ML17339A704

Responds to 791119 Ltr Requesting Addl Info on Condensate Polishing Demineralizers & Steam Generator Repair. Installation of Demineralizer Sys Does Not Require Mod to Tech Specs

ML17339A704
Person / Time
Site:	Turkey Point
Issue date:	03/18/1980
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML17339A705	List: ML17339A704 ML17339A706
References
NUDOCS 8003210425
Download: ML17339A704 (14)

Text

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A CCESSION t hR:8003210<>25 OOC DATE: 80/03/18>>OTARIZEO: >>0 I ACIL:50- 'urkev ~

Point Plant~ Uni t 3i Florida Power and Light C 7

05000250

-251 ur key Point Pl anti Unit 4~ F lorida Power and Liaht C 05000251 Specs'OCYTE AUTP ~ A AU THOR AFF IL I ATION UHRTbgh,ED Floriaa Power 5 Light Co ~

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SCH+EACER~A, Operating Reactors Branch 1 SUOJFCT: Hesponds to 791119 ltr reauestina aadl info on condensate polishing demineralizers 8 steam aenerator repair.

Installation of oemineralizer sys does not reauire mod to Tech DISTRIBUTION COOE: A001S COPIES HE.CE.IVEO:LTR + E~CL Q SIZE:~ 4 ~

TITLE: General Oistribution for after Issuance of Ooeratinn Lic

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March 18, 1980 L-80-87'ffice of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Operating Reactors Branch 81 Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Schwencer:

Re: Turkey Point Units 3 & 4 Docket Nos. 50-250 and 50-251 Steam Generator Re air This letter is in response to your letter dated November 19, 1979 which requested additional information on the condensate polishing demineralizers and our planned steam generator repair. The responses to the questions enclosed with your letter are provided in Attachment 1.

The planned installation of a condensate polishing demineralizer system at Turkey Point Units 3 & 4 has been reviewed by the Turkey Point Plant Nuclear Safety Committee. They have concluded that the planned installation of the condensate polishing demineralizer system does not involve an unreviewed safety question or require a modification to the Facility Technical Specifications. A copy of our evaluation is attached as Attachment 2 in accordance with your request.

Please feel free to call me if you should have any additional questions about this matter.

Very truly yours, Robert E. Uhrig Vice President Advanced Systems & Technology REU/GDW/ah Attachments cc: J. P. O'Rei lly, Region II gaol Harold f. Reis, Esquire 5 mls

A. Provide the following information regarding the full flow condensate 0: polishing demineralizer system (contention 7).

I h 11 and its concentration at point of

<<I I release.

11 ionic species as well as contaminants removed from the demineralizers.

Include I h regenerant ANSWER The condensate polishers planned for installation at PTP 3 and 4 are of the Powdex type. Regenerant chemicals will not be utilized. FPL's current scheme for discharge of the polisher wastes includes a solids-water separation process, with high quality supernatant liquid being discharged into the closed cooling system, and solids held for land type burial.

0 0: I the waste.

h 01 ANSWER: A description of Powdex polisher waste is provided in the attached paper by Dr. Robert Kunin.

0 1 0: I h I I 0 0 ANSWER: Condensate polishers planned for PTP 3 and 4 do not involve a regeneration process.

EE lp 0: <<I discharge.

h f 0 <<I f h ANSWER: Same as 83.

00 0: 0 I I the demineralizer waste.

h<<f I p1 ANSWER: Under the currently proposed scheme of waste disposal, only high quality supernatant liquid would be discharged into the facility's closed cooling water system. It does not appear that dilution of the supernatant liquid prior to discharge will be required.

g 0: ld discharge.

d 1 1 1 h ANSWER: The point of discharge is expected to be on the discharge side of the facility.

0 0  : 10 h 11 1 1 111 1 immediate area of the discharge.

ANSWER: Under FPL's current plans for handling condensate polisher wastes, only high quality supernatant liquid would be discharged into the facility cooling canal system. The discharge point would be at the facility's discharge basin. The discharge stream is not expected to exceed 150 gpm. Flow rate through the facility discharge basin due to forced pumping is approximately 1.8X106 gpm with all circula-ting water pumps running. Due to the high quality of the discharge, g 0 ANSWER:

0:

discharge.

10 <<

FPL has no minimum requirement for circulating flow during the prior to release.

FPL's current plan

<<h for the handling of ll h 1110'0 condensate 1

polisher waste is as follows:

Spent resins would be backwashed as a resin-water slurry (using condensate quality backwash water), into a backwash receiver tank. Powdex resin and other solids would then be separated from the slurry leaving a high quality supernatant liquid for discharge into the facility cooling canal system. plan to dispose of the solid resins by 0:

We land burial.

1 <<h <<1 0 " hlh 111 1 d.

ANSWER: It is presently estimated that there will be no environmental degradation caused by the effluent release as a result of the operation of the full flow condendate polishing demineralizer system. The water quality of the polishing demineralizer system effluent discharge is expected to be superior to the water quality of the cooling canal system, Biscayne Bay, or Card Sound, FPL has been issued a National Pollutant Discharge Elimination System (NPDES) permit for Turkey Point Plant, NPDES bFL001562

by the United States Environmental Protection Agency (EPA) on June 14, 1978. That permit authorizes discharges to the circulating water cooling canal system without limitations or monitoring requirements provided that there is no surface discharge to Biscayne Bay or Card Sound. The effluent dis-charge from the full flow condensate polishing demineralizer system will be consistent with the terms and conditions of this permit. The permit requires FPL to monitor the water quality of the circulating water cooling canal system.

Grab samples must be taken quarterly at the outlet from Lake Warren and must include the following parameters:

salinity; total suspended solids; and total zinc, iron and copper. Results are submitted in reports annually on January 31 of each year.

In the event of indications of primary to secondary leakage, samples will be collected from the backwash receiver tank and tested for radioactivity prior to disposal of the wastes.

Liquid radioactive releases. are control.led by Appendix A of the Turkey Point operating licenses (Technical Specifications, Section 3.9) as well as by written procedures. Both quantity and concentrations are controlled. The releases are required to and do meet the restrictions imposed by 10 CFR Part 20 and Part 50, Appendix I.

Disposal of any radioactively contaminated polisher wastes will be in accordance with applicable NRC regulations concern-ing the discharge and/or disposal of solid radioactive wastes and 'radioactive effluents.

ETON: i 1<< f i 1ikly b receiving waters near the point of discharge.

ANSWER: Lists of organisms likely to be present in the cooling canal system have been compiled from published and unpublished sources. The lists of organisms are presented in the following tables, Table A-1 and Table A-2.

g 0: 1 <<h inants present i f i h <<i f in the waste stream on the aquatic organisms found near the plant.

ANSWER: FPL's current plans call for discharging only high quality supernatant liquid to the faci,l,ity cooling canal system.

The supernatant will be of higher quality than the water in the cooling canal system. The supernatant will therefore

have no deleterious effect on the organisms living in the cooling canal system.

UESTION 12'escribe the biological monitoring programs that will be conducted to assess the environmental impacts associated with operation of the demineralizer system.

ANSWER: The existing biological monitoring program (Environmental

.Technical Specification (ETS) for FPL Turkey Point Units 3 and 4) which is implemented for the Turkey Point Plant cooling canals will be used. Plankton (ETS Section 4.'. 1.

1. 1), fish (ETS Section 4. 1. 1. 1.2), and benthos (ETS Section

4. 1. 1. 1.3) monitoring will provide enough information to assess the environmental impacts associated with operation of the demineralizer system.

UESTION 13: Describe the status of all relevant permits required by other state, local and Federal agencies.

ANSWER: FPL has 'applied for and received all required relevant permits for the Turkey Point Plant from state, local or Federal agencies.

Any new application or amendments required as a result of changes or additions to current operating practices will be made at the appropriate time.

UESTION B: Provide the design details and exact location of the storage building (referred to in contentions 6* and lid). Include the structural design details to the extent necessary for the staff to determine the adequacy of the building to withstand hurricanes and floods. Also include the weight and dimensions of the steam generator lower assemblies to be stored in the building.

Provide the details of the method of sealing the steam generator lower assemblies; weld design, weld material, cap material and dimensions, corrosion protection, and any related information that will be needed to evaluate the possibility of radioactive material leaking out of the stored assemblies.

• Contentions referred to in this request are to be taken as given in the Atomic Safety and Licensing Board's "Order Relative to Contentions and Discovery" dated September 25, 1979.

ANSWER:=- The conceptual design and nominal dimensions of the storage compound are shown on the attached figure'. The final design might change depending on the outcome of ongoing engineering studies and evaluations. Each steam generator lower assembly with steel support saddles will rest on reinforced concrete

bearing pads. The compound will be designed and constructed in accordance with the South Florida Building Code, ACI 318, AMS Dl. 1 and AISC t1anual of Steel Construction; The approximate location of the storage compound in the laydown area is also shown on the attached figure. The current elevation of the laydown area ranges from +6 to +9 feet HLW. The approxi-mate subsurface profile in the vicinity of the storage compound consists of 4 feet of limerock fill fill over 6 feet of muck under and muck will be lain by Miami limestone. The existing excavated to a minimum distance of 15 feet beyond the edge of the storage compound. The entire compound and lay down area will be backfilled or filled as required with compacted limerock fill to + 17'" MLM with perimeter slopes of 1-vertical on 3-horizontal. Heavy equipment transport, laydown storage, and heavy lift crane implacements in support of repair and storage operations will require a minimum of 65 feet around the storage compound.

The limerock fill willfootbe which compacted to a minimum dry density of laboratory tests yields 110 pounds per cubic based on allowable bearing capacity of approximately 15 kips per square

'oot, strength of cohesion of approximately 3 kips per square foot, and an internal angle of friction of approximately 39.

A steam generator lower assembly is approximately 39 feet long and 127 inches in diameter except for the last 6 feet 4 inches where the diameter expands linearly from 127 inches to 166 inches.

The volume is approximately 3620 cubic feet and the dry weight is approximately 205 tons which yields a total vessel density of about 113 pounds per cubic foot.

The top of the assembly (approximately 13'0" diameter) and the two channel head nozzles (approximately 31" diameter) will be provided with 3" steel shield plates. The two blowdown nozzles (approximately 2" diameter), one shell drain (1" diameter), and one instrument nozzle (3/4" diameter) will be provided with 1" steel shield plates. The shield plate materials will be ASTN A36 or equivalent and will be welded to the lower assembly openings. Only carbon steel weld materials will be used and the weld throat will be 1" minimum. Since the storage compound will have a water tight roof the lower assemblies will be protected from industrial corrodent and salt spray deposition, hence special corrosion protection will not be required.

FPL is presently evaluating the effects of a postulated design basis hurricane upon the steam generator storage facility and its foundation. The results of this evaluation will be made available upon completion.

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0 0: 10 h 1 1 (referred to in contentions 1 h 7 and 11 lie).

0 h d ANSWER: The estimated costs for installing a condensate polishing demineralizer system for Turkey Point Units 3 and 4 is $ 9. 1 million.

0 0: dd h <<1" to in contention 11e).

1 1 0 d ANSWER: The cost involved in retubing the Turkey Point Units 3 and 4 condensers was approximately $ 1 million per water box; or a-total of $8 million.

0: 1 <<1 to the present time (discussed in contention llf).

>>11 ANSWER: The repair of the Turkey Point Units 3 and 4 steam generators is estimated to be $ 119.3 million (1979 dollars).

TABLE A-1 ORGANISMS OCCURRING IN THE TURKEY POINT COOLING CANAL SYSTEM (ANNUAL REPORTS, ABI 1974-1980)

ANNELIDA MOLLUSCA Polychaeta Gastropoda (continued)

Amphi ctei s gunneri floridu Prunum apici num Autolytus brevicirrata Retusa eburnea Capi tella capi tata Cauli eri ella killariensis Ci rri formia filigera MOLLUSCA Dorvi llea soci abilis Pelecypoda Fabricia sp. Astarte nana Glycera ambri cana Haploscoloplos foliosus Chione cancellata Laonone salmi ci dis Chione gl US Lumbrineris Sp. Diplodonta nuclei formis Maldane sarsi Gouldia cerina Marphysa sanguinea X,ucina mul tilineata Nereis succinea Lyonsia floridana Odontosyllis enopla modul us carchedoni us Paraoni des lyra Pitar albida Pista cristata Pseudocyrene floridana Platynereis dumel il1ii Tellina Sp.

Tellina al tezata Podarke obscura Polydora li gni ARTHROP0DA

'olyophthalmus pictus Pri onospi o heterobranchia texana Pycnogonida Sebi stomeringos rudolphi Scyphoproctus Sp. Anoplodactylus lentus syllzs sp.

'erebellides stroemi ARTHROPODA Crustacea Tri chobranchus glaciali s Typosylli s Sp. Cylindroleberi s mari ae MOLLUSCA Sarsi ella ameri cana Gastropoda Harpacticoida Oxyurostyli s smithi Batillaria minima Leptocheli a savi gnyi Bulla striata Aegathoa oculata Bulla occi dentale Cymodoce fa'xoni Crepidula forni cata Eri chsonella filiformi s Crepi dula maculosa Idotea metalli ca Cyclostremiscus trilix Sphaeroma quadri denta turn Cyli chna cerina l Elasmopus evi s Hami noea el egans li Eri ch thoni us brasi ensi s Grandi di erel la bonni eroi des Hydrobi a minuta

~

Hemiaegina minuta

TABLE A-1 (continued)

ORGANISMS OCCURRING IN THE TURKEY POINT COOLING CANAL SYSTEM (ANNUAL REPORTS, ABI 1974-1980)

ARTHROPODA FISHES (continued)

Crustacea (continued)

Centropomus undeci mali s rysianopsis alba Fundulus grandis Microdeutopus SP. Haemulon sci urus Mysi s st enol epi s Arius felis Taphromysi s bowmani Strongylura notata Alpheus armillatus Meni dia beryllina Hippolyte pleuracantha Diapterus plumieri Palaemonetes pugio Lagodon rhomoboi des Thor floridanus Caranx hippos Pinnixia sayana Haemulon parrai, Atherinomorus sti pes ECHINODERNATA Ophiuroidea l

Mugi cephalus Elops saurus Chaetodi pterus faber Amphi pholi s squamata Syngnathus Sp.

Gobi onellus SP.

MISCELLANEOUS Selene vomer Strongylura marina Echiuroi d cworms Hippocampus erectus Priapulid cworms Echenei s naucrates Sea squirts Caranx crysos Trachinotus falcatus SHELLFISHES Menticirrhus li ttoralis Archosargus probatocephalus Callinectes sapidus Dormitator maculatus Penaeus SPP. Mi crogobi us mi crolepi s Meni ppe mercenaria Sphoeroides testudineus Panuli rus argus Megalops atl anti ca Zi mulus polyphemus. Carcharhi nus leucas FISHES Floridichthys carpio Cypri nodon vari egatus Poeci lia lati pinna Lophogobi us cyprinoi des Gerres cinereus Euci nostomus gula Belonesox beli zanus Euci nostomus argenteus Lucania parva Albula vulp s Sphyraena barracuda Opsanus beta Fundulus confluentus L,gtjanus griseus L,utj anus apodus

TABLE A-2 ORGANISMS OCCURRING IN THE TURKEY POINT COOLING CANAL SYSTEM (FPL, 1975)

Blue Green Algae Lyngbya sp.

Chroococcus planctonica OsciZZatoria sp.

Chroococcus gigantea Schizothrix calcico1a Arthrospira sp.

Spirul~ sp.

Oscillatoria minor Merismopedia g1auca Johannesbaptisia sp.

Gomphospharia sp.

Merismopedia punctata Anabaena sp.

Eu glen ophyceae Astasia sp.

Eutreptia sp.

Uolvocidae Pyramkdcuonas grossi a

Cryptophysida Silicoflagellida Dictyocha ~ula Baci13 m9.ophyceae Navt.u1a sp.

~toms unid.

Cymatopleura solea Amphora oval.s Synedra ulna Nitzschia sigmoidea Synedra crysta1lina Nitzschia acicularis Su~e1la sp.

Pleurosi~ sp.

Synedra superba Nitzschia longa

Attachment 2 Condensate Polishin Oemineralizer S stem The new condensate polishing demineralizer system is planned for installation in the condensate/feedwater system at the discharge of the condensate pumps between the pumps and the No. 1 low pressure feedwater heater. The system's function is to purify the condensate by filtration and demineralization to assure high quality feedwater to the steam generators.

The condensate polishing demineralizer system control is independent from the existing condensate/feedwater system. When in use, the system treats full condensate flow from the condensate pumps. A full flow bypass system has been provided to assure continuous uninterrupted condensate/feedwater system operation.

Loss of normal feedwater flow due to pipe break, pump failures, valve malfunctions or loss of outside AC power, is discussed in Section 14. 1. 11 of FSAR, Chapter 14.

Technical specification 3.8 discusses the steam and power conversion system.

The condensate/feedwater system is not a safety related system.

10 CFR 50.59 (a) (2) defines an unreviewed safety question as follows:

"A proposed change, test, or experiment shall be deemed to involve an unreviewed safety question (1) if the probability of occurrence or the consequences of an accident or mal-function of equipment important to safety previously evaluated in the safety analysis report may be increased; or (2) if a possibility for an accident or malfunction of a differe'nt type than any evaluated previously in the safety analysis report may be created; or (3) if the margin of safety as defined in %he basis for any technical specification is reduced."

A summary of the review of the planned addition of the demineralizer system against the foregoing definition of an "unreviewed safety question" follows.

With respect to the probability of occurrence of an accident previously evaluated in the FSAR: As discussed previously, a full flow bypass line is provided for the condensate polishing demineralizer system. The probability of a loss of feedwater (LOFW) accident due to a failure in the condensate polishing demineralizer system and a concurrent failure of the bypass control valve to open is extremely small. This probability is not significant when considered in light of the frequency of feedwater transients (2 to 3 per year) as documented in Section 3. 1 of NUREG-0560 "Staff Report on the Generic Assessment of Feedwater Transients in PWR's designed by Babcock and Wilcox," 51ay 9, 1979. Therefore, the probability of occurrence of this accident is not increased by the addition of this system.

With respect to the consequences of an accident previously evaluated in the FSAR:

The addition 'of the condensate polishing demineralizer system has no effect on

the severity of any of the accidents discussed in Chapter 14 of the FSAR. The LOFW accident, which is the most severe accident for the feedwater system, has already been evaluated in the FSAR.

With respect to the probability of malfunction of equipment important to safety previously evaluated in the FSAR: The only system affected is the condensate/

feedwater system, which is not required to mitigate the consequences of a LOFW accident. The addition of the condensate polishing demineralizer system will have no effect on the auxiliary feedwater system since the systems are totally independent of each other.

With respect to the consequences of the malfunction of the equipment important to safety previously evaluated in the FSAR: For the reason stated above, the addition of the condensate polishing demineralizer system will have no effect on the consequences of malfunction of equipment important to safety.

With respect to the probability of an accident of a different type than analyzed in the FSAR: As discussed earlier, the most severe accident for the condensate/

feedwater system is the LOFW. This accident has already been evaluated in the FSAR. The addition of the condensate polishing demineralizer system does not create the possibility for a different type of accident.

With respect to the possibility of malfunction of a different type than any analyzed in the FSAR: For the reason discussed in 2.a above, the addition of condensate polishing demineralizer system would not create the possibility of a malfunction of a different type than considered in Chapter 14 of the FSAR.

With respect to the margin of safety as defined in the basis for any Technical Specification: The addition of the condensate polishing demineralizer system would not decrease any margin of safety discussed in the Facility Technical Specifications.

Conclusion For the reasons discussed above, addition of the condensate polishing demineralizer system does not involve an "unreviewed safety question" as defined in 10 CFR 50.59 (a) (2). The planned addition of the condensate polishing demineralizer system has also been reviewed against the Facility Technical Specifications. The addition of the condensate polishing demineralizer system does not require a change to Facility Technical Specifications.