ML17338B206

Ack Receipt of 790913 Ltr Re Followup Actions Resulting from NRC Review of Tmi.Forwards Response Including Info Re Emergency Power Supply Requirement,Relief & Safety Valve Testing,Direct Indication of Valve Position & Recombiners

ML17338B206
Person / Time
Site:	Turkey Point
Issue date:	10/22/1979
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
L-79-293, NUDOCS 7910250373
Download: ML17338B206 (10)

Text

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e REGULATORY INMATION DISTRIBUTION SYSTEO(RIDSI ACCESS/ON NBR: 7910250373 DOC, DATE: 79/10/22 NOTA RI ZED! NO DOCKET.

FACIL:50 250 Turkey Point Planti Unit 3E 'Florida Power and Light C 05 50" 251 Turkey Point P)anti Unit Qi Flor,ida Power -and -Light C 05000251 AUTH'AMP AUTHOR AFFILIATION UHRIGEp,E. Florida Power 8 Light Co.

RECIP ~ NAME'ECIPIENT, AFFILIATION EISENHUT-<D G. ~ Division of Oper ating Reactors SUBJECT Ack receipt of 790913 ) tr re fo) lowup actions resulting from NRC review of TMIBForwards response inc)uding info re emergencypower supplyrequirement<relief 8 safety valve testingidirect'ndication'f valve position L recombiners',

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J fkwsslX FLORIDA POWER 8 LIGHT COMPANY October 22, 1979 L-79-293 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: Turkey Point Units 3 & 4 Docket Nos. 50-250 & 50-251 NUREG-0578 We have reviewed your letter of September 13, 1979 regarding the followup actions resulting from NRC staff review of the TMI-2 event, and our response for Turkey Point Units 3 and 4 is attached. While we are attempting to meet the staff's proposed schedule, this will not be possible in every instance We believe that the commitments made in our response represent a realistic and reasonable schedule.

Very truly yours, Rober E. Uhrig Vice President Advanced Systems & Technology REU/MAS/cph Attachment cc: Mr. James P. O'Reilly, Region II Harold F. Rei s, Esquire v,e 0~ P~

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PEOPLE... SERVING PEOPLE

ATTACHMENT 2.1.1 EMERGENCY POWER SUPPLY REQUIREMENT Preliminary reviews to date indicate that Turkey Point Units 3 and 4 presently meet the requirements of NUREG-0578, Item 2.1.1.

Therefore, the functional and schedular requirements are expected to be fully met. Should the ongoing review show that modifications are required, they will be evaluated and scheduled and we will inform the NRC of such schedule.

2.1.2 RELIEF AND SAFETY VALVE TESTING Florida Power 8 Light Company is, part of an owners group formed by utilities utilizing Westinghouse reactors in their plants. The Westinghouse Owners Group is working in conjunction with the other PWR owners and the Electric Power Research Institute (EPRI) to develop a program for qualification of reli.ef and safety valves under expected operati ng conditions including solid-water and two-phase flow conditions. The program descriptions and schedule will be submitted by the required date of January 1, 1980.

2.1.3.a DIRECT INDICATION OF VALVE POSITION The Turkey Point Units 3 and 4 primary system relief and safety valves will be provided with direct position or flow indication devices which meet the functional requirements of NUREG-0578, item 2.1.3.a- It is FPL's intent to install the required equipment during each unit's scheduled 1980 refueling outage. This ccmmitment assumes that equipment procurement will not impact the desired schedule.

2.1.3.b INSTRUMENTATION FOR INDE UATE CORE COOLING Turkey Point Units 3 and 4 are proceeding with the purchase of Subcooling Meters for installation in the control room. The meter's will continuously display the margin to saturation in units of either temperature or pressure through the use of a selector swi-tch. A vendor has been selected and advised of our decision in order to expedite delivery in parallel wi'th the processing of documents required for the purchase of the equipment.

The procedures to be used by an operator to recognize inadequate core cooling will be developed based on analyses being performed as required by Item 2. 1.9, Transient 8 Accident Analysis, Analysis of Inadequate Core Cooling. Procedural guidelines developed by the Westinghouse Owners Group will be used to establish generic resolutions no later than January 1, 1980.

The functional requirements and a conceptual design for a reactor vessel level measurement device are being reviewed by Florida Power 5 Light Company. This effort includes a survey of currently available technology and assessment of the feasibility of various

alternatives. If required as a result of the generic resolutions discussions with the NRC Staff, the functional requirements and conceptual design will be submitted for proposal review by the NRC Staff prior to implementation. The installation schedule, for such a device, should it be deemed necessary, will be established during the Proposal Review.

2.1.4 DIVERSE CONTAINMENT ISOLATION Turkey Point Units 3 and 4 meet the requirement for diverse containment isolation in that containment isolation is initiated from a containment pressure signal and also frcm a safety injection actuation signal. In order to be in full compliance with the intent of NUREG-0578, item 2-1.4, modifications to prevent inadvertent repositioni ng of isolation valves are being implemented. These modifications should be ccmpleted by January 1, 1980.

2. 1.5. a DEDICATED H CONTROL PENETRATIONS Turkey Point Units 3 and 4 have redundant purge connections which are independent of the large containment penetrations. However, we have not concluded our engineering review to determine if the design criteria specified in NUREG-0578, item 2.1.5.a are met. This review will be completed and Florida Power 8 Light Company will provide a plan description which meets the intent of the NUREG-0578 requirements by January 1, 1980. Any required modification will be completed during the 1981 refueling outages for each unit.

2.1.5.c RECOMBINERS Turkey Point Units 3 and 4 do not currently employ hydrogen recombiners for control of hydrogen gas in the contai nment resulting frcm zirc-water reaction. As a result, no procedures exi st, nor are any required for recombiner usage at this time. Should future requirements result in the installation of reccmbi ners, procedures for their use will be provided at that time.

2.1.6.a SYSTEMS INTEGRITY FOR HIGH RADIOACTIVITY FPL is currently developing a program which will identify leaks in systems outside containment that could potentially 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. Our preliminary evaluations indicate that applying this program to gaseous systems will be considerably more difficult than to the liquid systems, however, our intent is to complete the short term leakage reduction programs during each unit's 1980 refueling outage-2.1. 6.b PLANT SHIELDING REVIEW Our A/E is presently performing the required design review. They have advised us that a review of the plants and identification of potential problems can be canpleted prior to January, 1980, however,

dose calculations affecting personnel access and sensitive equipment will be completed by July 1, 1980. Our intent is to attempt to implement required shielding or other modifications during the 1981 refueling outages for each unit. However, this is obviously dependent on the extent of the required modifications. We will provide the actual schedule as soon as it can be established.

2.1.7.a AUTOMATIC INITIATION OF AUXILIARY FEED Turkey Point Units 3 and 4 presently have automatic initiation of auxiliary feed with the exception that the normal operating mode has the flow control valves closed requi ring manual modulation from, the control room by the designated operator. We intend to add automatic time delayed opening of the discharge valves, thus giving fully automatic auxiliary feedwater initiation. However, our A/E has not indicated that a January 1, 1980 ccmpletion date is feasible. We will make every attempt to fully comply with this item during the 1980 refueling outages for each unit.

2.1. 7.b AUXILIARY FEED FLOW INDICATION Our A/E has indicated, that qualified transmitters cannot be procured by January 1, 1980. Our intent would be to complete installation that would satisfy the NUREG-0578 requirements during the 1980 refueling outages for each unit (if somehow we can get the required equipment within this time frame). If these plans are precluded by unavailability of equipment, we would complete the required work as soon thereafter as practical.

2. 1.8.a POST ACCIDENT SAMPLING In conjunction with Section 2. 1.6.b above, a design review is in progress to identify areas where the post-accident sampling capability can be improved. This revi ew is scheduled for completion by January 1, 1980. Additionally, plant procedures are undergoing a detailed review in order to accompli sh the same end including the minimization of personnel exposure. Procedure revisions are scheduled for completion by July 1, 1980. If plant modifications are required, a description of any such modifications and a schedule for implementation will be submitted to the NRC.

If the radiological spectral analysis cannot be performed in a prompt manner with existing equipment, design modifications, equipment procurement, or contractural arrangement will be undertaken to accomplish a spectral analysis. The two hour time restriction is considered to be neither practical nor critically essential. It, should be n'oted that we anticipate complex and potentially insurmountable difficulties in complying with the requirements

,regarding chlorine and boron analyses. Our investigations indicate that a highly-radioactive chloride and boron analysis could not be performed on-site. A contractural arrangement is being investigated along with on-line boron-monitoring capabilities. Following the resolution of these specific requi rements, an implementation schedule will be submitted to the NRC.

2.1.8.b HIGH RANGE RADIATION MONITORS Fl orida Power 8 Light is proceeding to design, procure and install noble gas monitors in plant effluent lines and high range containment radiation monitors. We anticipate that installation of this system can be accomplished during or prior to the unit's scheduled 1981 ref uel i ng outage.

2.1.8.c IMPROVED IN-PLANT IODINE INSTRUMENTATION

'n view of the lead time involved in obtaining the equipment necessary to comply with this requirement, as well as the time needed to engineer and install the modification, we estimate that we will be unable to meet implementation schedule date of January 1, 1980. FP8L will, however, make every effort to accompli sh the installation of this system at the earliest date practical.

2.1.9 1. Transient and Accident Anal sis Analyses of small break loss-of-coolant accidents, symptoms of inadequate core cooling and required actions to restore core cooling, and analysis of transient and accident scenarios including operator actions not previously analyzed are being performed on a generic basis by the Westinghouse Owners Group of which Florida Power 8 Light Company is a member. The small break analyses has been completed and are reported in WCAP-9600, which was submitted to the Bulletins and Orders Task Force by the Owners Group on June 29, 1979. Incorporated in that report were guidelines that were developed as a result of the small break analyses. These guidelines have been reviewed with the BKO Task Force and were presented to the owners group utlity representatives at a semi nar held on October 16-19, 1979.

Following this seminar, each, utility .will develop plant specific procedures and train their personnel on the new procedures. (It is intended that the revised procedures and training will be in place by December 31, 1979, in accordance with the requirement in Enclosure 6 to Nr. Eisenhut's letter of September 13.)

The work required to address the other two areas -- inadequate core cooling and other transient and accident scenarios is being performed in conjunction with the Bulletins and Orders Task Force, including establishment of information requirements to meet the duties specified in Enclosure 6. Analyses related to the definition of inadequate core cooling and guidelines for recognizing the symptoms of inadequate core cooling based on existing plant instrumentations and recovery from such a condition >sill be provided by October 31. Further work to better define the approaches to inadequate core cooling and recovery operations may be required and will be performed later. It is intended that the guidelines provided by October 31, 1979, will be incorporated into plant procedures and training acccmplished by the required date of January 1, 1980.

The Owners Group is also providing pretest prediction analysis of the LOFT L3-1 nuclear small break experiment. This analysis will be submitted by the required date of November 15, 1979, in accordance with the schedule established by the B80 Task Force.

2. Containment pressure monitor.

3. Containment water level monitor.

4. Containment hydrogen monitor.

Items 2, 3, and 4 are presently being engineered and preliminary schedules provided by our A/E (assuming no unusual equipment procurement problems) i ndicate that FPL can complete installations of these items during the scheduled 1981 refueling outages for each uni t ~

5. RCS Venting FPL is presently evaluating functional requirements and conceptual designs for the addition of RCS vents to Turkey Point Units 3 and 4. These requi rements and a conceptual design will be available for discussions with the NRC Staff to establish generic resolutions no later than January 1, 1980. A decision concerning installation of an RCS venting'ystem at Turkey Point Units 3 and 4 will be made following completion of the 'generic resolution meetings.

2.2.1. a SHIFT SUPERVISOR RESPONSIBILITIES Plant procedures and practices in this area are undergoing review to ensure that reactor operations command and control responsibilities and authority are properly defined. Procedure revisions or other changes required as a result of this review will be incorporated by January 1, 1980. An operational policy directive specifying the duties, responsibilities, authority and lines of command covering the control room operators, the shift technical advisor and the shift supervisor will be issued by FP8L's corporate management by January 1, 1980.

2.2.1.b SHIFT TECHNICAL ADVISOR FP8L will establish technical advisors, either on call or on each shift, during periods when one or both Turkey Point nuclear units are not in the cold shutdown or refueling modes as defined in the Technical Specifications. A minimum of 2 qualified individuals would be on call at all times and would be capable of responding within -45 minutes. Each individual on call will be supplied with two-way radios to enable communications with the plant. Coverage will commence on January 1, 1980. The technical advisor's primary function 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, but this schedule may be impacted by the availability of simulator training time.

Operational experience evaluation and assessment may be performed by the technical advisor or other functional organizations either on-site or at FP8L's General Office. At such time that the man-machine interface is improved as a result of such activities as improved control rocm design and/or operator qualification, FPSL may elect to designate a qualified member of the operating shift to perform the accident/transient function.

2.2.1.c SHIFT TURNOVER PROCEDURES Turkey Point Units 3 and 4 plan to meet the intent of NUREG-0578, item 2.2.1.c by January 1, 1980.

2.2.2a CONTROL ROOM ACCESS Turkey Point Units 3 and 4 plan to meet the intent of NUREG-0578, item 2.2.2.a. by January 1, 1980.

2.2.2.b ONSITE TECHNICAL SUPPORT CENTER FPL is presently evaluating a design for a new facility and also determining if an appropriate existing structure is available at the Turkey Point Plant site. We will establish an interim Technical Support Center by January 1,'980. The center will include as a minimum dedicated phone ccmmunication to the control rocm, and appropriate plant drawings. By January 1, 1980, we will provide our plans to establish the onsite Technical Support Center intended to meet the functional requirements of NUREG-0578, item 2.2.2.b. We will target completion of the upgraded center as near to January 1, 1981 as allowed by the integration of the following limiting concerns: equi pment procurement times, structure construction times, and unit outage schedules.

2.2.2.c ONSITE OPERATIONAL SUPPORT CENTER Turkey Point Units 3 and 4 plan to meet the intent of NUREG-0578, item 2.2.2.c by January 1, 1980.

Encl. 8 NEAR TERM EMERGENCY PREPAREDNESS IMPROVEMENTS Florida Power 5 Light is in general agreement with the required improvements contained in Enclosure 8 to your September 13, 1979 letter. We believe we can implement these improvements consistent with the NRC schedule with the exceptions noted in Section 2. 1.8 in addition to three other areas of concern as discussed in the following paragraphs.

Each of our sites has, in the past, routinely conducted site test exercises in conjunction with local, State, and Federal officials on an annual basis. The 1980 tests are scheduled to be conducted during August/September. As the improvements to the emergency plan are not scheduled for completion until June, 1980, we believe the present test exercise schedule is reasonable and can commit to meeting this requirement by October 1, 1980.

Regarding the upgrading of the emergency plans, we agree in principle with the recommendation to upgrade to Regulatory Guide 1.101.

However we cannot at this time canmit to the action level criteria as contained and described in that document and in NUREG-0610, Draft Emergency Action Level Guidelines for Nuclear Power. We require additional time to review the draft criteria. We believe we can forward our position on this item to the NRC by January 1, 1980.

With respect to the Emergency Operations Center, we believe that specific requirements are not sufficiently defined to enable FPKL to designate dedicated primary and alternate locations at this time.

Once the criteria are firm, we will provide the NRC with primary and alternate locations and a schedule for implementation of upgrading requi rements.

STATE OE PLORXDA )

) ss COUNTr OZ DADE )

H. A. Momat ,'eing first duly sworn, deposes anQ says.

That he is Executive Vic- P c '"-n- of Florida Power 5 Light. Comoany, the Licensee herein; That he has executed the foregoing document; t:hat the state-ments maQe in this saiQ document, are true anQ correct to .the best, of his knowledge, information, and belief, anQ that he is aut:horizecl to execute the document on behalf of said Licensee E. A Adomat..

Subscribed anQ sworn to before me this Qay of 4d l" c~

NOTARY P HLXC, in and fr .the County of Dacle, /~

Florida QQ}

State o ,~w

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