ML17345A698

Discusses Integrated Schedule Category a Items,Per 860812 Confirmatory Order.Remaining Items to Be Performed Include, Air Start Motor Upgrade & Select Sys Walkdown Nonconformance Repts on P&Ids

ML17345A698
Person / Time
Site:	Turkey Point
Issue date:	05/18/1989
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-89-187, NUDOCS 8905260185
Download: ML17345A698 (11)

Text

. ACCELERATED DI~BUTION 'EMOYSTP+OY SYSTEM j

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 8905260185 DOC. DATE: 89/05/18 NOTARIZED: NO DOCKET N FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION WOODY,C.O. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Discusses integrated schedule Category A times,per 860812 confirmatory order.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1

-EDISON,G 5 5 INTERNAL: NRR/DEST/ADS 7E 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/RSB 8E 1 1 NRR/DOEA/TSB 11 1 1 NUDOCS-ABSTRACT 1 . 1 OC FM 1 0 OGC/HDS2 1 0 G FILE 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 S

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D NOIR 'I0 ALL "RIDS" RECIPIENIS:

S PIZASE HELP US 'IO REDUCE MAli~! CXNI'ACT 'IHE DOCGMEÃZ CONIRBL DESK ROOM Pl-37 (EXT. 20079) K) ELIMINATE YOUR NAME FRY DISTJGBVZIQN LISTS FOR DOCUMENIS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR '2 ENCL 20

P.O. Box14000, Juno Beach, FL 33408-0420 L-89-187 MAYi 1 8 1989 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inte rated Schedule Cate or A Items Florida Power 6 Light Company's (FPL) Turkey Point Units 3 and 4 are the subject of a Confirmatory Order dated August 12, 1986.

This order required FPL to complete the Select Systems review discussed in FPL letters L-86-112,,dated March 19, 1986, and L 197 dated May 19, 1986. The remaining items to be performed under this review are included in the Turkey Point Integrated Schedule (I/S) ~

I/S Mod No. 576, "Air Start Motor Upgrade", and I/S Mod No. 1098, "Select System Walkdown NCRs on PGIDs", will not be completed by the dates indicated in the current I/S. I/S Mod No. 576 will be completed during the Unit 3 Diesel Tie-In/Unit 4 Cycle 13 refueling outages currently scheduled to begin the fall of 1990. I/S Mod 1098 will be completed by December 29, 1989. Since these modifications are Category A Items, NRC approval is required prior to revising their schedules. FPL had previously requested NRC approval to change the schedule for I/S Mod No. 576 (FPL letter L-89-91 dated March 9, 1989).

The scope for I/S Mod No. 1098 was defined in FPL letter L-86-112 dated March 19, 1986 (see Attachment 1). A listing of the nonconformance reports (NCRs) generated by the walkdowns by system and a status of their disposition are included in Attachments 2 and 3 respectively. FPL is working to complete disposition of the remaining NCRs and preparing changes to affected drawings, data bases, and other plant documents using the DEEP (Design Equivalent Engineering Package) process. Use of the DEEP process involves an increase in scope resulting in the need for additional time to complete the project. In addition, the implementation of the drawing redlining effort during the fall of 1988 and winter of 1989 8905260185 890518 PDR ADOCK 05000250 p PDC oo(

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U. S. Nuclear Regulatory Commission L-89-187 Page two were deemed a higher priority on the engineering and drawing resources available to perform I/S Mod 1098. A schedule for issuing the DEEP packages to the site for approval is included in . Use of the DEEP process and the reverification walkdowns associated with the NCR resolutions will ensure that affected drawings and plant documents are identified as part of this program (not just PAID's), and that the P&IDs associated with the 16 select systems will be reflective of the as-installed, as-designed field conditions. Delay in completion of this project to December 29, 1989 will have no safety or operational impacts. Each of the NCRs was reviewed for safety and operability concerns within three days of engineering receipt of the NCRs generated by the walkdowns. No safety or operability concerns were identified.

As previously stated in FPL letter L-89-91, I/S Mod No. 576, the addition of a second emergency diesel generator (EDG) air start motor, was one of several modifications FPL evaluated with the intent of improving EDG reliability in response to Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability" (FPL letter L-84-316 dated November 6, 1984) and also NUREG CR/0660, "Enhancement of On-Site Emergency Diesel Generator Reliability." This modification was identified as a Select System (I/S Category A) item in FPL letter L-86-527 dated December 23, 1986. FPL had requested an extension to the scheduled completion date to coincide with completion of the Emergency Power System (EPS) Enhancement Project. This extension would allow consideration of the lessons coming out of the EPS project such as installing larger air tanks and a different instrumentation scheme for increased reliability, and to permit consideration of plant comments regarding maintainability, operability and reliability.

As stated above, the proposed modification is to enhance reliability and not resolve operability or safety concerns. The requirements for operability are clearly defined in the plant technical specifications, and surveillance testing is performed to ensure that the EDGs meet those requirements. Therefore, delay in completing this modification will not impact plant safety.

t NRC approval is requested prior to the Unit 4 return to power currently scheduled for May 25, 1989.

U. S. Nuclear Regulatory Commission L-89-187 Page three Should there be any questions regarding either modification, please contact us.

Very truly yours, Acting nior Vice President Nuclear COW/TCG/gp Attachments cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant

ATTACHMENT I BASIS OF THE ORIGINAL NRC COMMITMENT REGARDING PAID VERIFICATION NCR' VE lflC*TI PEOPLE: FPL CONSTRUCTION Q.C. INSPECTORS PROCESS: " MALKDOMNEXISTING PIPING SYSTEMS DENOTING ANY DIFFERENCES FROM P. 8a I.D. DRAMINGS ANO EXISTING FIELD CONDITIONS FOR SELECT SYSTEMS.

~ PROCEDURES )SSUED

~ VERIFICATION 'MILL REFLECT THE FOLLOWING ATTRIBUTES:

- VALVES, PUMPS 4 MECHANICALEQUIPMENT AGREE M)TH THE P. 8a I.O. FOR PROPKR LOCATION, DESIGNATION ANO POSITION.

- IN-LINE EQUIPMENT AGREK M)TH P. L I.D.

- INSTRUMENTATION IS TAGGED AND LOCATED PROPERLY

- EVERYTHING IS INSTALLED IN SYSTEM THAT IS SHOMN ON P 8c I.D. AND CONVERSKLY EVERYTHING IN THE SYSTEM IS SHOMN ON P. 5 'I.D.

" MARKED UP P 5, I.D.'S ARK TRANSMITTKOTO SITE ORAMING UPDATE FOR PROCESSING.

+ ORAMING/AS-BUILTCONFL)CTS MILLBE AOORKSSKO ON

• S-BUILTVERIF )CAT)ON REQUEST TO ORAM)NS UPOATE FOR REVIKM/ACTION.

~ NON-CONFORMANCE CONDITIONS SUCH AS BROKEN/DAMAGED EQUIPMENT, CABLES, ETC. MILLBK OOCUMENTKD FOR DISPOSITION PROOUCT: " CORRECTION OF DISCREPANCIES

.< AS-BUILT PS )0's

~

ATTACHMENT 2

'CR DISTRIBUTION BY SYSTEM 68 Verification NCR's Generated from the P&ID Walkdowns Address the Following 16 Systems (the number in paranthesis indicates the total number of NCR's written against that system - both units considered)

Select Safet S stags Other Safet S tees Non-Safet -Related S stems Intake Cooling Water (2) Chemical 5 Volume Turbine Plant Cooling Control (6) Water (2)

Component Cooling Water (19)

'ain Steam Isolation (3) Instrument Air System (11)

Safety Injection Breathing Air System (1)

System (7)

Residual Heat S/G Blowdown (1)

Removal (5)

Condensate Recovery (1)

Auxiliary Feedwater (5)

Primary M/U Water (1)

Containment Isolation (2) SWLU and S/G WLU (1)

Chemical Injection (1)

ATTACHt1ENT 3 HCR DISPOSITINING STATUS Total NCR's required for Engineering corrective action: 68 Status of safety/operability reviews for all 68 NCR's: 100% complete NCR's dispositioned by Engineering for corrective action (pre-DEEP era): 47(69%)

NCR's dispositioned by Engineering for corrective action (post-DEEP era): 12 (18K)

Other NCR's dispositioned by Engineering (post-DEEP'era without formal transmittal to Turkey Point site): 3 (4X)

Total number of NCR's with interiim disposition by Engineering: 62 (91%)

Total number of NCR's yet to be. dispositioned (all of those

, remaining NCR's are within the Instrument Air System): 6 (9X)

NOTE: The total number of non-conformance items can be estimated at approximately 25 items per NCR or roughly 1700 items (total).

ATTACHNENT 4 SCHEDULE FOR ISSUING DEEP PACKAGES FOR PAID MALKDOWN NCR's Status or A roximate Tota1 Number of NCR's J ssue Date to the DEEP Pk . No./Select S stea Addressed in the DEEP Site for A royal 1/NSIS 3 Issued week of 5/8/89 2/CVCS 6 5/19/89 3/RHR 5 5/22/89 4/TPCW 2 5/25/89 5/ICW 2 5/25/89 6/Chem In). 1 5/25/89 7/CCW 6 5/29/89 8/CCW . 3 6/12/89 9/CCW 5 6/12/89 10/SIS 7 7/15/89 1 1/AFWS 5 7/31/89 12/CCW 5 7/31/89 13/Stm Gen 1 7/31/89 14/IAS 5 7/31/89 15/SGWLU 1 8/15/89 16/IAS 3 8/31/89 17/IAS 3 8/31/89 18/Niscellaneous 5 8/31/89 NOTES (1) Final NCR d$ spos$ t$ ons to be developed following completion of all DEEP activities and issued for eventual closeout by Site gC by October 1, 1989 (2) Drawing Update activities resulting from the issuance of the above packages shall be completed by December 29 1989.