L-84-239, Responds to 840814 Draft Safety Evaluation of Inadequate Core Cooling Instrumentation Sys,Per NUREG-0737,Item II.F.2.Addl Info,Implementation Milestones & Implementation Rept for Reactor Vessel Level Monitoring Sys Encl

Responds to 840814 Draft Safety Evaluation of Inadequate Core Cooling Instrumentation Sys,Per NUREG-0737,Item II.F.2.Addl Info,Implementation Milestones & Implementation Rept for Reactor Vessel Level Monitoring Sys Encl

ML17346A548
Person / Time
Site:	Turkey Point
Issue date:	09/20/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM L-84-239, NUDOCS 8409250200
Download: ML17346A548 (22)

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REGULATORY ii FORMATION DISTRIBUTION SY M (RIDS)

ACCESSION NBR;8409250200, DOC DATE! 84/09/20 NOTARIZED:

NO DOCKET' FACIL:50-250 Turkey Point.Plant~ 'Unit~ 3~ Flor.,ida 'Power and L'ight C

0500025(}

50-251 Turkey Point:Planti Unit 4~ Flor,ida Power and Light C

05000251 AUTH,NAME AUTHOR AFFILIATION'ILLIAMS'

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Flor ida Power L Light Co,

'RECIP., NAME RECIPIENT AFFILIATION VARGApS,AD Operating Reactors Branch 1

SUBJECT:

Responds t'o 840814 draft safety evaluation of inadequate cope coooling, instrumentwation sys~per.

NUREG~0737g Item; ILES 2,Addi infoiimplementation milestones~

8 implementation rept for reactor. vessel level manitoring sys encl'ISTRIBUT'ION CODE!

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OR Submi!ttal: Inadequate Core Cooling (Item II~ F ~ 2)

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X 14000, JUNO BEACH, FL 3340B FLORIDAPOWER 8( LIGHTCOMPANY L-84-239 September 20, 1984 Office of Nuclear Reactor Regulation Attention:

Mr. Steven A. Varga, Branch Chief Operating Reactors Branch No.

I Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Varga:

Re:

Turkey Point Units 3 & 4 Docket Nos. 50-250 and 50-25 I Inadequate Core Cooling Instrumentation (ICCI) System NUREG-0737 Item II.F.2 The enclosed information is submitted in response to your August l4, l984 letter which forwarded a draft Safety Evaluation for the Turkey Point Units 3 and 4 ICCI System.

Enclosure (I) includes a

response to the request for additional information regarding the ICCI System design.

Enclosure (2) includes the milestones for implementation of the ICCI System.

Enclosure (3) is the Implementation Report for the Reactor Vessel Level Monitoring System (RVLMS).

In providing Enclosure (3), Florida Power 8 Light Company requests NRC approval of the RVLMS installations for Turkey Point Units 3 and 4.

This information was discussed during the NRC ICCI System audit at the St. Lucie and Turkey Point sites on August 7 and 8, 1984.

Should you or your staff have any questions regarding this information, please contact us.

Very truly yours, J. W. Williams, Jr, Group Vice President Nuclear Energy JWW/TCG/cab cc:

J.'. O'Reilly, Region II Harold F. Reis, Esquire 8409250200 840920 PDR ADOCK 05000250

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.PDR goo PEOPLE... SERVING PEOPLE

0

ATTACHMENT2 TO ENCLOSURE (I)

INADEQUATECORE COOLING SYSTEM, ICCS)

PTP - UNITS 3 & 4 The following information updates our responses to NRC Generic Letter No. 82-28 submitted to the NRC on 3/IO/83 (L-83-I35):

I.

Item 3 (b) - Procurement schedule.

Allequipment has been delivered.

2.

Item 3 (c) - Installation schedule.

All equipment has been installed except the interconnecting cable from QSPOS to SAS.

The ICCS is in operation, however the qualification test reports for the Ml cable - connector,, have not been completed.

C.E. expects to have the Ml cable test completed by November 1984.

3.

Item 3 (d) - Test and Qualification Reports.

C.E. expects to have the Ml cable test completed by November l984.

All

'ther equipment qualification tests have been completed.

4.

Item 4 table I (I-b and I-c) - Status of Conformance of ICCS with NUREG-0737 II.F.2.

The ICCS has been completely installed and the old SMM has been removed.

5.

item 4 table I (2P,4, and 5) - Status of Conformance of the ICCS with NUREG-0737 II.F.2.

AlI documents. have been completed.

6.

Item 4 table I (6) - Status of Conformance of the ICCS with NUREG-0737 II.F2.

ICCS:installation has been completed.

ICCS test report has been completed except Ml cable test,.which, is scheduled by C.E. to be completed by November, I984.

. 7-Item 4 table I (7) - Status of Conformance of the ICCS with'NUREG-0737 II.F.2.

Guidelines for operability of the RVLMS have not yet been provided by Combustion Engineering.

0

8.'tem:4 table 2 (3) - Conformance with Appendix'B.of NUREG-0737.

ICCS willbe powered. from inverters as follows:

Unit Next I 985 Fall outage.

Unit 3 - l 986 outage.

.9.

Item 4 table 3 (7) -'Conformance with NUREG-0737 - CET Criteria Qualification, test report for cable - connectors will'e completed by November 1984.

0

ENCLOSURE (2)

MILESTONES FOR IMPLEMENTATIONOF INADEQUATECORE COOLING INSTRUMENTATION I. Submit final design description-(by licensee)

(complete the documentation requirements of NUREG-0737, Item II.F..2, including all plant-specific information items identified in applicable NRC evaluation reports for generic approved systems).

FPL provided design-and implementation details for the Turkey Point Units 3 and 4

ICCI Systems by letter dated March IO, I 983 (L-83-I35) and supplemented on April I 3, I 984 (L-84-l00) and June I 5, I 984 (L-84-I55).

2.

Approval of emergency operating procedure (EOP) technical guidelines (by

.NRC).

NOTE: This EOP technical guideline which incorporates the selected system must be based on the intended uses of that system as described in approved generic EOP technical. guidelines relevant to the selected system.

The Westinghouse Owners Group Emergency

Response

Guidelines, Rev. 0, were approved by the NRC with comments in an SER dated June I, I 983.

3.,Inventory Tracking Systems (ITS) installation complete (by licensee).

Unit 3 RVLMS installation was completed in December l983.

Unit 4 RVLMS installation was completed in May I984.

4.

ITS function-testing and calibration complete (by licensee).

Unit 3.RVLMS functional testing, and calibration was completed on December l6, 1983.

Unit 4 RVLMS functional testing and calibration was completed on May 25, l984.

5.

Prepare revisions to plant operating procedures and emergency procedures based on approved EOP guidelines (by licensee).

The existing plant'perating and emergency procedures will be revised to reflect the ICC System by November 30, l984 and implemented by December 2I, l984.

The revisions will be consistent with the technical content of the NRC approved Westinghouse Owners Group Emergency

Response

Guidelines.

Implementation, of plant specific emergency procedures based on the Westinghouse Owners Group Emergency

Response

Guidelines will occur by December 3I, l985 (FPL Letter. L-84-33 dated February l4, l984).

Ihis commitment was confirmed in an:NRC Order dated February 23, 1984.

0

6.

Implementation letter report to NRC (by licensee)

By submittal of this letter.

7. Perform:procedure walk-through to complete task analysis portion of ICCI system, design (by licensee).

The procedure walk-throughs to complete the task analysis portion of ICCI system design will be coordinated with the Task Analysis Upgrade'Program (DCRDR) and the development and implementation of the procedures based on the approved Emergency Response Guidelines (See Milestone 5).

8.

Turn on system for operation training and familiarization.

The RVLMS systems for Unit 3 and 4 have been in operation since completion of the functional tests.and calibration (See Milestone 3).

Between April 4, l983 and July l5, l983, training on the new QSPDS System was presented to all licensed operators in the requalification classes.

9.

Approval of plant-specific installation (by NRC)

Pending NRC approval.

IO. Implement modified operating procedures and emergency procedures (by licensee)

See Milestone 5.

il

ENCLOSURE (3)

IMPLEMENTATIONREPORT INADEQUATECORE COOLING INSTRUMENTATION(RVLMS)

I.

The installation,.functional testing, and calibration of the RVLMS portion of the ICCI system were completed by December 16, l983 for Turkey Point Unit 3 and May 25, l984 for Turkey Point Unit, 4.

The functional 'testing and calibration were completed in accordance with Temporary Procedure TP

0065, "Qualified'afety Parameter Display System Functional Test Bc Calibration".

Copies of the procedure and test results for both units were given to the NRC during the ICCI System audit at the Turkey Point Plant on August 8, I 984.

2.

Based on the. test results obtained, the RVLMS performs in accordance with design expectations and within design error tolerances.

There were no deviations from the design performance specifications.

As discussed during the audit, there are a number of hardware and software problems which remain to be resolved.

FPL is pursuing resolution of those problems with the vendor, Combustion Engineering (C-E).

3.

Deviations, of the as-built system from previous design descriptions (FPL letter L-83-l35 dated March, IO, l983) are described in Attachment (2) to Enclosure (I) of this Submittal.

4.

A request for modification of the Turkey Point Units 3 and 4 Technical Specifications, to include all 'ICC instrumentation for accident monitoring was submitted to the NRC on June l5, l984 (FPL Letter L-84-I55). Appropriate operability requirements for the RVLMS have.not yet been defined.

Because of this, FPL on September l3, I 984 (FPL letter L-84-250),submitted a request to withdraw the, requested specification for the RVLMS from Table 3.5.5, accident monitoring instrumentation.

As 'a member of the C-E 'Owners

Group, FPL will be participating in the effort to define appropriate operability requirements.

Until this effort is completed, it would be inappropriate for FPL to establish a technical specification for this system.

5.

By this submittal FPL is requesting approval of the plant-specific installation of the RVLMS for Turkey Point Units 3 and 4.

6.

The emergency operating procedures used for operator training will conform to the technical content of NRC approved EOP guidelines.

(See Enclosure (2) of this submittal, Milestones 2 and 5.)

0

RESPONSE TO NRC REQUEST FOR ADDITIONALINFORMATION ON THE ICCS (ENCLOSURE I)

I.

Show schematically the final ICC instrumentation system and identify any deviations from the Appendix B to NUREG-0737 design requirements.

Also, provide.a detailed description of the power supply for ICCI and proposed upgrading plans with a completion schedule with respect to station Class IE power sources stated in NUREG-0737, Appendix B, Criterion 3.

The final ICCS schematic is shown on Fig.

I (attachment I).

The only, deviation from Appendix B to NUREG-0737 design requirements is the Power Supply for the ICCS.

The Inadequate Core Cooling System is presently powered from panels 3(4)C202A and 3(4)C203A.

These safety related panels are powered from the vital portion of MCC's 3(4)B and 3(4)C.

In the event of a loss of offsite power,, there willbe momentary interruption of power to the ICCS until the MCC's are automatically sequenced onto the diesels.

The ICCS can tolerate a power loss without "crashing" the system.

The ICCS functions will be lost during the power loss only.

Upon restoration of power, the system will automatically come back into operation.

The present power supplies represent on-interim configuration until the Vital Inverters of Turkey-Point are replaced.

At that time, the ICCI will be transferred to the l20 volt vital a.c.

system and powered from the Vital Instrumentation panels.

These panels are

.fed from the Vital Inverters which are normallly fed from the battery chargers and backed up by the safety related plant batteries.

2.

Describe the operational status of the final ICCI system, and identify any as-built deviations of the system. from your previous design descriptions.

The operational status of the final ICCS and deviations from the previous FPL submittal (FPL letter L-83-l35 dated 3/IO/83) is shown on Attachment.

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@ST Florida Power and Light Company ATTN:

Mr. J.

W. Williams, Jr.

Group Vice President Nuclear Energy Department P. 0.

Box 14000 Juno

Beach, FL 33408 Gentlemen:

SUBJECT:

MEETING

SUMMARY

- DOCKET NOS.

50-250 AND 50-251

~~ He~rmcopg This refers to a meeting that Mr.

R.

C.

Lewis of my staff and I held with Mr.

C. 0.

Woody of your staff.

The meeting was held, at your request, in the Region II Office on September 10, 1984.

We discussed the Turkey Point Plant Performance Enhancement Program and other related issues.

It is our opinion that the meeting was beneficial and has provided us with a better understanding of your plans.

Should you have any questions, we will be pleased to discuss them.

Sincerely, cc:

K. N. Harris, Vice President Turkey Point Nuclear Plant C. J.

Baker, Plant Manager Turkey Point Nuclear Plant bcc:

NRC Resident Inspector Document Control Desk State of Florida James P. O'Reilly Regional Administrator RII RII RII RI

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/84 84i03i0765 840918.

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September 17, 1984 Docket Nos.

50-250/251 Mr. J.

W. Williams, Jr.,

Vice President Nuclear Energy, Department Florida Power and L'ight Company Post Office Box 14000 Juno Beach, Florida 33408

SUBJECT:

AUXILIARYELECTRICAL POWER UPGRADE Re:

TURKEY POINT PLANT UNITS 3 AND 4 Distribution Docket 'e NRC PDR Local PDR ORBgl Reading Gray File DEisenhut OELD EJordan JNGrace DMcDonald CParrish ACRS (10)

The Turkey Point Plant experienced a series of events on February 12 and 16, 1984, which included reactor trips, unscheduled shutdowns and loss of offsite power to Unit 3.

By confirmation of Action Letter dated February 21, 1984, Florida Power and Light identified interim actions which were completed'rior to restart and long term actions which included a

review of the offsite and onsite electrical power system.

FPL provi'ded the results of their review and proposed design modifications for the NRC to review and approve prior to completing the proposed changes.

By letters dated June 22 and July 25, 1984, FPL provided design details and analysis in support of the auxiliary power upgrade.

The staff has completed their review of the proposed design changes.

The changes provide improved separation of safety-related loads; el.iminates AC system undervoltage operating constraints; provides a direct electrical station blackout tie from the existing five cranking diesels to the Units 4'. 16 KV busses; minimizes interaction with the fossil units and; provides additional electrical ties to the switch yard.

Based on the staff review of the information provided and'ur site visit on June 5 and 6, 1984, we have concluded that the design of the auxiliary electric power system upgrade results in an overall improvement in the electrical system and plant safety and is, therefore, acceptable.

The details of our review are provided in the enclosed Safety Evaluation.

Sincerely,

/s/DWigginton, for

Enclosure:

As stated Steven A. Varga, Branch Chief Operating Reactors Branch 81 Division of Licensing cc w/enc 'osure:

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