ML17207A591

Forwards Supplemental Response to NRC 790913 Ltr Re Implementation Schedule for Requirements of NUREG-0578

ML17207A591
Person / Time
Site:	Saint Lucie
Issue date:	11/21/1979
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
L-79-327, NUDOCS 7911260323
Download: ML17207A591 (23)

Text

REGULATORY 1 FORMATION DISTRIBUTION SYSTEM (RIDS3 ~

ACCESSIQN NOR)7911260323 C's DATE: 79/11/21 NOTARIZh s "0 DOCKET FAt:lC:SO-3'l5"St;", Licie Planti *Unit lr Fluoride Power L Light Co-. 05O00P5 AO'TH ~ NAME~ AUYHOA AFFILiATION UHRICg H ~ E;, F 1 or f da Power L Li ght Co, ~

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SUBJECT:

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=-p FLORIOA POWER II LIGHT COMPANY liovembeI" 21, 1979 L-79-327 Office of Nuclear Reactor Regulation Attention: Mr. Darrell G. Eisenhut, Acting Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Eisenhut:

Re: St. Lucie Unit 1 Docket No. 50-335 NUREG-0578 Shor't Term Re.uirements Pursuant to Yir. Denton's letter of October 30, 1979 and subsequent telephone conversations with members of the NRC Staff, = lorida Power & Light Company has re-evaluated its response to vour letter dated September 13, 1979. Based on the foregoing and having additional time available in %he interim to more clearly define schedules regarding the purchase and installation of hardware necessary to meet the requirements of NUREG-0578, PPGL has supplemented its response to your September 13th letter. Our supplementary response is attached to this letter, which is also intended to serve as a response to Nr. Denton's letter.

Very truly yours, Robert. E. Uhrig Vice President Advanced Systems G Technology REU/ DKZ/cph Attachments cc: Mr. ~ames P. O'Reilly, Region .IX Harold P. Peis, Esquire

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ATTACH'AENT 1

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Re: St. Lucie Unit 1 Docket No. 50-335 NUREG-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 init'ia'lly presented in our letter dated October 22, 1979 (L-79-292). Wherever 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 schedules, limited manpower resources throughout the industry, and 'elivery system load requirements "relative to'the operation of three nuclear units on the Florida Power 8 Light Company (FPL) grid.

Procurement and mahpower 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 time frame)- Since 1977, the FPL systemwide winter demand peaks have approached and sometimes exceeded the summer demand peaks. Given the certainty of a major winter peak, it is unavoidable that the short-term NUREG-0578 modification schedule be closely coordinated with the overall FPL load management projections for 1980. Consideration of procurement and manpower exclusive of load management not accurately represent the situation that must be considered relative 'ould to installation of the NUREG 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 Decawber 2, 1979 to February I, 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. Lucie Unit I in addition to Turkey Point Unit 3 would cause seri'ous deficiencies in our ability to generate the expected wi nter loads.

For examp.e, if St. Lucie Unit I is removed from service concurrent with furkey Point Unit 3, there 'will be a projected systemwide deficiency of 489 Hw h

and a South Florida area deficiency of 90 Nw (the South Florida 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 with Turkey Point Unit 3, there will be a projected systemwide deficiency of ll85 Hw and a South Florida area deficiency of 786 Hw. In accordance with s andard operating practices mandated by the National Energy Reliability Council, a "single contingency alowance" has been factored into (1) th systemwide projections to allov for the loss of the next largest unit and (2) the South .

Florida projections to allow for the loss of the Andytown-Orange River 500 kV transmission line'. It should be noted that these figures assume peaking of all normally avail able gas turbines.

The shortfalls in generation caused by concurrent NUREG-0578 shutdowns would lead to s lective, rotating outages within the FPL service area. 1!e believe that this can be justifiably avoided by maintaining the current planned-outage schedules for St. Lucie Unit I and Turkey Point Unit 4, since our improved

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1 modification schedule shows that almost all HUREG-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), subcooling margin monitor (2.1.3.b),

and auxiliary feedwater initiation and flow indication (2.1.7).

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 t arch 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 duri ng the inter'im period, we would use that time to work on uncompleted items that requi red plant shutdown, given the availability on-site of necessary materials.

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4 ATTACHl'1ENT 2 Re: St. Lucie Unit 1 Docket No. 50-335 NUREG-0578 Short Term Re uirements 2.1.1 Emer ency Power Sources The pressurizer heaters can be loaded onto the lA3 and 183 busses'rom the Control Room. This was not explicitly stated in our initial response.

2.1.3.a Direct Indication of Valve Position The St. Lucie Unit 1 primary system relief and safety valves will be provided with direct position or flow indication devices that meet the f'unctional requirements of'UREG-0578, item 2.1.3.a. Action has been initiated to implement this requirement:

(1) Purchase orders have been placed for the necessary material and equipment-(2) Equipment delivery at the plant, based on the manufacturer's promise to deliver, is scheduled to be completed by January 1, 1980.

(3) Compl ete impl ementation of this requirement is scheduled for approximately triarch, 1980, based on the justification provided in Attachment 1.

2.1.3.b Instrumentation for Inade uate Core Cooling A subcooling margin monitor will be installed in the St. Lucie Unit 1 Control Room. The mo'nitor will continuously display the margin to saturation in terms of either .temperature or pressure e 'through the use of a selector switch. 'ction has been initiated to'implement this requirement:

(1) A vendor has been selected and advised of our decision to purchase a subcooling monitor.

(2) A portion of the material required is available at the plant .

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(3) Purchase orders have been placed for the remainder of the necessary material and equipment.

4 (4) Equipment delivery at the plant is scheduled to be completed by January 1, 1980. This'is the best ava'.lable delivery date based on negotiation with the manufacturer of the subcooling

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(5) Complete implementation of this requirement is scheduled for approximately March, 1980, based on the justification provided in Attachment 1.

(6) The procedures to be used by the operators as backup for recognizing inadequate core cooling are being developed based on analyses performed in response to Item 2.1.9, Transient and Accident Analysis - Analysis of Inadequate Core Cooling. The guidelines for the procedures have been developed by the C-E Owners Group and will be incorporated into plant procedures by January 1, 1980.

2.1.6.a S stems Integrity for High Radioactivity FPL is currently developing a program which will identify and minimize leakage in systems outside containment that could possibly-contain highly radioactive fluids during a serious transient or accident. The program will identify applicable systems, develop procedures, and establish inspection frequencies and acceptance criteria as well as ensure that required maintenance is performed.

Our preliminary evaluations indicate that ap'plying this program to gaseous systems vill be considerably more difficult than to the liquid systems, however, we plan to implement the leak reduction program by January I, 1980..

Our Architect/Engineer (A/E) is reviewing the St- Lucie Unit I plant design to identify locations where additional shielding may be required, in order to conduct post-accident operations. This review will be completed prior to January I, 1980. Dose calculations affecting personnel access and sensitive equipment will be ccmpleted by July 1, 1980. 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- he do not have sufficient information at this time to make a finn schedular, commitment, however, we intend to make every reasonable effort to meet the January I, 1981 date.

2.1.7 Auxiliary Feed Hodifications A Plant Change/Hodification (PCH) has been engineered which provides for automatic star ting of all three auxiliary feedwater pumps installed at St. Lucie Unit 1. This PCH provides a safety-grade system which allows use of the steam generator low level trip to initiate the pump start. Initial investigations into equipment procurement indicate that delivery schedules for qualified components will severely delay implementation of the PCN. "Additionally, the PCM, which was generated as a result of commitments made in response to IE Bulletin 79-06B, does not presently incorporate the auto'matic openi ng of the AFH pump flow control valves. A preliminary engineering design has been generated by our A/E to resolve this

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matter, but this effort may prove extensive due to the requirements '.

for complex circuitry (and possible new safety analyses) required to address postulated accidents such as main steam line break and reactivity restart.

Based on the extensive redesign, procurement, and installation effort that will be needed for implementation of a safety-grade system for, automatic initiation of auxiliary feedwater, we do not believe that we can supply a realistic implementation schedule at this time-Implementation of a control-grade system can provide no 'relief due to the long lead time for procural of Class lE isolators which would be required to interface a control grade system to the presently installed Class 1E auxiliary feedwater circuitry.

Design. of the fully automatic, Class lE auxiliary feedwater I

modiiications is expected to be finalized prior to v'anuary I, 1980.

We believe that a realistic schedule for implementation of the design modification could be provided at that time- For the interim. period, we believe that the concept of a designated operator, as committed to in our response to IKE Bulletin 79-06B, provides adequate assurance that auxiliary feedwater flow, if required,'will be initiated and verified under transient or accident situations.

4 2.1.8.a Post Accident Sam 1 inq (1) A generic design for automatic sampling and analysi;s, including the additional shielding, can be completed by our

A/E by January 1, 1980. lie 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.

(3) -

Me will make every reasonable effort to meet the January 1, 1981 modification date.

2.1.8.b Hi h Range Radiation llonitors FPL is proceeding with the design and procurement of high r ange in-containrrient radiation monitoring instrumentation and effluent monitoring instrumentation. Hovever, we do not have sufficient information at this time to make a firm commitment regarding scheduled implementation of these modifications. Since the unit is scheduled for a routine refueling otuage in the Spring of 1981, we intend to make every reasonable effort to implement the modifications at that time-Since the January 1, 1980 procedural requirements related to the monitoring oi noble gases, radioiodine, and particulate effluents was not contained in HUREG-0578, we are just beginning our effort to comply. Given the short time frao.e and our short-term manpower limits, we can only approximate an April 1, 1980 ccmpletion date.'He

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will make every reasonable effort to advance. that date as much as possible-2- 1.8.c Im roved In-Plant 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

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the charcoa'l, and analyzing for Iodine on a GeLi detector.

2-1.9 Analys'is of Design 8 Off-Normal Transients 5 Accidents

{I) Transient and Accident Analysis:

No change from initial response.

(2) Containment Pressure Monitor:

(3) Containment llater level Monitor:

(4) Containment Hydrogen Monitor:

Items 2, 3, and 4 are being engineered by. our A/E and our preliminary planning (assuming no equipment procurement problems) is for installation by the Spring 1981 refueling outage.

(5) RCS Venting:

The engineering design by our A/E will be completed by January 1, 1980. Since the details involving analysis, procurement, and installation remain to be resolved, we are unable to make a firm schedular commitment at this time- However, since the Unit is scheduled for a routine refueling outage in the Spring of 1981, we intend to make every reasonable effort to implement the modification by that time.

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 interfere with his primary function. Training of technical advisors is scheduled to be ccmpleted by January 1, 1981, conti.ngent on the availability of simulator training time.

FPL believes that the STA responsibility can be appropriately discharged over the short term by utilizing an "on call" system as

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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 4e 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 duri ng the interim until all STA positions are formally filled-k Operational experience evaluation and assessment may 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 is 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.

2-2.2.b Onsite Technical Su ort Center (1) The training and classroom area, (formerly intended as the Unit 2 Control Room) will be used to house the Technical Support Center (TSC) by January 1, 1980.

0 (2) Design details to upgrade the TSC to meet all requirements vIill be provided by our A/E as soon as possible in an effort to meet the January 1, 1981 implementation date.

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