ML17345B037
| ML17345B037 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/29/1983 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML17345B036 | List: |
| References | |
| NUDOCS 8304060621 | |
| Download: ML17345B037 (16) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION TURKEY POINT PLANT UNITS 3 AND 4 JUSTIFICATION FOR CONTINUED OPERATION UNQUALIFIED ELECTRICAL EQUIPMENT INTRODUCTION The s'taff required that all licensees provide documentation which demonstrates that the safety-related electrical equipment in their plants meet the DOR guidelines; NUREG 0588 or; commit to replace, requalify or other appropriate corrective action.
If a corrective action was indicated, justification for continued operation was required until the corrective action is completed.
Florida Power and Light (FPGL) provided detailed documentation and justifi-cation in their responses to IE Bulletin 79-01B in August 1981, and the staff's initial Safety Evaluation dated tray 21, 1981.
The submittals were reviewed by Franklin Research Center (FRC)'.
As a result of their review, FRC concluded in the Tech~ical Evaluation Report (TER) that FPSL has stated that the equipment items are environmentally qualified; or has provided a technically sound rationale as a basis for justification for continued plant operation; or has provided a technically sound rationale or other additional information which in FRC's judgment provides a basis for justification for continued operation.
These conclusions were valid while the staff and FRC were continuing their review and evaluation.
- However, upon completion of the effort and the issuing of the Safety Evaluation dated December 13, 1982, for Turkey Point 3 and 4, it became necessary to reassess all electrical equipment items in TER Categories I.B, II.Aand II.B.
830406062i 830329 PDR ADOCK 05000250 P
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This Safety Evaluation addresses the six ('6) items included in the TER, Table 4-1, Item II.B -.Equipment Not qualified.
FP&L's initial response dated February 2, 1983, indicated that the necessary justification was provided in their previous submittals.
- However, based on subsequent discussions clarifying the applicability of Appendix D, FP8L provided justification in their letter dated March 1, 1983.
EVALUATION CRITERIA The recently enacted regulation on environmental qualification, 10 CFR 50.49, "Environmental gualification of Electrical Equipment Important to Safety for Nuclear Power Plants," provides the appropriate guidelines for justification for continued operation.
These guidelines are included in paragraph (i) of 10 CFR 50'9.
The necessary elements to be considered, where appropriate, are:
(1)
Accomplishing the safety function by some dysignated alternative equipment W
if the principal equipment has not been demonstrated to be fully qualified.
(2)
The validity of partial test, data in support of the original qualification.
(3) -'Limited use of administrative controls, over equipment that has not been demonstrated to be fully qualified.
(4)
Completion of the safety function prior to exposure to the accident environment resulting from. a design basis event and ensuring that the subsequent failure of the equipment does not degrade any safety function or mislead the operator.
(5)
No significant degradation of any safety function or misleading information to the operator as a result of failure of equipment under the accident environment resulting from a design basis event..
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EVALUATION The TER identified six (6) equipment items in the.II.B Category as being not qualified.
The item numbers are:
39, 40, 42, 46, 47, and 50.
For each of these equipment items FP8L provided:
Equipment type Identification Number Function Analysis of 'Loss of Coolant Accident (LOCA) and High Energy.Line Break (HELB)
Safety Conclusion Item. 39:
Flow Transmitter Fischer and Porter Mod.
10B2496PBBABBBNS Safety Injection (SI) Flow to Hot Leg FT-3-932',. 933 and FT-4-932, 933 Required Operating Time 31 days The information provided by these transmitters is used to verify flow to the hot legs which is not required until 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after a
LOCA.
Additional flow transmitters located outside of containment (not exposed to the accident) which provide inputs to the plant computer are available for flow information which can be read in the control room.
These instruments are not required for an HELB.
The redundant transmi,tterswhich are not exposed to the harsh environment provide alternative equipment for providing the necessary information to the operator.
This is in accordance with the guidance provided in 10 CFR 50.49(i)..
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Item 40 Flow Transmitter Fischer and Pol.ter,Mod.
10B2496 PBBABBBNS Steam Flow Main Steam Line FT-3-474, 475, 484, 485, 494, 495, and FT-4-474, 475, 484, 485, 494, 495 Required Operating Time 1 min These instruments provide inputs to the protection logic for HELB events and are not required for a LOCA.
As indicated the maximum required operating time is one (1) minute and redundant instruments which are spacially separated are provided on each-of the steam genera'tors.
Therefore, it is likely the instruments would provide their automatic signals to. the protection logic prior, to a potential failure.
The signals provide automatic isolation to the steam generator which has the failed high energy line.
However, if the automatic isolation of the steam generator did not occur, the steam generator pressure indication. is available'o the operator in the control room which will enable determination of the faulted steam generator.
The operator can manually isolate the faulted steam generator and align the auxiliary feedwater to the intact generators.
The short required operating time (maximum of one minute) coupled with separate redundant instruments provides reasonable assurance the protective function will occur prior to a potential failure of. the instruments. " In addition, information is available to the operator from qual'ified instruments to perform necessary actions leading to recovery from the event.
These are in accordance with the.
guidance provided in 10 CFR 50.49(i).
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Item 42 Level Transmitter Fischer and Porter Mod.
1302495K BBABBBNS Steam Generator Mater Level LT-3-474,475, 476, 484, 485, 486, 494, 495, 496, and LT-4-474, 475, 476, 484', 485, 486, 494, 495, 496 Required Operating Time:
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> These instruments provide inputs to the protection logic for HELB events and are not required for a LOCA.
The automatic function of these instruments will be performed within minutes of an, HELB.
Redundant instruments which are spacially separated are provided on each of the steam generators.
Therefore, it is likely that the instruments would provide their automatic signal's to the protection logic prior to a potential failure.'edundant and diverse signals to the protection logic are provided for an HELB such as high containment
- pressure, high neutron flux or low pressurizer pressure in addition to the steam generator
.level inputs.
Loss of'he steam generator level indication:will not preclude accident recovery.
The reactor coolant system temperature is lowered during blowdown and the intact steam generators can be filled until the coolant temperature is 350'F and the RHR system placed in operation.
The short required operating time (approximately one minute) coupled with separate redundant instruments provides reasonable assurance the protective function will occur prior to
- a. potential failure of the instruments.
In addition, information is available to the operator from qualified instruments to perform necessary actions leading to recovery from the event (see items 40 8 46).
These are in accordance with the guidance provided in 10 CFR 50.49(i).
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Item 46 Pressure Transmitter Fischer and Porter Mod.
50EP1041 BCXANS Pressurizer Pressure Input to SI PT-3-455, 456, 457, and PT-4-455,
- 456, 457 Required Operating Time:
1/2. hour These instruments provide inputs to the protection logic for both LOCA and HELB.
The automatic function of these instruments will be performed within a minute.for either a
Diverse protection is provided, by the high containment pressure signal for both events.
Monitoring the pressurizer pressure is not required following a LOCA.
Following an HELB the reactor coolant system pressure can be determined by several means.
The SI system will repressurize the system at 1350 psig until level is restored in the pressurizer.
In addition, pressure can be determined by. aligning gauges in the sample system or pressurizer temperature can be used to determine pressurizer saturation pressure.
The short time required for the automatic actuation coupled with separate redundant instruments provides reasonable assurance that the protective function will occur prior to potential failure.
In addition, diverse protection is provided by the high containment pressure.
System pressure can be determined by various means subsequent to an HELB.
These are in accordance with the guidance provided in 10 CFR 50.49(i).
Item 47 Pressure Transmitter Fischer and Porter Mod EP1041BCXANS Reactor Coolant Pressure Monitor and.Interlock To MOV-3-750 and MOV-4-750 PT-3-403 and PT-4-403 Required Operating Time ".
31 days
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These instruments provide the low pressure permissive signal to the Residual 1
Heat Removal system'RHR).
The RHR system is only required subsequent to an HELB.
The RHR system is riot required until a significant time after an HELB.
The permissive block can be overridden in the control logic thus allowing opening of the valves and the necessary forced flow cooling via the RHR system.
These instruments provide no automatic function during the initial phase of an HELB.
Their low pressure/high pressure protective function can be over-ridden if necessary for long term cooling.
System pressure can be determined as stated in Item 46.
This is in accordance with the guidance provided in 10 CFR 50.49(i).
Item 50 Pressure transmitter Rosemount Model 1153 Subcooling Marg.n Monitor Input PT-3-404, 406 and PT-4-404, 406 Required Operating Time 31 days The instruments are used to provide information to the operator of the margin to saturation in the reactor coolant system as an aid to the operator during recovery from an HELB.
As previ'ously indicated there are several means of determining system pressure.
The system pressure can be maintained above saturation by use of the pressurizer heaters.
The instruments provide information to the operator post event and several alternative means are available to verify the reactor coolant system pressure.
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This is in accordance with the guidance provided in 10 CFR 50.49(i).
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CONCL'US ION-In addition to the considerations above,. the licensee has indicated during
,,discussions that the l.icensed operators, have been, provided written notifi-cation and are aware of the potential instrument. failures, required actions and alternatives available.
Based on our review, we have: concluded that:
(1) the justification for continued, operation provided-.by FPEL for Turkey Point 'Units 3 and, 4 for the
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items identified in Category. II.B is in accordance with: the guidance provided in 10 CFR 50.49(i) and (2) reasonable assurance exists that the plant can be.
operated in a safe manner pending testing,',replacement or other corrective action which is acceptable to the staff.
Date:
MAR 2 9 1993 Princi pie Contributor,:
Daniel G. 'McDonald
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