ML17345A992

Forwards Responses to Generic Ltr 82-28 Re Inadequate Core Cooling Instrumentation Sys for Facilities.W/Nine Oversize Drawings.Aperture Cards Are Available in PDR

ML17345A992
Person / Time
Site:	Turkey Point
Issue date:	03/10/1983
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML17345A993	List: ML17345A992 ML17345A994 ML17345A995 ML17345A996 ML17345A997 ML17345A998 ML17345A999 ML17345B000 ML17345B001 ML17345B002 ML17345B003 ML17345B004 ML17345B005 ML17345B006
References
GL-82-28, L-83-135, NUDOCS 8303160267
Download: ML17345A992 (79)

Text

REGULATOR VFORMATION .DISTRIBUTION S EM (RIDS)

AGCESSION NBR:8303160267 DOC ~ DATE: 83/03/10 NOTARIZED: YES DOCKET

'FACIL;50 250 Turkey Point Planti Unit 3i Florida Power and Li'ght 'C 05000250

'50-251 Turkey Point Planti Unit 4r Florida Power and Light C 05000251 AUTH'AME AUTHOR AFFILIATION UHRIGtR ~ ED Florida:Power 8 Light Co ~

'REC IP NAME

~ RECIPIENT AFFILIATION EISENHUTpD G. ~ Division of Licensing SUBJECT.: Forwards responses to Generic Ltr 82-28 re i.nadequate core cooling instrumentation sys for facilities,h'/nine oversize drawings. Aperture cards =-are .available in 'PDR ~

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DISTRIBUTION ~CODE A002S <<COPIES RECEIVED:LTR TITLE: OR Submittal' Inadequate <<Core

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FLORIDA POWER & LIGHT COMPANY March 10, 1983 L-83-135 Office of Nuclear Reactor Regulation Attention: Mr. Oarrell G. Eisenhut, Director Divi sion of Licensing U. S. Nuclear Regulatory Commission

!Aashington, D. C. 20550

Dear Mr. Eisenhut:

Re: Turkey Point Units 3 8 4 Docket No. 50-250 & 50-251 Post-TMI Requi raIIents Inadequate Core Cooling Instrumentation System Response to Generic Letter 82-28 Please find attached our response to Generic Letter No. 82-28 concerning the Inadequate Core Cooling Instrumentation System for Turkey Point Units 3 and Please note that there is a separate document attached for each unit because the ICCS systems are on different schedules of implementation.

Very truly yours, Robert E. Uhrig Vice President Advanced Systems 5 Technology REU/PKG/js Attachments cc: Mr. James P. O'Reilly, Region II Mr. Harold F. Rei s, Esquire P NS-L I 174-1 8303160267 830310 PDR ADOCK 05000250 PDR PEOPLE... SERVING PEOPLE

>HEATED 3UNCTION THERMOCOUPLE: PHASE III TEST REPORT," 3UNE, 1982, COMBUSTION ENGINEERING, INC.

5. CEN-181-P, "GENERIC RESPONSES TO NRC QUESTIONS ON THE C E INA'DEQUATE CORE COOLING INSTRUMENTATION~

SEPTEMBER, 1981, COMBUSTION ENGINEERING, INC.

6. CEN-152 Rev. 1, "CE EMERGENCY PROCEDURE GUIDELINES",

NOVEMBER, 1982

7. FPL SUBMITTALTO NRC DATED JANUARY 7, 1982 (LETTER L-82-5)

8. FPL SUBMITTALTO NRC DATED 3UNE 25, 1981, (LETTER L-81-263)

9. FPL SUBMITTAL TO NRC DATED DECEMBER 26, 1980, (LETTER L-80-019)

10. FPL SUBMITTALTO NRC DATED MARCH 10, 1980 (LETTER L-80-79)

11. FPL SUBMITTALTO NRC DATED 3ANUARY L-80-16) ll, 1980 (LETTER NOTE: References 1 through 6 have been submitted to the NRC by the CE owner's group.

il 0 g, ~ I Page 5 of 15 3.0 RESPONSES TO NRC RE UEST NO. 1 GENERIC LETTER NO. 82-28 The following discussion covers the ICCS asked for in Request No. 3 as well as the RCIS. Identification of the Reactor Coolant Inventor S stem (RCIS) Selected for Turke Point Plant Unit 3. The Combustion Engineering's Inadequate Core Cooling System (ICCS) which includes the "Heated Junction Thermocouple System" (H3TC) to detect Reactor Coolant Inventory, was selected for implementation in Turkey Point Plant Unit 3.

2. General Desi n Descri tion of the Inade uate Core Coolin S stem ICCS .

(This description supersedes the generic description of our previous submittal, Reference 8). The ICCS as designed by C.E., is comprised of the following instrument sensor packages for detection of inadequate core cooling: (1) Heated 3unction Thermocouple System (H3TC) as (RCIS). (2) Subcooling Margin Monitor (SMM) Detection System, which comprises hot leg and cold leg RTD's (Resistance Temperature Detectors), and Reactor Coolant System pressure sensors. Core Exit Thermocouple System (CET's). The above instrument sensor packages are inputs'o the Qualified Safety Parameter Display Cabinets (QSPDS), which comprises the sensor processin'g equipment, operator interface equipment, and isolated data link with the Safety Assessment System (SAS). The ICCS instrument sensor packages are described in the CE generic document, Reference 1. The plant specific ICCS inputs are described in the. Data Bases, Attachment 0. The QSPDS is described in the CE generic document, Attachment 1. The plant specific functional design description for the QSPDS is detailed in Attachment 3. Note that the QSPDS for this plant is only used to process the ICCS parameters, and is not a back-up Safety Parameter Display System (SPDS) as described in Attachment 1. I The QSPDS functional design for the display is described in the CE generic document Attachment 2. The plant specific display design for the QSPDS is detailed in Attachment 5. The display system for this plant only includes the ICCS sensor packages as described above. The H3TC sensors are located in part length control rod locations No. 59 and 60, which will be modified in the internals and pressure boundary to accommodate the new H3TC probe assemblies. (See Attachment 10 4 11) 4 lf '( Page 6 of 15 Mineral insulated (MI) cable will be routed in two separate channels from the reactor head to the two redundant electrical penetrations designed for the ICCS inputs. Outside the containment the H3TC sensors will be connected to the two redundant channels of QSPDS processing equipment, with organic cables, routed in two channels. The data link cables will interconnect'he QSPDS cabinet with the display in the Control Room and the Safety Assessment System (SAS). The CET cabling system including connectors will be up-graded to meet containment environmental qualification as required by NUREG-0737. Plant Change Modification packages have been prepared for the installation of the ICCS. These implementation packages include the installation of the QSPDS equipment, electrical penetrations, MI cables inside containment, reactor head and reactor internals modification, interconnecting cables outside containment and Class IE power supply equipment for the-ICCS.

3. Schedule for En ineerin Procurement and Installation of the ICCS a) En ineerin Schedule a-1) The Engineering for the installation of the ICC System is essentially complete.

a-2) The Engineering for the ICC System hardware is essentially complete. Engineering documentation is available upon, request. b) Procurement Schedule All ICCS hardware and software have been purchased. Some equipment has already been delivered to the plant site. The remainder of the equipment will be delivered before the refueling outage, October, 1983. g ~ I 1 ~, Page 7 of 15 c) Installation Schedule The ICCS installation is projected to be completed during the 1983 refueling outage and to be operational by january, 1980 pending delivery of the hardware. The installation of the ICCS involvethe following:

1. Modification of the part length control rods for the H3TC probes. This modification includes reactor internals and pressure boundary modification (Attachment 10 8c 11 and Section 0.0, Note 5).

2. Replacement of the CET's connectors.

3. Installation of the Ml cable for the H3TC system from the two new probe assemblies at the reactor head to the two new electrical penetrations for the ICCS inputs.

Installation of the MI cable for the CET's from the reactor head to the two electrical penetrations. "

5. Installation of the two new electrical penetrations.

6. Installation of the QSPDS cabinets.

7. Installation of the ICCS plasma displays Power Supply and Page Control modules.

8. Installation of interconnecting cab'les outside containment, including communication cables from QSPDS to SAS and displays.

9. The Computer Room for the QSPDS will.be completed by September, 1983.

The system will be, used for operator training purposes until the control room design review and pre-implementation review by NRC is completed. Qualification and test reports, operating procedures, emergency procedures and licensing documentation will be completed before the unit start-up. (See section 3-d below)'. 4t Page 8 of 15 d) Test and uglification Re orts The H3TC test reports are documented in supplements 1, 2 and 3 of CEN-185 (Reference 2, 3 and 0). The QSPDS test is schedule to be completed by 1983 outage. The Ml cable qualifi'cation test report is projected to be completed by September I, 1983. The pressure boundary safety analysis and stress report will be available by the end of the refueling outage. The qualification report for the electrical penetration will be available by the 1983 outage. The qualification report for the complete ICCS will be available by September, 1983. The operating procedure will be addressed in our response to the NRC Generic Letter No. 82-33. l5 ik Page'9 of 15 0.0 RESPONSE TO NRC RE UEST NO. 2 GENERIC LETTER NO. 82-28 STATUS OF CONFORMANCE OF THE ICCS WITH NUREG 0737 SECTION II.F.2 TABLE 1 (Refers to same item number in the Appendix to the the generic letter 82-28) . Item Reference Deviation Schedule ~No. ( ~(Note 3 l.a. CEN-185 (1) No 1) 16081-ICE-3219 Attachment 0 No (Note 2) NPROD-ICE-3201 Attachment No (Note 0) Attachment 3 1'6081-ICE-3218 No (Note 2) NPROD-ICE-3202 Attachment 2 No (Note 2) 16081-ICE-3220 Attachment 5 No (Note 2) CEN-181-P (5) No (Note 1) CEN-185 Suppl. 1 (2) No (Note CEN-185 Suppl. 2 (3) 7,8and9.'Note No (Note 1) 1) CEN-185 Suppl. 3 (0) No (Note 1) l.b. See our previous submittals, references The existing Instrumentation systems which provide information pertinent to ICC considerations are the single channel Sub-cooling Margin Monitor (SMM) an'd the Core Exit Thermocouples. The Subcooling Margin Monitor (SViM) displays temperature margin continuously and any hot leg RTD temperature or Reactor Coolant Pressure on demand. The hot leg RTD's range is OoF to 750oF. The Reactor Coolant Pressure Transmitters range are 0 - 3000 psig. There are (3) three hot leg RTD's (1) per loop inputs to the SMM. The two pressure transmitters are input to the single channel SMM. The SMM was upgraded per our commitments described in letter L 019, dated 12/26/80. The Core Exit Thermocouples provide input to the Digital Data Processing System (DDPS). l.c. The ICCS is projected to be completed during the present refueling outage pending delivery of hardware. The hot leg temperature and pressure inputs to the existing SMM will be used as input for the ICCS. The new three dual cold leg temperature RTD's inputs to the ICCS will be installed during the refueling outage and routed to the QSPDS cabinets through the new electrical penetrations. The CET's will be separated in two channels and routed thru the two ICCS penetrations to the QSPDS cabinets. lh ) Page 10 of 15 Item Reference Deviation Schedule No. NN Continued... Note 3)

2. CEN-185 (App. A) (I) No (Note I)

CEN-185 Suppl. I (2) No (Note I) CEN-185 Suppl. 2 (3) No (Note I) CEN-185 Svppl. 3 (0) No (Note I) CEN-181-P Question 82 (5) No (Note I) CEOG letter 6/I/82 No (Note I) to D. Crutchfield (NRC) Yo (Note I) (Questions 1,2;3RO). QSPDS Factory Test Report 1983 outage

3. CEN-185 Suppl. I (2) No (Note I)

CEN-185 Suppl. 2 (3) No (Note I) CEN-185 Svppl. 3 (0) No (Note I) CEN-185 Section 5.0 (I) No (Note I) CEN-181-P Question 812 (5) No (Note I) Qualification Report No of the ICCS-(CE hardware) Sept. I, 83 ICCS Technical Manual Sept. I, 83 (including instrument calibration). CEN-185 Section 8 (I) No (Note I) Table 2 of this document No also addresses App. B NUREG 0737 Table 3 of this document Also addresses Attachment I NUREG 0737

5. CEN-185 Section 3 (I) No (Note I)

CEN-185 Suppl. 3 (0) No (Note I) N PROD-ICE-3201.01 Att. I No (Note 2) NPROD-ICE-3202 Att. 2 No (Note 2) 16081-ICE-3218 Att. 3 No (Note 2) 16081-ICE-3219 Att. 0 No, (Note 2) 16081-ICE-3220 Att. 5 No (Note 2) 16081-ICE-3111 Att. 6 No (Note 2)

6. Installation schedule for the new instrumentation is addressed in the response to NRC request No. I.

ICCS test reports. No Sept. 1983 ICCS instrument calibration will be included in the test reports. 1 0 0 Page ll of 15 Reference Deviation Schedule No. NN Note 3 CEN-185 Section 2 (1) No (Note 1) CEN-181-P Question 2 (5) No (Note 1) CEOG letter 6/I/S2'o No (Note 1) Crutchfield (NRC) '(question 8 1) CEN-152 Rev. 1 (6) (Note 1) CEN-152 Rev. 1 (6) (Note 1) Final Emergency Operating No (See 3.d) Procedure No additional submittals are projected after this document. Additonal information is available upon NRC request. The spacing of the H3TC sensor from the core alignment. plate to the top of the Reactor Vessel head is shown on the Attachment 9. Loss of a single sensor will not affect the ability of the system to detect an approach to ICC because the system is completely redundant. Two H3TC probes with eight sensors each are provided. Page 12 of 15 .NOTES - Table 1 Note 1: Document submitted to NRC by CE owners group. (Complete) Note 2: Document attached. Note 3: After implementation of the ICCS there are no deviations. from NUREG-0737 requirements, except Item 3 of Table 2. Note 0: This-document is proprietary and can only be reviewed at CE's or FPL's premises. Note 5: This document is propr'ietary and can only be reviewed at lV's or FPL's premises. i~ I Page.13 of 15 TABLE -2 CONFORM'ANCE V/ITH APPENDIX B OF NUREG-0737 Item Reference Deviation Note 3 CEN-185 (section 5) (1) No CEN-185 suppl. 3 (0) Test Report to comply with Req. Guide 1.89 (NUREG-0588) 20 CEN-181-P (5) No Question - Letter 6/1/82 811'EOG to NRC (Question NO)

3. Plant Change Modification Package Yes is available. (Class IE Power Supply for ICCS)+

CEN-185 Suppl. 3 (0) No CEN-181-P Question 812 CEOG letter 6/1/82 to NRC (Question 80)

5. CE Quality Assurance Design No Manual.

All other manufacturers of Class IE equipment Q.A. manual.

6. CEN-185 (Section 2RO) (1) No

7. Recording is accomplished in the SAS.

Described in the Plant Change No Modification Packages

9. Isolation is accomplished in the QSPDS cabinet.

+ Redundant Class IE power, backed-up by the Emergency Diesel Generator is provided instead of uninterruptible power supply. Existing Plant inverters will be upgraded at a later date to provide power to ICCS. Page 10 of 15 TABLE - 3 Conformance with NUREG-0737 II.F.2 ATTACHMENT 1 (CET Criteria)

1. Core exit thermocouple locations are shown on Attachment No. 7.

2. For a description of the primary operator display. Refers to the following documents:

N PROD-ICE-3202 Attachment 2 16081-ICE-3220 Attachment 5 See Attachment 8

3. The back-up display is redundant to the primary display. (See item 2 above).

Emergency operating procedure for the ICCS will be addressed in our response to the NRC Generic Letter No. 82-33. The operators will be trained in the operation of the ICCS, per the Plant Specific Training Program. a) . Control Room design task analysis will be provided in the response to NRC generic letter No. 82-33, Supplement 1 -to NUREG -0737, Requirement for Emergency Response Capability. b)'he Core Exit Thermocouples meet the criteria of NUREG-0737, Attachment.l and Appendix B.

6. The complete system is powered from two independent and redundant class IE power sources. Isolation is provided at the QSPDS cabinets.

7. Environmental qualification report will be provided for the CET's cabling and connectors. The CET's themselves are not required to be qualified per Regulatory Guide 1.97.

Page.15 of '15 5.0 RESPONSE TO NRC RE UEST NO. 3 GENERIC LETTER NO..'S2-28 INSTALLATION'OFICCS PLANT SPECIFIC SCHEDULE The response to this. request is included in Response No. 1. 0 RESPONSES TO NRC GENERIC LETTER NO. 82-28. TURKEY POINT PLANT UNIT 0 0 Page 2 of 15 TABLE OF CONTENTS SECTION NUMBER TITLE PAGE NUMBER

1.0 Purpose and Scope

2.0 References 3.0 Response to NRC Request No. 1 0.0 Response to NRC Request No. 2 5.0 Response to NRC Request No. 3 1 NPROD-ICE 3201.02, "Functional Design Specification For The Qualified Safety Parameter Display.

System"'ttachment

//2 NPROD-ICE-3202, "Functional Design Specification For QSPDS Display" 3 16081-ICE-3218, "Functional Design Description For The QSPDS For Turkey Point Units 3 R 0 Attachment NO 16081-ICE-3219, "Data Base Description For The QSPDS For Turkey Point Units 3 R 0 Attachment $15 16081-ICE-3220, "Functional Design Specification For The QSPDS Display For Turkey Point Units 3 h 0 Attachment ~/6 16081-ICE-3111, "Interface Design Requirements For QSPDS/SAS Data Communication For Turkey Point Units 3 R 0 Attachment /E7 Core Exit Thermocouple Location Drawings 8 Display Panel Layout Drawing and Installation Attachment N9 HJTC Probe Assembly Drawing 10 Westinghouse Procedure No. MP-2.7.1 FPL-1 Modification of Part Length CRDM for the CE RVLMS Installation, Attachment P/11 Westinghouse Procedure No. MP-2.7.1 FPL-2 Replacement of Upper Internals Guide Tube for the C.E. RVLMS Installation

p 0

Page 3 of 15 1.0 PURPOSE AND SCOPE This document contains responses, to the NRC Generic Letter No. 82-28, dated December 10, 1982, requesting information regarding the inadequate Core Cooling Instrumentation System being installed in Turkey Point Plant Unit 0 to comply with the requirements of NUREG-0737, Section ILF.2.

The scope of this document covers the specific information requested in each one of the three, separate items of the NRC letter which apply to Turkey Point Plant Unit 0. However, generic information is referenced when it is contained in a specific document.

The information included'in this document includes the following topics:

1. Identification of the Reactor Coolant Inventory System selected for this plant.

2. Generic design description of the system.

3. -

Detailed schedule for engineering, procurement and 'installation of the system.

0. 'System compliance with the NUREG-0737 Section II.F.2.

0 ik Page.O of 15

2.0 REFERENCES

CEN-185'DOCUMENTATION OF INADEQUATE CORE COOLING INSTRUMENTATION FOR COMBUSTION ENGINEERING NUCLEAR STEAM SUPPLY SYSTEMS," SEPTEMBER 1981, COMBUSTION ENGINEERING, INC.

2. CEN-18'5-P, SUPPLEMENT 1, "HEATED 3UNCTION THERMOCOUPLE: PHASE 1 TEST REPORT," NOVEMBER, 1981, COMBUSTION ENGINEERING, INC.

3. CEN-185-P, SUPPLEMENT 2, "HEATED 3UNCTION THERMOCOUPLE: PHASE II TEST REPORT," NOVEMBER 1981, COMBUSTION ENGINEERING, INC.

CEN-185-P, SUPPLEMENT 3, "HEATED 3UNCTION THERMOCOUPLE: PHASE III TEST REPORT," 3UNE, 1982, COMBUSTION ENGINEERING, INC.

50 CEN-181-P, "GENERIC RESPONSES TO NRC QUESTIONS ON THE C-E INADEQUATE CORE COOLING INSTRUMENTATION,"

SEPTEMBER, 1981, COMBUSTION ENGINEERING, INC.

6. CEN-152 Rev. 1, "CE EMERGENCY PROCEDURE GUIDELINES",

NOVEMBER,. 1982

7. FPL SUBMITTALTO NRC DATED 3ANUARY 7, 1982 (LETTER L-82-5)

8. FPL SUBMITTALTO NRC DATED 3UNE'25, 1981, (LETTER L-81-263)

9. FPL SUBMITTALTO NRC DATED DECEMBER 26, '1980, (LETTER L-80-019)

10. FPL SUBMITTALTO NRC DATED MARCH 10, 1980 (LETTER L-80-79)

FPL SUBMITTAL TO NRC DATED 3ANUARY 11, 1980 (LETTER L-80-16)

NOTE: References 1 through 6 have been submitted to the NRC by the CE owner's group.

Page 5 of 15 3.0 RESPONSES TO NRC RE UEST NO. 1 GENERIC LETTER NO. 82-28 The following discussion covers the ICCS asked for in Request No. 3 as well as the Reactor Coolant Inventory System:

Identification of the Reactor Coolant Inventor S stem (RCIS)

Selected for Turke Point Plant Unit 0.

The Combustion Engineering's Inadequate Core Cooling System (ICCS) which includes the "Heated 3unction Thermocouple System" (H3TC) to detect Reactor Coolant Inventory, was selected for implementation in Turkey Point Plant Unit 0.

2. Desi n Descri tion of the Inadequate 'eneral Core Coolin S stem (ICCS).

(This description supersedes the generic description of our previous submittal, Reference 8).

The ICCS as designed by C.E., is comprised of the following instrument sensor packages for detection of inadequate core cooling:

(1) Heated 3unction Thermocouple System (H3TC) as (RCIS).

(2) Subcooling Margin Monitor (SMM) Detection System, which comprises hot leg and cold leg RTD's (Resistance Temperature Detectors), and Reactor Coolant System pressure sensors.

Core Exit Thermocouple System (CET's).

The above instrument sensor packages are inputs to the Qualified Safety Parameter Display Cabinets (QSPDS), which comprises the sensor processing equipment, operator interface equipment, and isolated data link with the Safety Assessment System (SAS). The ICCS instrument sensor packages are described in the CE generic document, Reference 1. The plant specific ICCS inputs are described in the Data Bases, Attachment 0.

The QSPDS is described in the CE generic document, Attachment I.

The p'lant specific functional design description for the QSPDS is detailed in Attachment 3. Note that the QSPDS for this plant is only used to process the ICCS parameters, and is not a'back-up Safety Parameter Display System (SPDS) as described in Attachment l.

The QSPDS functional design for the display is described in the CE generic document Attachment 2. The plant specific display design for the QSPDS is detailed in Attachment 5.

The display system for this plant only includes the three ICCS sensor packages as described above.

The H3TC sensors are located in part length control rod locations No.

59 and 60,, which have been modified in the internals and pressure boundary to accommodate the new H3TC probe assemblies. (See Attachment 10 2 11)

Ik 0 Page 6 of 15 Mineral insulated (MI) cable will be-routed in two separate channels from the reactor head to the two redundant electrical penetrations designed for the ICCS inputs.

Outside the containment the H3TC sensors will be connected to the two redundant channels of QSPDS processing equipment with organic cables routed in two channels. The data link cables will interconnect the QSPDS cabinet with the display in the Control Room and the Safety Assessment System (SAS).

The CET cabling system including connectors is being up-graded to meet containment environmental qualification, as required by NUREG-0737.

Plant Change Modification packages have been prepared for the installation of the ICCS. These implementation packages include the installation of the QSPDS equipment, electrical penetrations, MI cables inside containment, reactor head and reactor internals modification, interconnecting cables outside containment and Class IE'power supply equipment for the ICCS.

3. Schedule for En ineerin Procurement and Installation of the ICCS a) En ineerin Schedule-a-1) The Engineering for the installation of the ICC System is essentially complete.

a-2) The Engineering for the ICC System hardware is essentially complete. Engineering documentation is available upon request.

b) Procurement Schedule All ICCS hardware and software have been purchased. Some equipment has already been delivered to the job site. The following is the projected, delivery schedule for the remainder of the, equipment.

QSPDS hardware (including electronics, March 10, 1983 display, page control module, power supply and cables).

H3TC Probe March 18, 1983 Probe Handling Canister March.15, 1983 MI Cable March 12, 1983

0 Page 7 of 15 c) Installation Schedule The in containment portion of the CE ICCS installation is projected to be completed during the 1983 refueling outage pending delivery of the hardware. 'The balance of the installation is expected to be completed by 3anuary 1980.

The system will be used for operator training purposes until the control room design review and pre-implementation review of the ICCS by NRC is completed, and until the new qualified computer room for the QSPDS cabinets are completed and ready for operation.

The Computer Room is scheduled for completion by September, 1983.

The modifications of the part length control, rods that will be used for the H3TC probes were completed. This modification includes reactor internals and pressure boundary modification (attachment 10

• 11 and section 0.0, Note 0). The rest of the installation involves the following:

1. Replacement of the CET connectors.

2. Installation. of the MI cable for the H3TC system from the two new probe assemblies at the reactor head to the two new electrical penetrations for the ICCS inputs.

3. Installation of the MI cable for the CET's from the reactor head to the two electrical penetrations.

0. Installation of the two new electrical penetrations.

'5. Installation of the QSPDS cabinets.

6. Installation of the ICCS plasma displays Power Supply and Page Control modules.

7. Installation of interconnecting cables outside containment, including communication cables from QSPDS to SAS and displays.

Qualification and test reports, operating procedures, emergency procedures and licensing documentation will be completed after the unit start-up. (See section 3-d below).

The existing Subcooling Margin Monitors (SMM) will remain in operation after the present outage until the ICCS is approved by the NRC for operation. The the existing Hot Leg temperature and Reactor Coolant system Pressure inputs will be re-connected to the QSPDS cabinets and the existing SMM equipment will be removed from the Control Room. (See Section 0.0 item I.c)

I

0 Page.8 of 15 d) Test and uglification Re orts The HJTC test reports are documented in supplements 1, 2 and 3 of CEN-185 (Reference 2,3 and 0).

The QSPDS test is on-going and is schedule,to be completed by June 1, 1983.

The MI cable qualification test report is projected to be completed by September 1, 1983.

The pressure. boundary safety analysis and stress report will be available by the end of the refueling outage.

The qualification report for the electrical penetration will be available by September, 1983.

The qualification report for the complete ICCS will be available by September, 1983.

The operating procedure will be addressed in our response to the NRC Generic Letter No. 82-33.

II Page 9 of 15 0.0 RESPONSE TO NRC RE UEST NO. 2 GENERIC LETTER NO. 82-28 STATUS OF CONFORMANCE OF THE ICCS 'I'ITH NUREG,0737 SECTION II:F.2 TABLE 1 (Refers to same item number in the Appendix to the the generic letter 82-28)

Item Reference Deviation Schedule No. ~Note 3 l.a. CEN-185 (1) No (Note 1) 16081-ICE-3219 Attachment 0 No (Note 2)

NPROD-ICE-3201 Attachment 1 No (Note 0) 16081-ICE-3218 Attachment 3 No (Note 2)

NPROD-ICE-3202 Attachment 2 No (Note 2) 16081-ICE-3220 Attachment 5 No (Note 2)

CEN-181-P (5) No (Note 1)

CEN-185 Suppl. 1 (2) No (Note 1)

CEN-185 Suppl. 2 (3) No (Note 1)

CEN-185 Suppl. 3 (0) No (Note 1) l.b. See our previous submittals,.references 7, 8 and 9.

The existing Instrumentation systems which provide information pertinent to ICC considerations are the single channel Sub-cooling Margin Monitor (SMM) and the Core Exit Thermocouples.

The Subcooling Margin Monitor (SMM), displays temperature margin continuously and any hot leg RTD temperature or Reactor Coolant Pressure under demand. The hot leg RTD's range is OoF to 750oF.

The Reactor Coolant -Pressure Transmitters range are 0 - 3000 psig.

There are (3) three hot leg RTD's (1) per loop inputs to the SMM. The two pressure transmitters are input to the single channel SMM. The SMM was upgraded per our commitments described in letter L 019, dated 12/26/80.

The Core Exit Thermocouples provide input to the Digital Data Processing System (DDPS).

l.c. The existing SMM described, in item l.b. will remain in operation after this outage. The ICCS is projected to be'completed during the refueling outage pending delivery of hardware.

The existing hot leg temperature and pressure inputs to the SMM will be used as input for the ICCS.

The new three dual cold leg temperature RTD's inputs to the ICCS will be installed during the re'fueling outage and routed to the QSPDS cabinets through the new electrical penetrations.

The CET's will be separated in two channels and routed thru the two ICCS penetrations to the QSPDS cabinets.

0 Page l0 of 15 Item Re ference Deviation Schedule No. NN Continued... Note 3

2. 'CEN-185 (App. A) (1) No (Note 1)

CEN-185 Suppl. 1 (2) No (Note 1)

CEN-185 Suppl. 2 (3) No (Note 1)

CEN-185 Suppl. 3 (0) No (Note 1)

CEN-181-P Question P/2 (5) No (Note 1)

CEOG letter 6/1/82 No (Note 1) to D. Crutchfield-(NRC) No (Note 1)

(Questions 1,2,3RO).

QSPDS Factory Test Report No Sept. 1983 3e CEN-185 Suppl. 1 (2) No (Note 1)

CEN-185 Suppl. 2 (3) No (Note 1)

CEN-185 Suppl. 3 (0) No (Note 1)

CEN-185 Section 5.0 (1) No (Note 1)

CEN-181-P Question N12 (5) No (Note 1)

Qualification Report No Sept., 1983 of the ICCS-(CE hardware)

ICCS Technical Manual Sept., 1983 (including instrument calibration).

CEN-185 Section 8 (1) No (Note 1)

Table 2 of this document No (Note 1) also addresses App. B NUREG-073>

Table 3 of this document No (Note 1)

Also addresses Attachment l NUREG.-0737 CEN-185 Section 3 (1) No (Note 1)

CEN-185 Suppl. 3 (4) No (Note 1)

NPROD-ICE-3201.01 Att. 1 No (Note 2)

NPROD-ICE-3202 Att. 2 No (Note 2) 16081-ICE-3218 Att. 3 No (Note 2) 16081-ICE-3219 Att. 0 No (Note 2) 16081-ICE-3220 Att. 5 No (Note 2) 16081-ICE-3111 Att. 6 No (Note 2)

6. Installation schedule for the new No instrumentation is addressed in the response to NRC request No. l.

ICCS test reports. No Sept., 1983 ICCS instrument calibration will be included in the test reports.

0 0 8

Page 1-1 of 15 Item Reference Deviation Schedule

~No.. Continued... Note 3

7. CEN-'185 Section 2 (1) No (Note 1)

CEN-181-P Question 2 No (Note 1) letter 6/1/82 (5)'EOG No (Note 1) to Crutchfield (NRC)

(question 81)

CEN-152 Rev. 1 (6) (Note 1)

CEN-152 Rev. 1 (6) (Note 1)

Final Emergency Operating No (See 3.d)

Procedure

9. No additional submittals are projected after this document.

A'dditonal information is available upon NRC request.

The spacing of the H3TC sensor from th'e core alignment plate to the top of the Reactor Vessel head is shown on the A'ttachment 9.

Loss of a single sensor will not affect the ability of the system to detect an approach to ICC because the system is completely redundant.

Two HJTC probes with eight sensors.

each areprovided.

\

V

Page 12 of 15 NOTES - Table 1 Note 1: Document submitted to NRC by CE owners-group. (Complete)

Note 2: Document attached Note 3: After implementation of the ICCS there are no deviations from NUREG-0737 requirements, except Item 3 of Table 2.

Note 0: This document is proprietary and can only be viewed at CE's or FPL's premises.

Note 5: This document is proprietary and can only be viewed at lV's or FPL's premises.

I

lh Page 13 of 15 TABLE -2 CONFORMANCE WITH APPENDIX B OF NUREG-0737 Item Re ference Deviation Note 3 CEN-185 (section 5). (1)

No CEN-185 suppl. 3 (4)

Test Report to comply with Req. Guide 1.89 (NUREG-0588)

2. CEN-181-P (5) No Question 811 CEOG - Letter 6/1/82 to NRC (Question S/4)

3. Plant Change Modification Package Yes is available. (Class IE Power Supply for ICCS)+

CEN-185 Supp>. 3 (4) No CEN-181-P Question f/12 CEOG letter 6/1/82 to NRC (Question 84)

5. CE Quality Assurance Design No Manual.

All other manufacturers of Class IE equipment Q.A. manual

6. CEN-185 (Section 2h:4) (1)

7. Recording is accomplished in the SAS.

8. Described in the Plant Change No Modification Packages

9. Isolation is accomplished in the QSPDS cabinet.

+Redundant Class IE power,, backed-up by the Emergency Diesel Generator is provided instead of uninterruptible power supply. Existing Plant inverters will be upgraded at a later date to provide power to the ICCS.

il 0 Page.10 of 15 TABLE - 3 Conformance with NUREG-0737 II.F.2 ATTACHMENT Criteria) 1'CET

l. Core exit thermocouple locations are shown on Attachment No. 7.

2. For a description of the primary operator display. Refers to the following documents:

NPROD-ICE-3202 Attachment No. 2 16081-ICE-3220 Attachment No. 5

'ee Attachment 8

3. The back-up display is redundant to the primary display. (See 'item 2 above).

Emergency operating procedure for the ICCS will be addressed in our response to the NRC Generic Letter No. 82-33. The operators will be trained in the operation of the ICCS, per the Plant specific training program.

5. a) Control Room design task analysis will be provided in the response to NRC generic letter No. 82-33, Supplement 1 to NUREG -0737, Requirement for Emergency Response Capability.

b) The Core Exit Thermocouples meet the criteria of NUREG-0737, Attachment 1 and Appendix B.

6. The complete system is powered from two independent and redundant class IE power sources. Isolation is provided at the QSPDS cabinets.

7. Environmental qualification report will be provided for the CET cabling and connectors. The CET's themselves are not required to be qualified per Regulatory Guide 1.97.

0 5.0, RESPONSE TO NRC RE UEST NO. 3 GENERIC LETTER NO. 82-28 INSTALLATIONOF ICCS PLANT SPECIFIC SCHEDULE The response to this request is included in Response No. l.

ih ATTACHMENTNO. I A

FUNCTIONAL DESIGN SPECIFICATION FOR THE QUALIFIED SAFETY PARAMETER DISPLAY SYSTEM FUNCTIONAL DESIGN SPECIFICATION NO. NPROD-ICE-320l, REV. 02 NUCLEAR POWER SYSTEM COMBUSTION ENGINEERING, INC.

WINDSOR, CONNECTICUT Note: Since the above document is a Combustion Engineering proprietary document, it cannot be transmitted with our submittal.

A non-proprietary document Engineering at a later date.

will be prepared 'y Combustion

It ~

J

ATTACHMENT NO. 7 CORE EXIT THERNOCOUPLE LOCATION DRAWINGS UNIT 3

1. Drawing E-16081-165-051 Rev. 01; Incore CET Wiring,Diagram Channel'A"

2. Dr awing E-16081-165-052 Rev. 01; Incore CET Wiring Diagram Channel "B" UNIT 4

1. Drawing E-16081-165-151 Rev. 01; Incore Wiring Diagram Channel "A"

2. Dr,awing f-16081'-165-152 Rev. 01;. Incore Wiring Diagram Channel "B"

ATTACHMENT NO. 8 DISPLAY PANEL LAYOUT AND INSTALLATION UNIT 3

1. Sketch 1

2. Sketch 2

.3. Or awi ng 5610-N-301-37-11 E-1714 UNIT 4

1. Sketch 1

2. Sketch 2

3. Or awi ng 5610-N-301-41-14 E-1718

0 ATTACHMENT NO. 9 HJTC PROBE ASSEMBLY DRAWING UNIT 3 Drawing E-West-849-501 Rev. 02; flexible HJTC probe Assy.

UNIT 4

.Drawing E-West-849-508 Rev. 02; Flexible HJTC Probe Assy-.

0 ATTACHMENTNO. 10 WESTINGHOUSE ELECTRIC 'CORPORATION NUCLEAR SERVICES DIVISION PROCEDURE NO. MP-2.7.1 FPL-1 "MODIFICATIONOF THE PART LENGTH CRDM FOR THE C.E. RVLMS INSTALLATION!'

Since the above document is a Westinghouse proprietary document it cannot be transmitted with our submittal.

The document is available for your review at Westinghouse Nuclear Services Division, Pittsburgh, PA.

ll Ik ATTACHM'ENT NO. 11 WESTINGHOUSE ELECTRIC CORPORATION NUCLEAR SERVICES DIVISION PROCEDURE NO. MP-2.7.1 FPL-2 "REPLACEMENT OF UPPER INTERNALS GUIDE.TUBE FOR THE C.E. RVLMS INSTALLATION" Since the above document is a Westinghouse, proprietary document it cannot be transmitted with our submittal.

The document is available for your review at Westinghouse Nuclear Services Div!sion, Pittsburgh,. PA.

STATE OF FLORIDA )

) ss COUNTY OF DADE )

Robert E. Uhri being first duly sworn, deposes and says:

That he is Vice Presiden of Florida Power &

Light Company, the Licensee 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 Robert E. Uhrig Subscribed and sworn to before me this

~4l~day of l9 Q3 NOTARY PUBLIC, 'n and for the County of Dade,

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