ML17354B191

Submits Response to GL 98-02, Loss of Reactor Coolant Inventory & Associated Potential Loss of Emergency Mitigation Functions While in SD Condition.

ML17354B191
Person / Time
Site:	Turkey Point
Issue date:	11/16/1998
From:	Hovey R FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-98-02, GL-98-2, L-98-258, NUDOCS 9811230154
Download: ML17354B191 (6)

Text

REGULAT INFORMATION DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9811230154 DOC.DATE: 98/11/16 NOTARIZED: NO DOCKET 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 HOVEY,R.J. Florida Power 8 Light Co.

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

SUBJECT:

Submits response to GL 98-02, "Loss of Reactor Coolant Inventory Sc Associated Potential Loss of Emergency Mitigation Functions While in SD Condition." A DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: T TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL 0 PD2-3 LA PD2-3 PD JABBOUR,K INTERNAL: E CEN R NRR/DE/ECGB/A 1 NRR D CB NRR/DRCH/HICB .1 NRR/DSSA/SPLB NRR/DSSA/SRXB 1 NUDOCS-ABSTRACT OGC/HDS3 1 EXTERNAL: NOAC NRC PDR D

NOTE TO ALL uRIDSit RECIPIENTS PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL

F NO. 6 1998 L-98-258 10 CFR 50.4 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 RE: . Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Res onse to Generic Letter 98-02 On May 28, 1998, the NRC issued Generic Letter (GL) 98-02,"Loss of Reactor Coolant Inventory and Associated Potential for Loss of Emergency Mitigation Functions While In a Shutdown Condition," to request that all licensees assess the susceptibility of their residual heat removal (RHR) and emergency core cooling (ECC) systems to common-cause failure as a result of reactor coolant system (RCS) draindown while in a shutdown condition, and to provide information that will enable the NRC staff to verify whether licensees comply with NRC regulatory requirements and conform with current licensing bases. This letter provides the Florida Power and Light Company response to GL 98-02 for Turkey Point Units 3 and 4.

GL 98-02 Required Information Item (1) requested licensees to perform an assessment of whether the ECC systems include certain design features, such as a common pump suction header, which can render the systems susceptible to common-cause failure as a result of events similar to the WolfCreek RCS drain4own event of September 17, 1994.

Turkey Point is designed with a common pump suction header for the ECC systems, and is therefore, susceptible to common cause failure, assuming events similar to the WolfCreek event occur (i.e. loss of command and control in the control room, operation of systems outside Technical Specification limits, failure to follow written procedures).

The Turkey Point RHR system design has specific design features, specifically, interlocked motor operated valves, which minimize the potential of diverting RCS fluid to the Refueling Water Storage Tank during hot shutdown. A review for potential drain-down pathways revealed the credible drain-down scenarios are limited to flowpaths containing valves provided with open-permissive interlocks which prevent inadvertent operation. Administrative controls are placed on system components, work control processes and control room activities, which significantly reduce the potential for an event similar to the WolfCreek event. Based on the Turkey Point features described above and the administrative controls in place, the safety-related function of the RHR and ECC systems during hot shutdown is assured.

This response is provided pursuant to the requirements of Section 182a of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f).

Very truly yours, 4I R. J. Hovey Vice President Turkey Point Plant OIH cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 9'Bii230i54 PDR ADOCK 98iiib 05000250 P PDR an FPL Group company

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-98-258 i

STATE OF FLORIDA )

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COUNTY OF MIAMI-DADE )

R. J. Hovey being first duly sworn, deposes and says:

That he is Vice President, Turkey Point Plant, for the Nuclear Division of Florida Power 8c Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this 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 Licensee.

R. J. Hovey STATE OF FLORIDA COUNTY OF MIAMI-DADE S worn to and subscribed before me this /6 dttyof +0~@4 19@

by R. J. Hovey, who is personally known to me.

( A- 4kW~m Name of Notary Public - State of Florida CHERYL A. STEVENSON fib is MY COINISSI0II 0 CC 6Q017

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