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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17355A4601999-10-26026 October 1999 Forwards Revised Epips,Including Revs to 0-EPIP-1102, 0-EPIP-1212,0-EPIP-20110,0-EPIP-20111,0-EPIP-20132, 0-EPIP-20133 & 0-EPIP-20201,per 10CFR50.54(q) & 10CFR50, App E.Epip 0-EPIP-20107,has Been Deleted ML17355A4301999-10-0808 October 1999 Forwards Rev 16 of Updated Fsar.Info Accurately Reflects Plant Changes Made Since Previous Submittal.Rev Incorporates Changes Completed Between 971015 & 990408.Summary of Accuracy Review Changes & Instructions,Included ML17355A4461999-10-0404 October 1999 Notifies NRC of Change in Commitment to Perform Periodic Testing of Critical Welds & Parts on Special Lifting Devices IAW NUREG-0612.Use of Ae Technology Will Provide Same Level of Testing Quality as Did NDE Methods Noted in ANSI Std L-99-208, Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included1999-10-0404 October 1999 Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included ML17355A4291999-10-0404 October 1999 Forwards Response to NRC Telcon Questions Re License Amend Request Dtd 990727,proposing Amend on one-time Basis to Modify TS 3.8.1.1 & TS 3.4.3 & 3.5.2 to Extend Allowed Outage Time for EDG from 72 H to 7 Days ML20212M1601999-09-28028 September 1999 Refers to 990908 Engineering Meeting Conducted at NRC Region II to Discuss Engineering Issues at Lucie & Turkey Point Facilities.List of Attendees & Copy of Presentation Handout Encl ML17355A4251999-09-22022 September 1999 Forwards NRC Form 536 in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Issued 990820 ML17355A4111999-09-0909 September 1999 Informs That Thermo-Lag Upgrades for Fire Zones 47,54,113, 114,115,116,118,119,120 & 143 Completed on 990726,per GL 92-08 ML17355A4131999-09-0707 September 1999 Forwards Revised Relief Request 20 Re Requirement to Perform Exams as Required by IWL-2524 & IWL-2525,Table IWL-2500-1 for Exempt Tendon Insp,Per Recent Discussions with NRC ML17355A4141999-09-0202 September 1999 Documents That Util Has No Concerns or Challenges Related to site-specific Written Exam Administered at Plant on 990830 ML17355A4041999-08-23023 August 1999 Forwards Info to Support Assessment of Potential Risks Associated with Proposed Civil Aircraft Operations at Former Homestead Air Force Base to FP&L Turkey Point Nuclear Facility Units 3 & 4 ML17355A4071999-08-23023 August 1999 Informs That FPL Has Completed Review of Info Listed in Reactor Vessel Integrity Database,Version 2 & Found Listed Discrepancies,Re Closure of GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity. ML17355A4061999-08-23023 August 1999 Forwards Semiannual FFD Performance Rept for Period of Jan- June 1999,for Turkey Point Units 3 & 4.List of Events Reported & Summary of Mgt Actions Taken,Included ML17355A4001999-08-20020 August 1999 Informs That on 990722,util Determined Blind Specimen Submitted to Smithkline Beecham Clinical Labs on 990721,was Reported Back with Unsatisfactory Results.Attachment 1 Is Summary of Investigation of Unsatisfactory Performance ML17355A3941999-07-27027 July 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for FY00 & FY01 ML17355A3871999-07-16016 July 1999 Provides Supplement to FP&L Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17355A3851999-07-14014 July 1999 Informs That Pages Missing from 1998 Annual Radiological Environ Operating Rept, Contain Info Unrelated to ODCM- Specified Sampling & Were Not Included as Part of Rept ML17355A3711999-07-0606 July 1999 Forwards Revised EPIPs 0-EPIP-20201, Maintaining Emergency Preparedness - Radiological Emergency Plan Training & 0-EPIP-20126, Off-Site Dose Calculations. with Summary of Changes ML17355A3591999-06-30030 June 1999 Forwards Turkey Point,Unit 4 ISI Rept. Listed Repts Are Encl.No Eddy Current Exams Scheduled for Unit 4 Steam Generators ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17355A3571999-06-28028 June 1999 Informs That Util Voluntarily Reporting Facility Readiness as Outlined in Suppl 1 to GL 98-01.Encl Is Y2K Readiness Disclosure for Units 3 & 4,reporting Status of Facility Y2K Readiness ML17355A3521999-06-18018 June 1999 Forwards Response to NRC 990415 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML17355A3491999-06-0404 June 1999 Forwards Summary of Corrective Actions Implemented by FPL Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions. ML17355A3441999-05-27027 May 1999 Modifies FPLs Consent to Confirmatory Order to Reflect Resolution of Four Issues Identified as Pending in L-99-031 ML17355A3451999-05-24024 May 1999 Requests Waiver of 520 Hours (13 Wks) Required Parallel Watchstanding in Control Room Prior to License Application Submittal for W Conley ML17355A2921999-04-22022 April 1999 Forwards Rev 35 to Turkey Point EP & Revised EPIP 0-EPIP-20101, Duties of EC, Per Requirements of 10CFR50, App E & 10CFR50.54(q).Summary of Changes,Encl.Implementation Date for Both Documents Was 990330 ML20205M0431999-04-13013 April 1999 Eighth Partial Response to FOIA Request for Records.App Q & R Records Encl & Being Made Available in PDR ML17355A2891999-04-0909 April 1999 Forwards Relief Request 20, Exempt Tendon Insp, Requesting Relief from ASME Section XI Code,1992 Edition,Paragraph IWL-2521.1(c) Which Requires That Each Exempted Tendon Be Examined IAW IWL-2524 & IWL-2525.Approval Needed by 991001 ML17355A2861999-04-0505 April 1999 Forwards COLR for Turkey Point Unit 4,Cycle 18,IAW TS 6.9.1.7 ML17336A0681999-04-0101 April 1999 Expresses Support for FP&L Request for Waiver of Applicable Review Fees Upon FP&L Submittal of an Application for License Renewal for Turkey Point Units 3 & 4 ML17355A2751999-03-25025 March 1999 Informs NRC & Staff of Fp&Ls Plans to Submit License Renewal Application for Turkey Point Units 3 & 4 by End of Dec 2000 ML17355A2641999-03-19019 March 1999 Requests Changes to FPL Official Service List for Turkey Point,Units 3 & 4.Add s Franzone & Remove G Hollinger from All Correspondence ML17355A2651999-03-19019 March 1999 Forwards Annual Radioactive Effluent Release Rept for Jan-Dec 1998 & Rev 7 to ODCM for Gaseous & Liquid Effluents from Turkey Point,Units 3 & 4. ML17355A2621999-03-16016 March 1999 Forwards Special Rept as Result of Turkey Point Unit 3 End-of-Cycle 16 ISI of SG Tubes.Rept Summarizes Results of SG Tube ISI ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML20204C6991999-03-10010 March 1999 Requests Amend to Turkey Point PSP to Modify Requirement to Post Security Officers to Provide Continuous Observation of Entire PA Perimeter in Event of Security Computer Failure. Change to Security Force Staffing Level Also Requested ML17355A2451999-03-0909 March 1999 Submits Info on FPL Current Levels of Nuclear Property Insurance,Per 10CFR50.54(w)(3) ML17355A2501999-03-0808 March 1999 Informs That Licensee Reviewed NRC 990228 Ltr Issuing Exemption Requested Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg.Tabulated Summary of Util Comments & Marked Copy of NRC Ltr & SER Encl ML17355A2441999-03-0101 March 1999 Provides Update to Util Written Notices,Dtd 961120 & 970627 of Claim Involving Alleged Bodily Injury Arising Out of or in Connection with Use of Radioactive Matl at Units 3 & 4 ML17355A2431999-02-25025 February 1999 Informs That FPL Does Not Have Any Candidates from Turkey Point Scheduled to Participate in 990407,Generic Fundamentals Examination (GFE) ML17355A2301999-02-18018 February 1999 Forwards Semiannual Fitness for Duty Performance Data for Period of 980701-981231 for Turkey Point Units 3 & 4 ML17355A2361999-02-18018 February 1999 Forwards Tabulation of 1998 Occupational Exposure Data for Turkey Point,Units 3 & 4,per TS 6.9.1.2.a.Reactor Coolant Specific Activity Limits of 100/E-bar Mci Per Gram of Gross Radioactivity Were Not Exceeded During 1998 L-99-042, Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3)1999-02-18018 February 1999 Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3) ML17355A2341999-02-18018 February 1999 Provides Response to RAI Re GL 97-01, Degradation of Crdm/ CEDM Nozzle & Other Vessel Closure Head Penetrations. ML17355A2231999-02-0808 February 1999 Informs That Util Will Comply with Commitment with Respect to Units 3 & 4,in Response to Ja Zwolinski 990129 Ltr.Util Also Agrees to Incorporate Commitment Into Confirmatory Order Modifying License Effective Immediately Upon Issuance ML17355A2031999-01-29029 January 1999 Forwards Rev 3 to Turkey Point Nuclear Plant Recovery Plan. Rev Does Not Decrease Effectiveness of Plan ML17355A2171999-01-20020 January 1999 Forwards Listed ISI Repts for Turkey Point Unit 3,in Accordance with Provisions of ASME Code,Section XI ML17354B2241999-01-0606 January 1999 Forwards Annual 10CFR50.46 Rept Re Changes To,Or Errors Discovered in ECCS Evaluation Models,Or in Application of Such Models That Effect Peak Clad Temp Calculation ML17354B2081998-12-15015 December 1998 Informs That Fpl,In Cooperation with State of Fl & County Emergency Response Agencies,Will Conduct Exercise of Turkey Point Radiological Emergency Plan on 990210.Scenario Package Forwarded to Emergency Preparedness Section Chief,Region II ML17354B2091998-12-15015 December 1998 Forwards Price Anderson Guarantees Annual Financial Rept,Per 10CFR140.21.Exhibit 1 Submitted to Satisfy Annual Financial Reporting Requirement of 10CFR50.71(b) 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17355A4601999-10-26026 October 1999 Forwards Revised Epips,Including Revs to 0-EPIP-1102, 0-EPIP-1212,0-EPIP-20110,0-EPIP-20111,0-EPIP-20132, 0-EPIP-20133 & 0-EPIP-20201,per 10CFR50.54(q) & 10CFR50, App E.Epip 0-EPIP-20107,has Been Deleted ML17355A4301999-10-0808 October 1999 Forwards Rev 16 of Updated Fsar.Info Accurately Reflects Plant Changes Made Since Previous Submittal.Rev Incorporates Changes Completed Between 971015 & 990408.Summary of Accuracy Review Changes & Instructions,Included ML17355A4461999-10-0404 October 1999 Notifies NRC of Change in Commitment to Perform Periodic Testing of Critical Welds & Parts on Special Lifting Devices IAW NUREG-0612.Use of Ae Technology Will Provide Same Level of Testing Quality as Did NDE Methods Noted in ANSI Std L-99-208, Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included1999-10-0404 October 1999 Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included ML17355A4291999-10-0404 October 1999 Forwards Response to NRC Telcon Questions Re License Amend Request Dtd 990727,proposing Amend on one-time Basis to Modify TS 3.8.1.1 & TS 3.4.3 & 3.5.2 to Extend Allowed Outage Time for EDG from 72 H to 7 Days ML17355A4251999-09-22022 September 1999 Forwards NRC Form 536 in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Issued 990820 ML17355A4111999-09-0909 September 1999 Informs That Thermo-Lag Upgrades for Fire Zones 47,54,113, 114,115,116,118,119,120 & 143 Completed on 990726,per GL 92-08 ML17355A4131999-09-0707 September 1999 Forwards Revised Relief Request 20 Re Requirement to Perform Exams as Required by IWL-2524 & IWL-2525,Table IWL-2500-1 for Exempt Tendon Insp,Per Recent Discussions with NRC ML17355A4141999-09-0202 September 1999 Documents That Util Has No Concerns or Challenges Related to site-specific Written Exam Administered at Plant on 990830 ML17355A4041999-08-23023 August 1999 Forwards Info to Support Assessment of Potential Risks Associated with Proposed Civil Aircraft Operations at Former Homestead Air Force Base to FP&L Turkey Point Nuclear Facility Units 3 & 4 ML17355A4071999-08-23023 August 1999 Informs That FPL Has Completed Review of Info Listed in Reactor Vessel Integrity Database,Version 2 & Found Listed Discrepancies,Re Closure of GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity. ML17355A4061999-08-23023 August 1999 Forwards Semiannual FFD Performance Rept for Period of Jan- June 1999,for Turkey Point Units 3 & 4.List of Events Reported & Summary of Mgt Actions Taken,Included ML17355A4001999-08-20020 August 1999 Informs That on 990722,util Determined Blind Specimen Submitted to Smithkline Beecham Clinical Labs on 990721,was Reported Back with Unsatisfactory Results.Attachment 1 Is Summary of Investigation of Unsatisfactory Performance ML17355A3941999-07-27027 July 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for FY00 & FY01 ML17355A3871999-07-16016 July 1999 Provides Supplement to FP&L Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17355A3851999-07-14014 July 1999 Informs That Pages Missing from 1998 Annual Radiological Environ Operating Rept, Contain Info Unrelated to ODCM- Specified Sampling & Were Not Included as Part of Rept ML17355A3711999-07-0606 July 1999 Forwards Revised EPIPs 0-EPIP-20201, Maintaining Emergency Preparedness - Radiological Emergency Plan Training & 0-EPIP-20126, Off-Site Dose Calculations. with Summary of Changes ML17355A3591999-06-30030 June 1999 Forwards Turkey Point,Unit 4 ISI Rept. Listed Repts Are Encl.No Eddy Current Exams Scheduled for Unit 4 Steam Generators ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17355A3571999-06-28028 June 1999 Informs That Util Voluntarily Reporting Facility Readiness as Outlined in Suppl 1 to GL 98-01.Encl Is Y2K Readiness Disclosure for Units 3 & 4,reporting Status of Facility Y2K Readiness ML17355A3521999-06-18018 June 1999 Forwards Response to NRC 990415 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML17355A3491999-06-0404 June 1999 Forwards Summary of Corrective Actions Implemented by FPL Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions. ML17355A3441999-05-27027 May 1999 Modifies FPLs Consent to Confirmatory Order to Reflect Resolution of Four Issues Identified as Pending in L-99-031 ML17355A3451999-05-24024 May 1999 Requests Waiver of 520 Hours (13 Wks) Required Parallel Watchstanding in Control Room Prior to License Application Submittal for W Conley ML17355A2921999-04-22022 April 1999 Forwards Rev 35 to Turkey Point EP & Revised EPIP 0-EPIP-20101, Duties of EC, Per Requirements of 10CFR50, App E & 10CFR50.54(q).Summary of Changes,Encl.Implementation Date for Both Documents Was 990330 ML17355A2891999-04-0909 April 1999 Forwards Relief Request 20, Exempt Tendon Insp, Requesting Relief from ASME Section XI Code,1992 Edition,Paragraph IWL-2521.1(c) Which Requires That Each Exempted Tendon Be Examined IAW IWL-2524 & IWL-2525.Approval Needed by 991001 ML17355A2861999-04-0505 April 1999 Forwards COLR for Turkey Point Unit 4,Cycle 18,IAW TS 6.9.1.7 ML17336A0681999-04-0101 April 1999 Expresses Support for FP&L Request for Waiver of Applicable Review Fees Upon FP&L Submittal of an Application for License Renewal for Turkey Point Units 3 & 4 ML17355A2751999-03-25025 March 1999 Informs NRC & Staff of Fp&Ls Plans to Submit License Renewal Application for Turkey Point Units 3 & 4 by End of Dec 2000 ML17355A2641999-03-19019 March 1999 Requests Changes to FPL Official Service List for Turkey Point,Units 3 & 4.Add s Franzone & Remove G Hollinger from All Correspondence ML17355A2651999-03-19019 March 1999 Forwards Annual Radioactive Effluent Release Rept for Jan-Dec 1998 & Rev 7 to ODCM for Gaseous & Liquid Effluents from Turkey Point,Units 3 & 4. ML17355A2621999-03-16016 March 1999 Forwards Special Rept as Result of Turkey Point Unit 3 End-of-Cycle 16 ISI of SG Tubes.Rept Summarizes Results of SG Tube ISI ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML20204C6991999-03-10010 March 1999 Requests Amend to Turkey Point PSP to Modify Requirement to Post Security Officers to Provide Continuous Observation of Entire PA Perimeter in Event of Security Computer Failure. Change to Security Force Staffing Level Also Requested ML17355A2451999-03-0909 March 1999 Submits Info on FPL Current Levels of Nuclear Property Insurance,Per 10CFR50.54(w)(3) ML17355A2501999-03-0808 March 1999 Informs That Licensee Reviewed NRC 990228 Ltr Issuing Exemption Requested Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg.Tabulated Summary of Util Comments & Marked Copy of NRC Ltr & SER Encl ML17355A2441999-03-0101 March 1999 Provides Update to Util Written Notices,Dtd 961120 & 970627 of Claim Involving Alleged Bodily Injury Arising Out of or in Connection with Use of Radioactive Matl at Units 3 & 4 ML17355A2431999-02-25025 February 1999 Informs That FPL Does Not Have Any Candidates from Turkey Point Scheduled to Participate in 990407,Generic Fundamentals Examination (GFE) ML17355A2341999-02-18018 February 1999 Provides Response to RAI Re GL 97-01, Degradation of Crdm/ CEDM Nozzle & Other Vessel Closure Head Penetrations. L-99-042, Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3)1999-02-18018 February 1999 Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3) ML17355A2361999-02-18018 February 1999 Forwards Tabulation of 1998 Occupational Exposure Data for Turkey Point,Units 3 & 4,per TS 6.9.1.2.a.Reactor Coolant Specific Activity Limits of 100/E-bar Mci Per Gram of Gross Radioactivity Were Not Exceeded During 1998 ML17355A2301999-02-18018 February 1999 Forwards Semiannual Fitness for Duty Performance Data for Period of 980701-981231 for Turkey Point Units 3 & 4 ML17355A2231999-02-0808 February 1999 Informs That Util Will Comply with Commitment with Respect to Units 3 & 4,in Response to Ja Zwolinski 990129 Ltr.Util Also Agrees to Incorporate Commitment Into Confirmatory Order Modifying License Effective Immediately Upon Issuance ML17355A2031999-01-29029 January 1999 Forwards Rev 3 to Turkey Point Nuclear Plant Recovery Plan. Rev Does Not Decrease Effectiveness of Plan ML17355A2171999-01-20020 January 1999 Forwards Listed ISI Repts for Turkey Point Unit 3,in Accordance with Provisions of ASME Code,Section XI ML17354B2241999-01-0606 January 1999 Forwards Annual 10CFR50.46 Rept Re Changes To,Or Errors Discovered in ECCS Evaluation Models,Or in Application of Such Models That Effect Peak Clad Temp Calculation ML17354B2081998-12-15015 December 1998 Informs That Fpl,In Cooperation with State of Fl & County Emergency Response Agencies,Will Conduct Exercise of Turkey Point Radiological Emergency Plan on 990210.Scenario Package Forwarded to Emergency Preparedness Section Chief,Region II ML17354B2091998-12-15015 December 1998 Forwards Price Anderson Guarantees Annual Financial Rept,Per 10CFR140.21.Exhibit 1 Submitted to Satisfy Annual Financial Reporting Requirement of 10CFR50.71(b) ML17354B2061998-12-0909 December 1998 Informs That Request for Exemption Specified in Section II.B.3 Will Not Be Needed Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg ML17354B1981998-11-25025 November 1998 Forwards Scope & Objective for 1999 Plant Annual Emergency Preparedness Exercise.Objectives Developed in Conjunction with State & Local Govts.Exercise Scheduled for 990210 1999-09-09
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ACCELERATED DISTjK3UTION DEMONSTPA,TION SYSTEM t REGULATORY INFORMATION DISTRIBUTION S STEM (RIDS)'t ACCESSION NBR:9010020257 DOC.DATE: 90/09/21 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 HARRISiK.N.
Florida Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Comments on 900615 safety evaluation re station blackout rule 10cfr50.63.
DISTRIBUTION CODE: R050D COPIES RECEIVED:LTR (ENCL SIZE: TITLE: OR Submittal:
Station Blackout (USI A-44)10CFR50.63, MPA A-22 NOTES: RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: NRR PD1-4PM TAM NRR/DST/SELB NRR/DST/SRXBSE EXTERNAL: NRC PDR COPIES LTTR ENCL 1 1 1 1 3 3 1 1 1 1 RECIPIENT ID CODE/NAME EDISONEG NRR/DET/ESGB 8D RR-..S LBSD1 REG FILE 01 NSIC COPIES LTTR ENCL 1 1 2 2 3 3 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WAS'ONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 15 IN 0 SEPTEMBER 2 1 1990.L-90-338 10 CFR 50.63 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Gentlemen:
Re: Turkey Point Units 3 and 4 Docket No.50-250 ance 50-251 Comments on NRC~s Safety Evaluation for Station Blackout By letter dated June 15, 1990, the Nuclear Regulatory Commission (NRC)provided Florida Power S Light Company (FPL)with a Safety Evaluation (SE)on FPL's response to the requirements of the Station Blackout (SBO)Rule, 10 CFR 50.63, for Turkey Point Units 3 and 4.The NRC found FPL's response, which incorporated plant changes that, will be made during the Emergency Power System (EDGs)upgrade, to be acceptable.
However, the SE requested FPL to confirm that one Emergency Diesel Generator (EDG)is capable of maintaining both units in a hot standby condition for an eight hour duration.Resolution'f the SBO issue at FPL's Turkey Point Plant is predicated upon the licensing criteria which were provided in Attachment C.1,"Licensing Basis Criteria", of FPL letter L-89-56 dated April 17, 1989.The capability of one EDG to maintain both units in hot standby is an existing plant design feature which will be incorporated into the Licensing Basis Criteria.Notwithstanding FPL's acceptance of an eight hour duration for a loss of offsite power event, one requirement of the SBO rule is to determine"the probable time needed to restore offsite power" (10 CFR 50.63 (a)(iv)).Based on analysis of all FPL system historical power restoration data, the mean time to restore offsite power applicable to the Turkey Point site is approximately 26 minutes.From this data, there is a 99~probability of restoration of offsite power in about two hours.As provided by FPL's.supplemental information letter, L-90-56, dated March 29, 1990, restoration of AC power can be provided from the FPL grid or offsite blackstart gas turbines.In addition, any two of Turkey Point's five black start diesel generators can supply power via the C-bus.Existing plant operating procedures allow for the black sta'rt diesels to be made available.
Restoration of off-90i0020257 90092i t PDR ADOCK 05000250 P PNU~an FPL Group company
~.~~
U.S.Nuclear Regulatory Commission L-90-338 Page 2 site power.to FPL's nuclear plants is controlled by system operations procedures to provide power to the Turkey Point.switch yard on a priority basis.Attached to this letter are additional details, comments and clarifications on.inaccurate or improper statements in the SE.This letter serves to document the information provided to the NRC during a meeting held with the NRC on August 30,1990, which was attended by NRC and FPL representatives.
If you have additional questions on this please contact us.Very truly yours, K.N.Harris Vice President Turkey Point Nuclear Plant KNH/RWG/lef Attachment 4 l ATTACHMENT To L-90-338 FPL COMMENTS and CLARIFICATIONS
ATTACHMENT 1 L-90-338 Page 1 of 6 1)SE Section
1.0 INTRODUCTION
Resolution of Station Blackout (SBO)for Florida Power and Light (FPL)consists of plant enhancements and modifications which will result in reduced frequency of core damage from a unit or station blackout event to less than 10/reactor year.FPL's compliance with 10 CFR 50.63,"Loss of all Alternating Current Power", and the guidance provided by Regulatory Guide 1.155 and NUMARC 87-00 encompasses meeting the value of 10/reactor year as an acceptable frequency for core damage contribution from sequences initiated by a station loss of offsite power (LOOP)'s established by the NRC.The NRC did recognize that some licensees could provide, or may actually have in place, alternative ways that would significantly enhance the overall AC power reliability (as provided in 10 CFR 50.63)by additional diesels, gas turbines or cross-connect options at two-unit sites that could serve as a one-of-four emergency diesel generator (EDG)configuration rather than one-of-two EDG configurations for unit blackout considerations'.
This led to the"10-minute" alternate AC source at multi-unit sites.The statements of consideration for the rule identified this approach as a"preferred option" to resolve this issue.During the NRC/SBO audit in October 1989, FPL provided the NRC with an overview of the methodology FPL used to comply with 10 CFR 50.63.Specifically, FPL addressed the rule requirements to resolve SBO based on the factors delineated in 10 CFR 50.63 (a)(i), (ii), (iii), and (iv).As presented in our March 29, 1990 submittal, FPL has demonstrated:
a)Redundancy of the onsite emergency AC power sources at Turkey Point Nuclear site will be increased from two to four (modification for SBO will be completed during the dual unit outage in which the EPS upgrades will be performed)
.b)The reliability of the onsite emergency AC power sources is greater than 0.95.c)Based on recent performance (1980's), the expected frequency of loss of offsite power is consistent with other U.S.electrical grids.'NRC staff responses to questions from Commissioners Asselstine, Bernthal, Roberts and Zech during final rule making decision on"Station Blackout" regulation date November 10, 1985.
ATTACHMENT 1 L-90-338 Page 2 of 6 d)The mean restoration time for offsite power is approximately 26 minutes.Based on historical FPL system data, the probability of restoration of offsite power in about two hours is 994 As part of the EPS upgrade, FPL proposed to add two EDGs and system electrical interties to cross-connect electrical buses such that the reliability of the emergency AC power system configuration after a LOOP is significantly enhanced.The new configuration permits any one of four EDGs to mitigate the effects of a unit blackout at the site.One EDG has been shown to be sufficient to provide all the necessary loads associated with placing both units in hot standby from 1004 power for the required transient time duration.FPL has performed a preliminary risk assessment which reflects the significant risk reduction gained by the modifications for a postulated SBO event.Results of the FPL evaluation demonstrates the risk of a SBO after a LOOP event has been reduced from approximately 7.6x10~to 2.9x10~per reactor year.This is directly attributable to the proposed cross-tie capability of the electrical system and adding two EDGs.The evaluation results in a risk reduction factor.in excess of 200.By comparison, in NUREG-1032,"Evaluation of Station Blackout Accidents of Nuclear Power Plants" and in NUREG-1109,"Regulatory Analysis for the Resolution of Unresolved Safety Issue A-44, Station Blackout", the NRC staff reports a risk reduction factor of approximately 2.5 (i.e.2.1x10 to 0.8x10 per reactor year)as the basis for issuance of the SBO rule for units with a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> DC coping capability and one-out-of-two EDG configuration~.
FPL has reduced the vulnerability of a hurricane induced LOOP resulting in a core damage from a SBO.Site specific frequency of hurricane wind speeds of greater than 125 mph is less than 10 per reactor year as reported by three independent sources'.FPL will implement design and procedural precautions to remove or reduce the effects of a hurricane on a SBO event:~Rulemaking Issue Affirmation, SECY-88-22, January 21, 1988.NUREG/CR-4762,"Shutdown Decay Heat Removal Analysis of a Westinghouse 3-LOOP PWR" 3/87.Dames&Moore,"Probabilistic Hurricane Analysis" 1/89.University of South Florida,"Statistical Frequency Hazard Model for Hurricane Wind Speed" 1/90.
L'I ATTACHMENT 1 L-90-338 Page 3 of 6 1)Design wind loads for Class I structures, systems and equipment (including the safety-related equipment which is relied upon to mitigate a SBO)meet or exceed those required by the South Florida Building Code.In addition, Class I structures which house safety-related equipment are designed to resist the effects of a tornado.All existing Class I structures have been designed to withstand tornado wind velocities of 225 mph acting concurrently with rapid pressure drop of 1.5 psi.The new EDG building has been designed to 360 mph and pressure drop of 3.0 psi.2)Turkey Point Units 3 and 4 will commence unit shutdown 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the projected onset of hurricane force winds (75 mph sustained winds)arrive at the site.The results of the above actions will insure that Turkey Point's vulnerability to a hurricane induced LOOP resulting in core damage from a postulated unit blackout is minimal.It is the understanding of FPL that the Technical Evaluation Report (TER)attached to the SE is for information
~onl.The Licensing basis for SBO for the Turkey Point plant is defined by the NRC's Safety Evaluation (SE).This was discussed and agreed upon in the August 30, 1990 meeting with the NRC.2)SE Section 2.0 EVALUATION SE Section 2.1"STATION BLACKOUT DURATION" FPL is interpreting the"duration" as defined in this section as the duration the Turkey Point plant must maintain both units in hot standby using one EDG.A coping analysis is not required pursuant to 10 CFR 50.63 (c)(2)therefore, FPL interprets this section of the SE not to be applicable to Turkey Point plant.The evaluation presented in our March 1990 submittal is valid for a 4-hour duration of SBO.However, since existing plant equipment and operating requirements permit extending the duration to 8-hours, FPL accepts the 8-hour Alternate AC (AAC)duration.FPL will verify that one EDG has sufficient AC power capacity (within the FSAR ratings of the EDGs)and capability to shutdown and maintain hot standby for units 3 and 4.
ATTACHMENT 1 L-90-338 Page 4 of 6 3)SE Section 2.2 ALTERNATE AC AAC POWER SOURCE'\SE Section 2.2.1 GENERAL STAFF POSITION ON AAC POWER SOURCE The capability and capacity of any one EDG as defined in the licensed design bases for Turkey Point units 3 and 4, is sufficient to place both nuclear units in hot standby after a LOOP (i.e., one-of-four redundancy is met for LOOP).The EDGs have been re-evaluated in accordance with SBO criteria for the purpose of maintaining hot standby in the event of a SBO.We have concluded that one EDG can maintain both units in extended hot standby after a LOOP;therefore, this qualifies the EDG as an alternate AC source.The addition of two EDGs does not alter the design bases for the shared electrical system.The enhanced electrical design will permit AC power from any one of four EDGs to maintain both units in hot standby for an eight hour duration after a LOOP event.It is our position that the alternate AC power source is capable of powering at.least one train of"normal safe shutdown" (hot standby)systems and equipment on both units.This includes decay heat removal, battery charging, HVAC, emergency lighting, and the associated controls and instrumentation.
Thus, the AAC source can support and maintain safe shutdown following SBO from the control room coupled with operator actions outside the control room.4)SE Section 2.2.1.1 EDGs USED AS AAC POWER SOURCE The TER (page 15)statement concerning loading additional equipment on the operable EDG (i.e.Residual Heat Removal (RHR)pump, computers, etc.')is inconsistent with the SBO rule requirements to load only safe shutdown loads.'onsistent with NUMARC 87-00 guidance letter of May 7, 1990, the Turkey Point EDG load evaluation assumes that safety grade loads, required by the design bases for LOOP events to maintain both units in hot standby, will automatically load on the EDG.In addition, select non-safety grade loads (i.e., charging pumps, pressurizer heaters, etc.)will be manually loaded as necessary.
FPL is interpreting"the full contingency of safety train loads" as those loads necessary to maintain hot standby after a LOOP event.These loads will be supplemented by other safety, and non-safety grade loads the plant operators deem helpful to mitigate the unit blackout.Turkey Point plant has no design bases requirements to depressurize after a LOOP.The SBO rule, NUMARC 87-00 and the licensing bases define safe shutdown as hot standby.For EDG evaluation purposes, we intend to maintain the units at hot standby for the eight hour duration.For units in hot standby, operating pressures and temperatures prohibit the use and operation of the RHR system.
ATTACHMENT 1 L-90-338 Page 5 of 6 Pursuant to the design bases of the Turkey Point nuclear units, the RHR system is placed into service when the Reactor Coolant System (RCS)is below 350'F and 450 psig.Our SBO loading evaluation will not consider mode changes during the eight hour period;therefore, the RHR system will not be used during this time.Based on the above, FPL will not include the RHR pump loads in the EDG load evaluation for SBO.It is our position that operator actions, their associated training and operating procedures used to respond to a LOOP event and failure of three of four EDGs (unit blackout)will focus on achieving and maintaining hot standby for both units.Current FPL emergency procedures and operator training rely on a certain amount of operator action after a LOOP event and failure of one EDG.Operator actions and their training are fundamental tenets of the SBO rule and the guidance provided in NUMARC 87-00.A LOOP affects both units equally, as will a unit blackout.Operator action is required to maintain both units in hot standby for eight hours.Trained operators are an important and necessary part of the plant s response to any LOOP and concurrent unit blackout recovery plan.FPL maintains that operators can and will perform load management actions as required to maintain the necessary loads for safe shutdown while ensuring the EDG remains within its load rating.The SBO loading evaluation confirms that safe shutdown equipment will not need to be de-energized on one unit to provide additional capacity for loads on the other unit.The term"normal e ui ment com lement" is used in reference to the loads necessary for the non-blacked out (NBO)unit to retain, while supplying the SBO unit with the necessary power.As agreed to with the NRC in the August 30th meeting we will define this term to mean"safe shutdown e ui ment".5)SE Section 2.2.1.2 CONNECTABILITY OF AN AAC POWER SOURCE It is our position that the SBO rule and NUMARC 87-00 guidance require the assumption of an arbitrary failure of one train (i.e.one EDG)of electrical redundancy on the non-blacked out (NBO)as a means to qualify that unit's remaining EDG as an AAC source.Turkey Point Plant's response to a unit blackout does not consider, nor postulate, additional failures beyond the loss of three EDGs.It is our position that the SBO rule, the regulatory analysis (i.e., NUREG-1032) and R.G.1.155 do not require single failure nor do they require application of Appendix A single failure criterion.
Failures beyond those which produce a unit blackout to qualify an AAC source on the NBO unit are not considered.
Our analysis does not apply single failure criteria to the NBO unit.concurrent with the EDG failures postulated.
ATTACHMENT 1 L-90-338 Page 6 of 6 6)SE Section 2.2.2 PROPOSED AAC POWER SOURCE The design ratings of the most limiting EDG (proposed AAC power source)are provided in FSAR Section 8.2.3"Emergency Power".FPL will not exceed the design ratings provided in the FSAR.~As long as the EDGs are operated within these ratings, it is our position that the EDGs are not considered to be overloaded.
7)SE Section 2.3.4 Effects of Loss of Ventilation As provided in our March 29, 1990 submittal (answer to question 9), HVAC systems for batteries, chargers, inverters, switchgear and charging pump rooms is provided and included in the EDG load list.FPL is presently evaluating select plant areas for additional SBO HVAC requirements.
In the unlikely event that additional fans are required, FPL will include them in the load list and modify procedures as required.The EDG loading will be evaluated to ensure the EDG load rating is not exceeded.8)SE Section 2.3.6 Reactor Coolant Inventor Turkey Point Units 3 and 4 use AAC for safe shutdown during an SBO event.The generic Reactor Coolant Pump (RCP)leakage criteria of 25 gpm per pump (for plants with DC coping), was intended to address units that do not provide cooling to the RCP seals.As an AAC plant, Turkey Point Plant will commence cooling to the seals on the SBO unit shortly after energizing the intertie (in approximately 10 minutes).As a result, no seal damage is postulated and only normal seal leakoff need be assumed for the RCPs.