L-85-372, Commits to Apply Appropriate Tech Spec Requirements to Address Auxiliary Feedwater Pump Availability & Performance Monitoring.Several Items Discussed in IE Operational Readiness Insp Team 850913 Exit Meeting Resolved

Commits to Apply Appropriate Tech Spec Requirements to Address Auxiliary Feedwater Pump Availability & Performance Monitoring.Several Items Discussed in IE Operational Readiness Insp Team 850913 Exit Meeting Resolved

ML20199E468
Person / Time
Site:	Turkey Point
Issue date:	09/30/1985
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20199E404	List: L-85-372, Commits to Apply Appropriate Tech Spec Requirements to Address Auxiliary Feedwater Pump Availability & Performance Monitoring.Several Items Discussed in IE Operational Readiness Insp Team 850913 Exit Meeting Resolved ML20199E398 ML20199E411 ML20199E432 ML20199E453 ML20199E461 ML20199E480 ML20199E486 ML20199E503
References
FOIA-85-729 L-85-372, NUDOCS 8603270235
Download: ML20199E468 (2)

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sE? e c ms L-85-372 Dr. J. Nelson Grace Regional Administrator, Region 11 U.S. Nuclear Regulatory Commission 101 Marietta St. NW Atlanta, GA 30323

Dear Dr. Grace:

Re: Turkey Point Units 3 & 4 Docket No. 50-250, 50-251 {

Auxiliary Feedwater System Florida Power & Light is concerned that there is not sufficient recognition of the numerous positive steps.taken in the past and being taken at present to upgrade and improve the auxiliary feedwater system at Turkey Point. As you know, Turkey Point is an early generation commercial nuclear power plant, designed with features such as shared systems which are not completely consistent with ,

current regulatory thinking. As a result of these changes in regulatory '

philosophy and a desire to improve performance where feasible, a number of modifications have been implemented on systems such as auxiliary feedwater by both NRC mandate and self-initiated betterment incentives. FPL senior l management has been personally involved in providing guidance, technical direction, and the significant resources necessary to accomplish these modifications, many of which were self-initiated and major in scope.

Examples of these self-initiated modifications include the procurement and installation of new and improved full pressure turbines on the three original safety grade auxiliary feedwater pumps. Also, exceeding any current requirements, FPL has installed two non safety grade motor driven, standby feedwater pumps to provide a capability that went further than the design requirements of the plant. These pumps have been routinely run in accordance with plant procedures. The power supply for these pumps is normally from the 4160 Volt C-bus, and in case of loss of off-site powpr, backup supply can be obtained from the 5 non-safety grade diesel generators rated at nominal 2500 KW each. These diesel generators can supply power directly to nuclear side loads via internal (site) cable runs independent of tne switchyard. To emphasize and receive appropriate credit for the capability that exists in these pumps, FPL is initiating steps and hereby commits to apply appropriate technical specification requirements to address their availability and performance monitoring.

FPL has taken the initiative to resolve items which had been self-identified.

Many of these items were also mentioned in the I & E Operational Readiness Inspection team's exit meeting on September 13,198A FPL has corrected a number of these items and will provide whatever resources are necessary to promptly resolve the remaining areas. D/$

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Turkey Point Units 3 & 4 Docket No. 50-250, 50-251 Auxiliary Feedwater System Page 2 Of particular concern to FPL was the team's impression of inadequacy in the nitrogen back up system to the auxiliary feedwater valve operating controls.

The Auxiliary Feedwater System flow control valves are normally operated using motive force from the Instrument Air System. As a backup to this source, a nitrogen system is available via automatic transfer on low pressure. Testing of the various unit / train configurations to determine pressure " drop versus time, was conducted during September 1985. The test considered three cases,i.e.,

bleedoff from the regulator with the valve closed, bleedoff from the valve with the valve in AUTO, and bleeedoff while the required AFW flow was being maintained MANUALLY. Statements made by the NRC staff in the Commission briefing of September 18, 1985, that "the nitrogen system would sustain the auxiliary feedwater system for about six minutes",is not representative of the manner in which the system is normally operated. The data used as a basis for this comment is considered the worst case bleed down rate which occurs only with the regulating valves in automatic, and nitr,) gen bottle pressure at the low alarm setpoint of 500 psig. No credit was given for the fact that the~AFW flow control valves are typically placed in manual mode by.the operator in order to maintain steam generator level, and that this mode of operation extends nitrogen bottle usage time to a value in excess of 10 minutes. With the alarm setpoint and worst case event initiation at 500 psig, the guidance of 10 minutes for operator action to valve out one bottle and valve in a standby bottle should be sufficient.

In conclusion,I want to emphasize that we fully recognize the importance of the Auxiliary Feedwater System and have made significant improvements in that area on our own initiative. 'It is our opinion that these initiatives have not received the credit that they are due in the public record. We would welcome the opportunity to provide any additional information which may be required to demonstrate our management team's determination to maintain the auxiliary feedwater system in a well designed, well operated and highly reliable condition.

Sincerely, /

s hilN D' 3.W. Williams, Jr.

Group Vice President Nuclear Energy l

3WW: mis I

cc: James R. Taylor, Director I & E, USNRC . '

Harold R. Denton, Director, USNRC Hugh L. Thompson, Director, Division of Licensing, NRR Dan G. Mcdonald, Senior Project Manager, NRR Steve R. Elrod, Section Chief, Region II Harold Reis, Esq.

PNS-LI-85-333/1 l

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