS BR 10 COPIES LTTR ENCL'XTERNAl!
16 16 1
1 LPDR 03 JAN 5 1981 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 39 ENCL 37
E II
~
~
El h ~
y
/I I
~
P EI E,i+
/',C W LEE J
g I
g 1
@s)le
-N JthiwAW FLORIOA POWER 5 LIGHTCOMPANY December 23, 1980 L-80-418 Office of Nuclear Reactor Regulation Attention:
Mr.
D.
G. Eisenhut, Director Division of Licensing U.
S.
Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Eisenhut:
Re:
St. Lucie Unit I Docket No. 50-335 Post-TMI R~euirements We have reviewed your letter of October 31, 1980 which transmitted NUREG-0737.
Based on that review,'e have found a few cases where our plans and schedules do not coincide with those in Enclosure 1.
A description of these cases and the bases for our plans and schedules are attached.
We are working towards meeti ng all of the remainder of the requirements within the required dates, and will advise you should problems arise in meeting any of the long-term dates.
We are also available to meet with you to discuss our plans and status regarding NUREG-0737 implementation.
Very truly yours, obert E. Uhrig Vice President Advanced Systems 8 Technology JEM/pah Attachment cc:
J.
P. O'Reilly, Region II Harold F. Reis, Esquire Pool
~h 0 y @309 g/&
PEOPLE... SERVING PEOPLE
h 4I
STATE OF FLORXDA
}
)
COUNTY OF DADE
)
Sso Robert E. Uhrig, being first duly sworn, deposes and says:
That, he is a Uice President of Florida Power a Light, Company, the Licensee herein; That he has executed the foreg'oing document; that the state-ments made in this said document are true and correct to the best of his knowledge, information, and, belief, and that he is authorized to execute the document.
on behalf of said Licensee.
Robert E. Uhri Subscribed and. sworn to before me 'this day of NOTARY PUBLIC, in and for the county of Dade, State of Florida NOTARY PUBUC STATS OF F'RiOA 't u<RP AY COhM!SSiOH KXPiSSS AUHlST 21<
Vml Ny commission expires:
soNoxo T'NRU '~MRo soNQ<NQ AQQBf
0
(
f f
/
l
ATTACHMENT Re:
St. Lucie Unit 1 Docket No. 50-335 NUREG-0737 TECHNICAL SPECIFICATIONS 2-A Proposed Technical Specification amendment has been submitted in response to an.NRC letter dated July 2.
1980 (implementation of TMI Lessons Learned Category A items).
These changes have been discussed with the NRC and a final version is being prepared.
We understand that additional model Technical Specifications are being developed by the NRC Staff, and that they will be issued after issuance of the final TMI Action Plan requirements package.
We will consider proposing additional Technical Specification amendments following receipt and review of the final requi rements package.
SHIFT MANNING I.A.1.3 3.
4.
We have implemented the overtime restrictions as described in the July 31.
1980 letter from D.
G. Eisenhut with the clarifications in NUREG-0737. for our SRO's and RO's.
It is our opinion that the overtime situation for other plant personnel involved in safety-related actions is sufficiently different such that we do not plan any additional overtime restrictions at this time.
Historically, overtime is concentrated during refueling shutdowns, major plant modifications.
and periods of major maintenance.
conditions which are excluded from overtime restictions by NUREG 0737.
In addition, in many cases we have limited numbers of people specializing in maintaining a
complex piece of equipment, and our previous operating history shows that occasional overtime extending beyond the new NRC limits is effective and does not impair safe operations.
TRAINING PROGRAM I.A.2.3 We will submit a description of our training program and how we plan to meet this requirement by January 1,
1981.
ACCIDENT REANALYSIS I.C.1 We are pursuing resolution of these requirements through the C-E Owners Group.
The new guidelines are currently scheduled to be submitted to the NRC by June 1, 1981.
OPERATION VERIFICATION PROCEDURE
( I.C. 6)
This new requirement involves interfacing activity between both our nuclear plants.
As a consequence.
we believe full implementation of this requi rement will not be achievable until 2/1/81.
V SI
~ V v
~
~
~
/,
V
~
V V
V
6.
REACTOR COOLANT SYSTEM VENTS II. B.1 We plan to provide the design description of the RCS Vent System as required by NUREG-0737.
- However, we will postpone development of operating procedures until such time that the design is approved.
Procedures for operation will then be developed and submitted.
7.
TRAINING FOR MITIGATING CORE DAMAGE II.B.4 We are pursuing this requi rement through the C-E Owners Group.
Materials for developing a traini ng program will be available at the end of March, 1981 at the earliest.
8.
SAFETY/RELIEF VALVE TESTING II.D.1)
"As a sponsor of the EPRI PWR Safety and Relief Valve Test Program, FPL intends to comply with the requi rements of NUREG 0578, Item 2. 1. 2.
By letter dated December 15,
- 1980, R.
C.
Youngdahl of Consumers Power Company has provided the current PWR Utilities'ositions on NUREG 0737, Item II.D.1 clarifications.
Briefly those positions are:
A. Safety and Relief Valves and Piping-the EPRI "Program Plan for Performance Testing of PWR Safety and Relief Valves", Revision 1, dated July 1,
- 1980, does provide a program that satisfies the NRC requirements.
Discussion with the NRC staff and their consultants are resolving specified detailed issues.
B. Block Valves - The EPRI Program has not formally included the testing of block valves.
- However, a small numer of block valves have been tested at the Marshall Steam Station Test Facility.
The PWR Utilities and EPRI can not provide a detailed block valve test program until results of the Wyle and CE relief valve tests are available.
Therefore, a block valve test program will not be provided before July, 1981.
The PWR Utilities and EPRI believe that the proper operation of the TMI-2, and Crystal River block valves and other operational experience, plus knowledge of the marshall tests, support a less hurried and more rational approach to block valve testing.
C.
ATWS Testing -
PWR Utilities will not support additional efforts for ATWS valve testing until regulatory issues are resolved.
The major safety and relief valve test facility (CE) is nearing completion and some measures were taken to provide additional test capability beyond the current program requirements.
The NRC shold recognize that results from the current program are likely to provide most of the information necessary to address ATWS events (i.e.
relief capability at high pressures)."
9.
VALVE POSITION INDICATION I I.D.3 The equipment required to provide valve position indication is currently installed and operational.
Our vendor is currently performing final environmental qualification tests which are scheduled for completion by December.
1980 and a report will be transmitted as soon as practical.
The -
I C
t
10.
equipment has been qualified seismically, radiologically and meets both functional and thermal aging requirements.
AWF SYSTEM EVALUATION II.E.1.1 The analyses required to document the design bases system flow requirements for the AFW (Item 3) are underway by our NSSS vendor and will be supplied upon completion.
AFW INITIATION 8 FLOW I I - E. 1-2 12.
13.
Equipment procurement and the design effort necessary for this modification has progressed such that we could meet the 7/1/81 implementation date for safety grade equipment.
However, to ensure safe plant operation and to allow complete testing, installation will be postponed until our next refueling outage in October, 1981.
CONTAINMENT ISOLATION DEPENDABILITY II.E.4.2)
We are evaluating the requirement for lowering the containment pressure setpoint for containment isolation.
- However, pending additional evaluation, we cannot concur. with the clarification statement that 1 psi above normal operation pressure. is an appropriate or necessary minimum pressure setpoint which will also preclude the spurious activation of containment isolation.
Due to the implications of making a change in this
- setpoint, our evaluation will not be complete until 7/1/81, and modifications, if any, will be performed by 1/1/82.
INSTRUMENTATION FOR INADE UATE CORE COOLING II.F.2) 14.
We will reschedule our upgrading commitment described in L-80-13, dated April 3, 1980 from January 1.
1981 to October 1981, the date of the next refueling outage-The equipment necessary to meet these commitments is available, but installation requires a plant shutdown.
We also plan to take the opportunity of the next outage to enhance the system at the same time beyond the NRC requirements by making additional alterations to the system which will provide completely redundant indication.
Performing both modifications simultaneously removes the possibility of redoi ng work already completed.
In addition we are participating in the C-E Owner's Group effort in evaluating reactor-water-level indication as a part of our evaluation of ICC.
A detailed description of our plans for ICC will be forthcoming upon the completion of that effort.
AUTO TRIP OF RCPS II.K.3.5 We are participating in the C-E Owner's group effort in evaluating LOFT test results regarding this issue.
Our submittal is dependent on the completion of this effort.
h tl' i
tl W
II
'i I',
II
~,
l II f ~
~
l f
15.
SMALL BREAK LOCA'NALYS IS II-K.3. 30 Florida Power 8 Light Company is participating in the C-E Owners Group to sponsor preparation of prediction of LOFT Test L3-6.
Documentation of the C-E Owners Group's plans for such prediction and response to related NRC requirements is provided in a letter dated July 31.
1980 from G.
E.
Liebler, C-E Owners Group, to P.S-
- Check, NRC (Test Analysis of LOFT Small Break Test L3-6).
Because of the importance of these tests in the evaluation of the adequacy of present small-break LOCA models, we feel that it is inappropriate to consider further model documentation or changes until completion of the NRC review of these test predictions.
Therefore, we will continue to participate as a member of the C-E Owners Group to support preparation of the predictions of the LOFT Test L3-6.
16.
EMERGENCY PREPAREDNESS III.A.2 The Florida Radiological Emergency Plan for Nuclear Power Facilities includes (or wi'll include) the Dade, Monroe, Martin and St.
Lucie County radiological emergency plans.
Since these plans are not completed, certain aspects of the Plan which will be submitted by FPL by January 1,
- 1981, must be considered subject to revision prior to the scheduled implementation date of April 1, 1981.
We are currently investigating various alternatives concerning this issue and following canpl etion of the investigation we will consult with local governmental officials to determine future action.