ML17341B121

Forwards Response to Generic Ltr 82-05, Post-TMI Requirements.

ML17341B121
Person / Time
Site:	Turkey Point
Issue date:	04/27/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.3.1, TASK-2.B.2, TASK-2.B.3, TASK-2.B.4, TASK-2.E.4.2, TASK-2.F.1, TASK-2.K.2.10, TASK-2.K.3.15, TASK-2.K.3.19, TASK-2.K.3.22, TASK-2.K.3.24, TASK-2.K.3.27, TASK-TM GL-82-05, GL-82-5, L-82-175, NUDOCS 8205040622
Download: ML17341B121 (9)

Text

REGUL RY INFORMATION DISTRIBUT SYSTEM (RIDS)

,ACCESSION NBR:8205040622 DOC ~ DATE: 82/04/27. NOTARI'ZEO! YES, DOCKET FACIL:50"250 Turkey Point Planti 'Unit 3i Florida Power and Li'ght C

'50"251 Turkey Point Plantr 'Unit 4i Florida 'Power and Light BYNAME 'C 05000251 AUTH AUTHOR AFFILIATION UHRIGr R ~ E ~ Florida Power 8 Light Co, RE'C I'P ~ NAME RECIPIENT AFFILIATION EISENHUTiO ~ G ~ Division of Licensing

SUBJECT:

Forwards response Requirements' to Generic Ltr 82 05< "Post,TMI DISTRIBUTION "CODE: A046S COPIES iRECEIVEDSLTR ENCL SIZE:, .

TITLE: Response to NUREG "0737/NUREG-0660 TMI Action iPlan Rgmts (OL's)

NOTES:

REC IP IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAPE LTTR ENCL ORB Pi BC 01 7 7 INTERNAL: ELD 1 0 IE/DEP OIR 33 1 1 IEIDEP EPDS 1 IE/DEP/EPLB "3 3

NRR/DE D IR 21 1 1 NRR/DE/AOCSE 22 1 NRR/DE/ADMQE 23 1 1 NRR/DE/ADSA 17 1 1 NRR/DHFS 0 IR 28 1 NRR/DHFS/OEPY29 1 1 NRR/DL D IR 14 1 1 NRR/DL/ADL 16 1 NRR/DL/ADOR 15 1 1 NRR/DL/ORAB 18 3 NRR/DSI ADRS 27 1 1 NRR/DSI DIR 24 1 1 NRR/DSI/AOP8 25 1 1 NRR/DS I/ADRP 26 1 1 NRR/DSI/AEB 1 1 NRR/DS I/ETSB 1 1 NRR/DS I/RAB 1 1 NRR/DST OIR 30 1 1 NRR/DST/ADGP 31 1 1 NRR/DST/AOT 32 1 00 1 RGN2 1 1 1'0 EXTERNAL: ACRS 34 10 FEMA>>REP OIV 1 1 INPOiJ ~ STARNES 1 1 LPDR 03 1 1 NRC PDR 02 1 NSIC 05 1 1 NTIS 1 1 TOTAL NUMBER OF 'COPIES REQUIRED: LTTR 53 ENCL .52 f

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>WCTU FLORIDA POWER tk LIGHT COMPANY April 27, 1982 L-82-175 Office of Nuclear Reactor Regulation Attention:. Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 APE]~

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Dear Mr. Eisenhut:

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Re: Turkey Point Units 3 8 4 Docket Nos. 50-250 and 50-251 Post-TMI Requirements O Generic Letter No. 82-05 This letter transmits to you our response to Generic Letter No. 82-05. All items applicable to Turkey Point Units 3 8I 4 that are listed in Enclosure 1 of the generic letter have been addressed.

Very truly yours,

.A.N

.Robert . Uhrig Vice President Advanced Systems and Technology REU/PKG/mbd Attachment cc: Mr. James P. O'Reilly, Region II Harold F. Rei s, Esquire 8205040b22 820427 PDR .ADOCK 05000250, P, PDR .. '-- -! PEOPLE... SERVING PEOPLE I

ATTACHMENT Re: Turkey Point Units 3 5 4 Docket Nos. 50-250 and 50-251 Post-TMI Requirements Generic Letter No. 82-05

1. SIMULATOR EXAMS I.A.3.1 Simulator exams have been included as part of the licensing examinations for senior reactor operators and reactor operators. This has been in effect prior to the required date of October 1, 1981. A tentative examination schedule was sent to l1r. Paul. F. Collins in letter L-81-446 dated October 13, 1981 as a response to Generic Letter No. 81-29.

2. PLANT SHIELDING I I.B.2 I

The schedule we provided you in letter L-82-5 dated January 7, 1982 is

'revised such that all modifications will be completed by June 4, 1982 with the following exceptions shown below that were previously identified. The replacement of air operated valves CV-2819 and CV-2826 at Unit 3 with qualified valves will be completed during the next available outage of sufficient duration following receipt of the valves. The same situation exists at Unit 4 but the valve change out will occur prior'to startup from the Unit 4 steam generator repair outage.

(a) JUSTIFICATION OF PROPOSED SCHEDULE All of the items needed for implementation had promised delivery dates no later than November 1981. The actual or currently promised delivery dates are listed below:

Radiation shielding doors - Received March 25, 1982 Reach rods - Partially received - February 27, $ 982 and March 18, 1982 Final shipment received March 29, 1982 Air operated valves - Promised ship date August 31, 1982 Plug Valve Received April 5, 1982 Lead Bricks Promised ship date April 13, 1982 Control panel (for doors) - Promised ship date April 7, 1982 (b) Demonstration of need for ro osed schedule With the late delivery of equi,pment shown in (a) above, there is approximately two months worth of construction effort required to canpl ete thi s i tan.

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(c) Description of Compensatory Measures Being Taken in the Interim The modifications are being completed as rapidly as possible.

3. POST ACCIDENT SAMPLING CAPABILITY II.B.3 In our letter L-82-5 dated January 7, 1982 we stated that it was our intent to have the Post-accident Sampling System installed and operable prior to the Turkey Point Unit 3 startup from its steam generator repair outage which has just recently ended. It is our intent (based on the justification provided below) to have the system installed by June 4, 1982 with startup testing scheduled for completion on July '2, 1982 with the following exception which we have previously identified to you. The replacement of the existing Unit 4 automatic sample valves will be completed at the next scheduled outage of sufficient duration. This does not effect the operability of the system, only the qualification for performing in the post accident environment.

(a) Justification of roposed schedule A strike by Milton Roy Corp., a subvendor to Applied Physics Technology, was the major delay in finalizing vendor drawings to our Architect-Engineer (Bechtel Power Corp.). This delayed the final engineering of the system within the proposed room.

Specifically affected were final layout, shielding design, and the ordering of cable trays.

The following items are presently on order:

Cable Trays Promised ship date April 30, 1982 Lead Bricks Promised ship date April 13, 1982 Steel Plate - Promised ship date April 12, 1982 Microprocessor for Chloride analysis - on indefinite hold.

NOTE: Manufacturer (Orion) has operabi,lity problems.

Grab Samplers - Promised ship date May 15, 1982 (b) Demonstration for Need for Pro osed Schedule With the late delivery of equipment shown in (a) above, there is approximately two months worth of construction effort required to complete this iten.

(c) Description- of Com ensatory Measures Bein Taken in the Interim In letter L-80-16 dated January 11, 1980 we briefly di scussed that appropriate plant procedures had been revised to describe methods which could be used to obtain RCS samples after an accident using existing facilities. The NRC "Evaluation of Com ance withli Cate ory "A" Lessons Learned Re uirements for Turkey Point 3 8 4 ate pri , 980 oun ,t at ur ey oint was in compliance with the lessons learned requirements for post-accident sampling.

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4. TRAINING FOR MITIGATING CORE DAMAGE II.B.4 The training program we discussed in letter L-81-183, dated April 28, 1981 was completed as required prior to October 1, 1981. We previously informed you of this status in our 'letter L-82-5 dated January 7, 1982.

5. AUXILIARY FEEDWATER SYSTEM AUTOMATIC INITIATION,AND FLOW INDICATION II.E.1.2 A. AUTOMATIC INITIATION OF AFW The as-built system is safety grade. We had previously identified to you that the actuation of the pressure regulating valves. for steam supply to the AFW pump turbines is not designed in accordance with single failure criteria. These valves are scheduled to be removed at the same time the long term modifications (new turbines, redundant piping) are installed during the Unit 4 steam generator repair outage.

B.'FW FLOW INDICATION The modifications for safety grade, redundant, AFW flow indication have been completed for both Turkey Point Units 3 and 4. As we stated in letter L-82.-5, dated January 7, 1982, the power supplies for the flow indication, and flow control were not environmentally or seismically qualified. Modifications to the qualified power supplies have been installed in Unit 3 and will be installed in Unit 4 during the next scheduled outage of sufficient duration.

These modifications are themselves in the process of being qualified at the present time.

6. CONTAINMENT ISOLATION DEPENDABILITY I I. E.4.2

'ART 5

A Safety Evaluation Report enclosed in a letter from S.A. Varga to R.E.

Uhrig dated August 31, 1981 concluded that the requirement of Item II.E.4.2(5) of NUREG-0737, with additional guidelines developed by the staff, have been met for the Turkey Point Units. We told you in letter L-82-5 dated January 7, 1982 that we considered this item closed with no modifications necessary.

PART 7 The containment purge and vent valves close upon receipt of a containment high radiation signal. This fact was submitted to you in letter L-80-39 dated January 31, 1980.

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7. NOBLE GAS MONITORS/IODINE PARTICULATE SAMPLING II F,l.l AND II.F.1.2 As we stated in our letter L-82-93 dated March 15, 1982, all five of the effluent monitors are completely installed and operable. Each has been tested and calibrated. Installation was completed ori January 1, 1982 and calibration completed on March 5, 1982. It is our intent to have operating procedures written by May 17, 1982. As previously stated in our letter L-82-5 dated January 7, 1982, the plant vent effluent monitor may require additional modifications to provide isokinetic sampling. Any needed modifications will be scheduled when the extent of the modifications, if any are known.

8. CONTAINMENT HIGH RANGE RADIATION MONITOR II.F.1.3)

The redundant containment high range radiation monitors were installed in Turkey Point Unit 4 on December 18, 1981 with startup testing completed and the system operable by January 17, 1982.. In situ calibration of both channels by means of a calibrated radiation source will be completed during the next scheduled outage of sufficient duration. In situ calibration by electronic signal substitution was made for the high ranges of this monitor.

The redundant monitors for Unit 3 were completed by March 15, 1982.

Calibration of the monitors in accordance with the requirement of NUREG-0737 Item II.F.1.3 have been completed for Unit 3.

(a) Justification of .Proposed Schedule The additional calibration, of the Unit 4 monitors requires containment entry. For health physics reasons, the high range source calibration of both channels are best performed during a plant outage.

(b) Demonstration of Need for Proposed Schedule See (a) above.

(c) Description of Com ensator measures bein taken in the Interim The Unit 4 monitors have already been calibrated at the high range with the electronic signal substitution. Llhen the calibration using the calibrated radiation source at Unit 3 was compared to the calibration using electronic signal substitution (at lower

'ange), there was good agre@vent between the two. The same correlation should hold for Unit 4.

9. CONTAINMENT PRESSURE MONITOR II.F.1.4 The high pressur e portion of the system for both Turkey Point Units 3 and 4 were operational by March 25, 1982. The vacuum range portion is scheduled to be completed by June 30, 1982.

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(a) Justification of Pro osed Schedule The vacuum range transmitters were originally added to a Westinghouse purchase order. Many months later, Westinghouse informed FPL that they could not supply the transmitters. FPL then went to Rosemount and received a commitment for tr ansmitters. This delivery date is presently scheduled for May 24, 1982. Installation, calibration,'nd startup loop testing should be completed by June 30, 1982.

,(b) Demonstration of need for proposed schedule J

The completion date is'based on vendor delivery. If the delivery is improved or slipped, implementation will move accordingly.

(c) Description of Compensatory measures being taken in the interim The high pressure portion of the system which is installed is the most useful part of the system in a potential accident situation. Compensatory measures are not necessary for the vacuum portion. *

10. CONTAINMENT WATER LEVEL MONITOR II.F.1.5 The redundant containment water level monitors were installed and operational in Turkey Point Unit 4 by January 1, 1982. Both trains of the Unit 3 monitors were completed as of March 27, 1982.

11. CONTAINMENT HYDROGEN MONITORS II.F. 1.6 It is scheduled that installation be complete by June 4, 1982 wi th the exception of heat tracing (including controllers and transformers) for the sample line from the containment to the H~ monitors. The scheduled shipping date from the vendor is June 30, 1982. We expect to have the heat tracing installed by August 16, 1982. Startup testing and calibration is scheduled for completion by July 2, 1982. It should be noted that the absence of heat tracing will affect the accur acy of the monitors during certain accident conditions.

(a) Justification for ro osed schedule The "A" Train monitors will be physically located in the same room as the Post Acci'dent Sampling System. Thus, the delays described under "Justification" in II.B.3 are common to this item. . The "8" Train monitors are presently installed (except for heat tracing) and turnover from construction is in progress.

(b) Demonstration of need for roposed schedule Same reasons as described under. Item II.B.3.

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(c), Desciiption of Compensatory Measures being Taken in Interim The necessary sampling and analysis of containment atmosphere hydrogen concentration can be performed using exi'sting nuclear chemistry procedures, NC-53, "Sampling and Analysis of Containment Atmosphere for Preparation and Documentation of Instrument

'leedline and Contaiaoent Purge Releases" and NC-94, "Determination of Percent Gas Concentrations (Chromomapography)".

12. TECHNICAL SPECIFICATIONS NUREG-0737 identifies the following items that are applicable to Turkey Point Units 3 5 4 addressed in enclosure 1 of Generic Letter No. 82-05 as requiring the submittal of technical specifications: II.B.3, II.E.1.2, II.E.4.2(7) and II.F.1. 1 through II.F.1.6.

In letter L-82-93 dated March 15, 1982, we stated that it is our intent to submit all of the required Item II.F. 1 technical specifications in a single submittal following the complete installation and determination of OPERABILITY of all the monitors. It is still our opinion that a single technical specification submittal of all item II.F.1 monitors will be more efficient and will eliminate repetitive reviews by both your staff and ours. It is also our intent to submit any required technical specifications for item II.B.3 at that time. We are currently reviewing items II.E.1.2 and II.E.4.2(7) to determine what technical specifications if any are appropriate.

13. NON-APPLICABLE ITEMS The following NUREG-0737 items identified in Generic Letter 82-05 are applicable to either BSW plants or BWR's and are not applicable to Turkey Point Units 3 8 4.

II.K.2.1'0, II.K.3.15, II.K.3.19, II.K.3.22, II.K.3.24, II.K.3.27 6of 6

STATE OF FLORIDA )

) ss COUNTY OF DADE )

being first duly sworn,, deposes and says.

That he is Manager, Nuclear Licensing ~

of Florida Power Light Company, the herein That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that, he is

,authorized to execute the document on behalf of said J. A. Det1astry Subscribed and sworn to before me this

~~~day of 19 Q~

'NOTARY'UBLIC, and fo the County of Dade, Stake of Florida Large Notary public, Stato of Florida at 1983 Cornmhsion fxpires October 30, My y C mmiS>>On eXpireS- tbru Mayrrad Bo drr A y