L-82-168, Forwards List of Engineering & Const Items Not Expected to Be Complete at Core Load,Consisting of NUREG-0737,Items I.D.2,II.B.1,II.B.2,II.B.3,II.E.1.2 & II.F.1 & FSAR Items. List Includes Justification for Operation Until Completion

Forwards List of Engineering & Const Items Not Expected to Be Complete at Core Load,Consisting of NUREG-0737,Items I.D.2,II.B.1,II.B.2,II.B.3,II.E.1.2 & II.F.1 & FSAR Items. List Includes Justification for Operation Until Completion

ML17273A064
Person / Time
Site:	Saint Lucie
Issue date:	05/04/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.2, TASK-2.B.1, TASK-2.B.2, TASK-2.B.3, TASK-2.E.1.2, TASK-2.F.1, TASK-TM L-82-168, NUDOCS 8205070294
Download: ML17273A064 (20)

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'REGULATO INFORMATION DISI'RIBUTION STEM ORIDS)

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"ACCESSION hJBR:8205070294

.DOG ADA'TE; "82/05It'04 NOTARI'ZEDt"'NO FAGIL:50 389 "St. Lucie Plantr,.Unilt 2E.'Florida IPower 8 Light Co ~

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'AUTHOR AFFILIATION UHRIGr R ~ E ~

Florida 'Power,8,'Li'ght 'Co.

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'RECIPIENT AFFILIATION EI'SENHUT<D;G ~

Di.vision of Licensin'9

SUBJECT:

For wards list of.engineering 8, const, i~tems not expected

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FLORIDAPOWER 5 LIGHTCOMPANY May 4, 1982 L-82-168 Office of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Mr. Eisenhut:

Re:

St.>>.Lucie Unit 82 Docket No. 50-389 Outstandin Work Items REJIG}f MAYS 1S8gc neer em~

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'b Attached please find a list of all engineering and construction items that are not expected to be complete at core load.

This list has been reviewed in detail by our engineering and construction departments and it represents every item that is scheduled to be completed after initial operation.

Florida Power im Light Company has included in this listing the reasons that we feel plant operation is justified prior to comple-tion of these work items.

We are submitting this for your review and comment.

Very truly yours, Robert E. Uhrig Vice President Advanced Systems 8 Technology REU/RAK/ga Attachment cc:

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Attachment to L-82-168 Page 1 of 8 The following items will.not be complete by Core Load.

Each item will include a short description, the reason that it is not complete, the schedule for completion and the justification for operation until it is complete.

A.

NUREG 0737 ITEMS I.D.2 Safet Parameter Dis la S stem aO b.

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This system displays information to the control room operator to assist him in diagnosing problems in the reactor plant.

Due to excessive demand on the electrical construction trades this system will not be completed by Core Load.

Portions of the system, component installation and cable routing, may be performed during plant operation.

System tie-in willrequire plant shutdown.

A majority of this system will be installed by Core Load but the complete installation will not be finished until first refueling.

This assumes some period of reactor shutdown to allow hookup.

Testing can be performed during plant operation.

Operation of the reactor prior to system completion is justified for two reasons.

First, the safety parameter display system does not provide any safety action, it simply displays information to the control room operator and therefore its vacancy does not compromise any engineered safety system function.

Second, the information that is displayed is entirely redundant to the display systems that are built into the existing control room panels.

II.B.1 Reactor Coolant Gas Vent S stem ao b.

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This system allows venting of the reactor vessel head and the pressurizer steam space in the event of abnormal gas buildup in these locations.

The only portion of this system that will not be complete by Core Load is the electrical hookup to the control room.

This portion is being delayed because of the extensive demand on the electrical construction trades to complete all systems that are absolutely essential for Core Load. All piping and valve installation willbe complete by Core Load and all work inside the reactor containment building will be complete by Core Load.

The only remaining activities after Core Load will be the electrical hookup in the reactor auxiliary building.

This system willbe fullyoperational prior to operations above 5% power.

Operation of the reactor prior to system completion is justified for the following reasons.

The system will be in operation very shortly after Core Load and prior to any high power operation of the plant.

The potential for hydrogen generation in the core is extremely remote considering the limited core power history prior to exceeding 5% power and the negligible decay heat.

II.B.2 Plant Shieldin (Motor 0 crated Valves) ao This requires design and installation of sufficient shielding to allow operation of emergency systems following an accident that releases significant amounts of radioactive material to the reactor coolant.

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Attachment to L-82-168 Page 2 of 8 Allportions of this requirement willbe complete by Core Load except for electrical raceway work and the installation of motor operators on four valves.

These motor operators will allow remote manual operation of four valves in the auxiliary building that could be in a radiation area following an accident.

These motor operators will not be complete because of extensive demand on electrical construction trades that are required to complete all systems essential for Core Load.

This requirement will be completed 8 months after Core Load.

The remainder of this work can be completed during plant operation without causing undue interference with operating routine.

The lack of motor operators on these valves does not preclude manual operation as needed in an emergency.

In the unlikely event of an accident, manual operation of these valves can be accomplished with some personnel exposure.

Since the accident is unlikely, the associated personnel exposure is also a reasonably low probability occurence and operation for the short time until installation is complete can be justified.

h II.B.2 Plant Shieldin (ECCS Area Sum Pum back S stem) ao b.

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This system allows pumping of the ECCS sumps to the containment building.

This system would serve to remove radioactive leakage that may accumulate in the auxiliary building ECCS sumps following an accident and transport to the reactor building where it is isolated and contained.

All of piping and valves for this system will be installed by Core Load.

Local manual operation of these valves is possible until they are electrically connected to permit remote operation.

As described

above, the critical demand on electrical construction trades has necessitated that systems of higher priority be completed ahead of this system.

This system will be completed and tested for remote operation before proceeding above 5% power.

Operation of the plant below 5% power without this system is acceptable for the following reasons.

First, the system is capable of being operated locally and can serve its intended function at Core Load.

The reactor core fission product inventory will be very low prior to high power operation and this presents a small likelyhood for significant release of highly radioactive material.

II.B.3 Post Accident Sam lin S stem ao b.

Ce This system would allow low exposure sampling of radioactive coolant following an accident.

All hardware for this system is on site and undergoing installation but will be completely installed by Core Load.

Since this system serves as redundant sampling capability to the normal sampling system which is used for normal plant operation and can'erve in an emergency, craft trades are being utilized to complete the normal sampling system.'n addition, the relatively recent delivery of hardware has necessarily delayed the final hookup.

This system will be complete and operational 12 months after Core Load.

The system installation can proceed during reactor operation and does not require any plant shutdowns for completion.

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All sampling that can be performed on the post accident sampling system can also be performed using the normal sampling system.

Since sampling capability will always exist during operation, the short time period before this system is in operation is reasonable and justified.

It has been demonstrated that an accident sample can be obtained and analyzed using the existing system without exceeding NUREG 0737 radiation guidelines.

II.E.1.2 Automatic Initiation of Auxiliar Feedwater ao b.

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This system ensures that auxiliary feedwater system is automatically initiated when it is needed and therefore does not rely on operator action.

The auto initiation circuitry will be in place by Core Load.

The electrical tie-ins willnot'be,complete at Core Load because of the heavy demand on the electrical construction trades which is a critical trade for plant system completion.

The elecrical portion willbe the only portion of this item that willnot be complete.

This system will be completely installed and fully operational before exceeding 5% power.

Operation of the reactor up to 5% power without this system is justified for the following reasons.

The auxiliary feedwater pumps will be operating continuously to provide makeup to the steam generators while the plant is in a low power condition.

The main feed pumps are not used at low power conditions and therefore an emergency initiation of the auxiliary feedwater pumps willnot occur since these pumps willbe running.

II.F.I.D Radiation Monitors ao b.

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This requirement consists of high range radiation monitors for inside and outside containment.

These monitors would be capable of reading a much higher than normal level of radiation that could occur if an accident takes place that severely damages the reactor core.

These high range monitors willnot be 'electrically hooked up to support Core Load; however, the monitors themselves will'be physically installed.

The relatively recent engineering change and short procurement interval has not allowed sufficient time to fully incorporate these items into a reasonable construction schedule.

This fact combined with tight utilization of the electrical trades precludes completion by Core Load.

These monitors willbe fullywired in and tested 6 months after Core Load.

Reactor operation prior to final hookup is justified for the followingreasons.

The plant has, as a normal part of its radiation monitoring system, the ability to measure the radiation levels inside and outside containment.

The high range monitors are redundant to the existing instrumentation, although they have a higher range.

These monitors do not provide any signals to actuate any safety systems; they only provide information to the plant operators.

The safe operation of the plant is not in jeopardy if these monitors are not installed.

The time period between Core Load and monitor hookup is relatively short and therefore they are likely not to be required and portable monitors will be available.

In the event of an accident, the final hookup may be accelerated if needed since all components willbe in place.

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FSAR REVIEW Attachment to L-82-168 Page Oof 8 Low Flow Alarms on Safet In ection Pum s

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These alarms willalert the control room operator that the high pressure or low pressure safety injection pumps have inadequate flow through them to preclude pump damage.

This alarm system will not be complete by Core Load.

The agreement to install the system occured during the FSAR review by'the NRC staff.

This recent change in plant design has only provided a limited amount of time to engineer and procure this equipment.

This interval has riot provided enough time to complete these items.

These alarms will be completely installed and operational 12 months after Core Load.

These alarms provide no reactor safety function.

They will alert an operator of insufficient flow in the safety injection pumps which willoccur during periodic testing or inadvertant actuation when the recirculation line is mistakenly closed.

This alarm serves to alert an operator of impending pump degradation during non-accident conditions, its late installation will not degrade plant safety.

Waste Mana ement S stem Pum

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This engineering addition allows automatic cutout of the waste management transfer pumps before the refueling water storage tank overflows as it is being filled by these pumps.

This system is an electrical revision to the existing waste management pumping system and was only recently added as a result of the FSAR review.

There is no change to the piping and valves.

The change will not be complete because of higher priority items that are being installed by the electrical construction trades.

This system willbe complete 10 months after Core Load.

The system that will be complete at Core Load has a high level alarm in the refueling water tank that will alert the plant operator to secure the tank fill. The fillpump is only 50 gpm and willrequire a lengthly time between high level alarm and tank overflow.

The effects of a complete overflow of the tank, including a complete rupture, have been analyzed and shown to be well within allowable release limits. Reactor operation without this feature is justified for the above stated reasons.

Second Fuel Pool Heat Exchan er ao b.

This is a redundant heat exchanger for removal of decay heat in the spent fuel pool.

This heat exchanger will not be operational by Core Load.

The installation of this component was agreed upon during the FSAR review and therefore has not allowed sufficient time for procurement, installation and test.

The heat exchanger is actually in place but tie-in and test will not be complete by Core Load.

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Attachment to L-82-168 Page 5 of 8 This component willbe operational by first refueling.

The NRC staff in the SER has stated their concurrence with installation of this component, by first refueling.

This decision is justified because of the numerous other means of providing spent fuel cooling and because there willbe no spent fuel until the first refueling.

Concentrator Bottoms Tanks ao b.

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These tanks provide holdup for the liquid waste management system waste concentrator bottoms.

FPL's present waste management scheme does not necessitate the use "of the evaporators.

FPL has had good results on St. Lucie 1 using ion exchange for the processing of liquid waste and this allows shipment of dewatered resins as the end product of this management scheme.

As a result of this experienc, the waste concentrator evaporators willlikely not be used for some time into the future, if ever.

The bottoms tanks were added into the design late in the engineering phase; during the

'FSAR review.

This late addition has not allowed sufficient time to complete the design, procure the equipment and install it in the plant.

The waste concentrator bottoms tanks will be installed in the plant by first refueling.

The waste management scheme that FPL intends,to use has been discussed with the NRC staff and they have provided concurrence with the approach.

Recognizing that waste evaporators may be used in the distant future, FPL has agreed to install the bottoms tanks.

Operation of the plant prior to installatin of these tanks is justified because of the proven waste management program that will be implemented on St.

Lucie 2.

Since this program relies on ion exchange rather than concentration and solidification, the plant can be safely operated utilizing the equipment that willbe in place.

Ductilit Factor Regnal sis ao b.

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This item is a reanalysis of St. Lucie missile barriers assuming a more conservative ductility factor than what had been applied during the original design of the plant.

FPL has applied ductility factors in the plant structural analysis that were not as conservative as the NRC staff prefers.

As a result of the FSAR review,-FPL has agreed to reanalyze St. Lucie Plant utilizing the ductility factors that the NRC staff suggested.'"

This reanalysis is complete.

FPL has also agreed to modify any structures that could not be shown acceptable with the new analytical assumptions.

FPL expects that the engineering will be complete by Core Load but any modifications would follow Core Load.

All work that results from this engineering will be complete by first refueling.

Operation of the plant prior to completion of this work is justified for several reasons.

First, the only areas involved are the intake pump enclosure fan housing, the condensate storage tank vent hood enclosure and an RAB sliding door.

Since these areas are very limited and the existing design does utilize a conservative, although less conservative than agreed upon, ductility factor; operation does not constitute an unreasonable risk.

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Attachment to L-82-168 Page 6 of 8 Finally, since the design basis missile strike is itself a somewhat low probability occurence, the need for these structures to provide missile protection prior to first refueling is very unlikely.

Diesel Generator Lube Oil Modifications ao b.

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This item requires the modification of the diesel generator lube, oil system to provide a continuous supply of lube oil to the diesel generator bearings.

This willensure that the diesels have good bearing lubrication prior to any demand start.

The addition of this modification was agreed upon during the FSAR review.

FPL clearly agrees that this modification is acceptable and will enhance engine reliability.

The change is somewhat extensive and.

it willnot be complete by Core Load.

The complete lube oil modification willbe complete by first refueling.

Operation prior to this modification is justified for the following reason.

Diesel engine bearing wear is a function of engine operation and number of fast starts.

The proposed lube oil modification provides an improved method of ensuring engine bearings are lubricated prior to starting, it does not alter the normal method of lubrication during engine operation.

Since the number of demand starts during the first year of operation is expected to be limited and the engine bearings are essentially brand new at this time, the engine reliability during this period with new bearings will be acceptably high to allow the plant to operate safely.

This system is intended to improve the long term life of the engine bearings and therefore would have a limited effect on reliability at the beginning of plant operation.

Therefore, FPL feels that-plant operation prior to this modification is justified.

Diesel Generator Vibration of Instruments ao b.

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This item requires the removal of any instruments from the diesel generator skid to instrument racks that are not mounted directly to the engine.

In this way, the instruments would not be subjected to engine vibrations and thus would improve their reliability.

This item was agreed to during the FSAR review.

The late identification of this change and critical craft manloading for the electrical construction trades has precluded the completion of this item prior to Core Load.

This item willbe complete by first refueling.

The NRC staff has stated in the SER that they concur with an installation completion date by first refueling.

Plant operation without this item is justified because of the limited use of the emergency diesel generators before first refueling.

The existing installation is approved by the engine manufacturer and movement of the engine mounted instruments off the engine skid would serve to reduce vibratory damage that may occur over a long period of time.

Plant Sound Powered Communications This system provides plant communications in the event that all normal communications are not available.

This system willnot be complete at core load because of heavy demand on electrical construction trades.

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Attachment to L-82-168 Page 7 of 8 This system willbe complete before power ascension.

Operation without this system is justified because of the very short time period between Core Load and power ascension are very unlikely and the effects would be insignificant with very little core power history.

The use of this system prior to full p'ower operations is considered extremely remote.

Re ulator Guide 1.63 ao b.

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This item requires redundant protection of circuits that penetrate the containment from the effects of electrical short circuit.

The circuits must be protected in such a manner that the containment integrity will not be compromised following a short circuit with a single failure of any protective device.

This change to plant design was agreed to during the FSAR review with the NRC staff.

The late incorporation of this change, combined with procurement times and installation demands on the critical electrical construction trades has caused this item to extend beyond Core Load.

This change to the plant willbe complete by the first refueling.

The NRC staff has provided their concurrence with the first refueling completion date in the SER.

Operation of the plant without the completion of R.G.

1.63 circuit modifications is justified for the following reason.

The time period of reactor operation before the circuits are modified is short.

The probability of short circuit and failure of containment integrity, is reasonably low.

Since these circuits will be modified in this relatively short time period, operation of the plant prior to this modification does not pose an unreasonable risk to the plant safety.

Re ulator Guide 1.75 ao b.

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This item requires the modification of circuits connected to safety buses so that a single failure of a circuit isolation device willnot render the safety bus inoperable.

This plant change was agreed to during the FSAR review.

Because of this late engineering change and the extensive demand on electrical trades for implementation, this item will not be complete by Core Load.

Reg. Guide 1.75 willbe implemented by first refueling.

The NRC staff has concurred with the implementation date of this engineering change in the SER.

3ustification for operation without this change completed is for the following reason.

All safety buses in the plant are redundant, failure of one bus does not render the plant unsafe.

The safety buses are presently protected by at least one isolation device and this provides a high level of reliability because of the pedigree of these installed devices.

Failure of a piece of electrical equipment in a manner that could jeopardize a

bus is not a likely occurence.

The safety buses themselves are protected by isolation devices from impacting other buses; fault identification and repair could allow a rapid return of the bus to service.

FPL feels operation until first refueling with this change not completed poses little additional risk to plant safety.

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Re ulator Guide 1.97 Attachment to L-82-168 Page 8of 8 ao b.

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This item requires the instrumentation identified in R. G.

1.97 be included in the plant design.

This Regulatory Guide is a somewhat recent addition to the plant design requirements.

Final negotiations with the NRC staff are not complete and some engineering remains.

The implementation date of this Reg.

Guide follows the St. Lucie core load date.

This item willbe complete in accordance with the implementation date specified in Reg. Guide 1.97.

Operation of the plant is justified because most instrumentation required by this requirement is a part of the existing plant design and the remaining por tions will be complete by the required implementation date.

Securit S stems a.

The status of the physical security systems at St. Lucie 2 at Core Load willbe discussed in separate correspondence due to the sensitive nature of this information.

Fire Protection Some of the fire protection items will not be completed prior to Core Load because the design criteria were not developed until late 1981 and early 1982 in concert with the NRC.

Subsequently, the procurement and installation are delayed as well.

The items inside containment will be completed prior to Core Load and the installation of the remainder of the item's will be as expeditious as possible.

However, procurement has proceeded in most areas in parallel with discussions with the NRC.

In the interim, strict control of combustibles and a fire patrol will be used to minimize the possibility of fires.

In addition, smoke detectors will be installed.

Specific fire protection items which will not be in place at Core Load are addressed below.

1)

Post indicator and miscellaneous fire protection valves will be essentially complete at Core Load with the remainder completed prior to power ascension.

Except for the sprinkler systems which are not installed, the water supply system willbe operational at Core Load.

2)

Reactor Coolant Pump Lube Oil Collection System.

This item will be complete prior to power ascension because of the late delivery of hardware and the availability of construction craft manpower.

3)

The reactor auxiliary building sprinkler systems, some fire dampers and barriers.and some electrical cable rerouting will not be completed prior to power ascension.

The late completion of the

design, procurement and delivery caused a late start of construction.

However, construction will continue to complete the items as quickly as possible.

In exceptional cases completion willrequire a plant outage and therefore may not be completed until the first refueling.

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