L-83-237, Responds to Generic Ltr 82-33 (NUREG-0737,Suppl 1) Re Emergency Response Capability.Proposed Implementing Schedules Encl

Responds to Generic Ltr 82-33 (NUREG-0737,Suppl 1) Re Emergency Response Capability.Proposed Implementing Schedules Encl

ML17345B053
Person / Time
Site:	Turkey Point
Issue date:	04/15/1983
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, L-83-237, NUDOCS 8304210184
Download: ML17345B053 (16)

Text

rA W REGULATORY FORMATION DISTRIBUTION SYQ M (RIDE).

ACCESSION NBR: 8304210184 DOC, DATE: 83/04/1'5 NOTARI'ZED; YES FACIL:50-250 Turkey Point Planti Unit 3F Florida Power and Light C

50-251 Turkey Point Planti 'Unit 4F Florida Power and Light C

AUTH'AME AUTHOR AFFILIATION UHRIGPR ~ E, Fl or i de Power 8 L'ight Co, REC IP ~ NAME RECIPIENT AFFILIATION EISENHUTFD.G ~

Division of Licensing DOCKET 05000250 05000251

SUBJECT:

Responds to Generic Ltr 82"33 (NUREG"0737FSuppl 1) re'mergency response capability, Proposed implementing schedu.les encl D I'STRI BUTION CODE A003S COP I ES RECEIVED LT'R ENCL SI ZE ~,

TITLE: OR/Licensi.ng Submi,ttal; Suppl 1 to NUREG-0737(Generic Ltr 82-33)

NOTES:

RECIPIENT ID CODE/NAME NRR ORB1 BC INTERNAL: If/DEPER/EPB NRR/DHFS/PSRB NRR/DL/ORB5 NRR/DSI/ICSB NRR I/RAB FI EXTERNAL: LPDR NSIC tCOPIES LTTR 'ENCL 7

7 3

1 1

5 5

1 1

1 1

1 1

1 1

1 1

RECIPIENT ID CODE/NAME NRR/DHFS/HFEB NRR/DL/ORAB NRR/DS I/CPB NRR/DSI/METB NRR/DSI/RSB RGN2 NRC PDR NTIS COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

TO'YAL NUMBER OF 'COPIES REQUIRED:

LTTR ~

ENCL

~9

0 r

v r,

4 l,

I I

rW j

IPW<<1

'll I I) il yi I f i

il Irr WI II I

I lf, i,r I Ir

<<8 ~

'1('r '1 If y.l!I II ~ r' r

J I r III rJr~Err

<<W

~

I 1

,r,r

)

r~

Wil, Iv QI f

~e w~v<<<<<<vra<<- <<

'- +

40<<$

.> r ~ >" >>

~

W h ~r "l

~e.

I~ I il iii Wire I.W il 1.

Il a I i g

I I

II il f 1 l r,W IJ 'I:1 li'l

'W.l i I

'i Il il 'I 'lg i

/Wring,I h XI'"'

II 3

XI'

'g 'l,

,I,," I4 g

ir r

W,ll, t.

I I

P.

'IX 14000, JUNO BEACH, FL 3340B g1 lg/g

+lliaaA+

FLORIDAPOWER & LIGHTCOMPANY April 15, 1983 L-83-237 Office of Nuclear Reactor Regulation

'Attention:

Mr. Darrell G. Eisenhut, Director Division of Licensing U.

S. Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Mr. Eisenhut:

Re:

Turkey Point Units 3 8t 4 Docket No. 50-250 8 50-251 Supplement 1 to NUREG 0737 Generic Letter 82-33 e

Your letter dated December 17, 1982 transmitted Supplement 1 to NUREG 0737 (Generic Letter No. 82-33).

This Supplement distilled thy basic requirements for five NUREG.0737 items regarding Requirements for Emergency

Response

Capability.

It also requested that we develop our own plant specific schedule for integrating these items and implementing whatever modifications are deemed necessary.

We have participated continually in the Nuclear Utility Task Action Committee (NUTAC) on Emergency

Response

Capabilities, which includes over 40 utilities and is administratively supported by INPD.

We have factored into our schedule the guidance developed by the NUTAC on integrating these initiatives.

Since we have already accaIIplished a

significant amount of work on these, as well as other NUREG 0737 items, we were -forced to deviate somewhat frcm the "idealized" integration

scheme, but have generally followed its outline.

The following are our status and proposed implementing scheduias for the JI0Ip~

items in Supplement 1 to NUREG 0737:

SAFETY PARAMETER DISPLAY SYSTEM SPDS Ao>'50'.

TURKEY POINT UNIT 3 Current Status The parameter selection in accordance with NUREG 0696 and the functional design specification has been completed.

The hardware has been manufactured and is scheduled to be tested and delivered to the site by June 1983.

. The isolation 83042i0184 8304i5 PDR ADOCK 05000250 F

'DR PEOPLE... SERVING PEOPLE

Office of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut Page 6

3.

Emergency Offsite Facility (EOF) - The location of our EOF i s at the FPL General Office located greater.

than 20 miles (about 24 miles) frcm the site.

Accordingly, in L-81-447, dated October 13,

1981, we submitted a request for a specific approval by the Commission in accordance with Generic Letter 82-10.

To date, we have had no response on our request from the NRC.

We are proceeding to implement the necessary physical modifications and are adding the required communication equipment.

However, we are at this time unable to provide a

schedule for full operational capability of the EOF pending NRC response to our request.

It should be noted as stated in the SPDS discussion, that the SPDS will not be in operation prior to startup from the Spring 1985 and Spring 1984 Refueling Outage for Turkey Point Unit 3 and 4, respectively.

The SPDS will be provided in the EOF and TSC at that time.

However, we consider the SPDS to be an additional aid to emergency

recovery, and not a requirenent for the ERFs to oe operational.

We look forward to discussing these schedules with our Project Manager to arrive at a mutually acceptable schedule.

FPL has devoted considerable time and effort in the past to implementing NUREG 0737 requirements.

It is our opinion that with these previous modifications and upgraded plant operations, the continued operation of the plant should pose no threat to the health and'afety of the public with consideration of our implementation schedule for Supplement 1 to NUREG 0737.

Very truly yours, Robert E. Uhrig Vice President Advanced Systems 8 Technology REU/JEM/j s cc:

Mr. James P. O'Reilly, Region II Mr. Harold F.

Rei s, Esquire

j

Office of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut Page 2

2.

3.

cabinets for safety related instrumentation signals will be installed prior to the end of Fall 1983 Refueling Outage.

The software is being tested at the factory.

Submittal of Parameter Selection Basis and SPDS Implementation Pl an Report.

The reports describing the parameter selection and definition along with the implementation plan will be submitted by May 1, 1984.

Date When SPDS Wil 1 Be Operable and Operators Trained The SPDS will be operational prior to startup from the Spring 1985 Refueling Outage.

The verification and validation of the SPDS and operator training wi.ll be completed prior to the SPDS beccming operational.

'B.

TURKEY POINT UNIT 4 Current Status The parameter selection in accordance with NUREG 0696 has oeen completed.

The functional design specification has been completed.

2 ~

The hardware has been manufactured and is scheduled to be tested and delivered onsite by June 1983.

The isolation cabinets for safety related instrumentation signals wi 1 1 be installed prior to the end of the Spring 1983 Refueling Outage.

The software is being tested at the factory.

Submittal of Parameter Selection Basis and SPDS Implementation P ant Report.

The reports describing the parameter selection and definition along with the implementation plan will be submitted by May 1, 1984.

3.

Date When SPDS will be 0 erable and Operators Trained The SPDS will be operational prior to startup from the Spring 1984 Refueling Outage.

The verification and validation of the SPDS and operator training will be ccmpleted prior to the SPDS beccming

.operational.

gl I

Office of Nuclear Reactor Regulation Attention:

Mr.. Darrell G. Eisenhut Page 3

DETAILED CONTROL ROOM DESIGN REVIEW DCRDR A.

TURKEY POINT UNITS 3 5 4 1.

Current Status The DCRDR for Unit 3 has been canpleted except for the review of the SPDS.

A Human Factors Engineering design of the SPDS will integrate the abbreviations and color coding i'nto that of the control room design.

In view of the progress to date, the requirements to,submit the program plan within two months of the start of the DCRDR has been superceded.

With.the issuance of Supplement 1,

and the finalization of NRC requirements, we will now prepare the required documentation.

2.

Submittals The management plan describing our DCRDR. program will be submitted by June 1,

1983.

A summary report of the completed

review, describing the Human Engineering discrepancies.

revi ew and assessment and proposed implementation schedule will be submitted by November 1, 1983.

Actual modifications to.the control roan will be dependent upon NRC review and approval fo the summary report.

REGULATORY GUIDE 1.97 REV.

2 A.

TURKEY POINT UNITS 3 5 4 Current Status 2 ~

We have reviewed our existing accident monitoring instrumentation and control systems against the requirements of Regulatory Guide 1.97, Rev.

2'.

We are presently assessing the deviations found and are developing the schedule for required modifications, if any.

Submittals The evaluation report of the plant instrumentation, schedule for any required modifications, and justification of any deviations not requiring modifications will'e.submitted by March 1, 1984.

Actual modifications will be dependent upon review and approval by the NRC.

i

Office of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut Page 4

UPGRADE EMERGENCY OPERATING PROCEDURES EOPs A.

TURKEY POINT UNITS 3 8 4 Current Status The revision of several Turkey Point EOPs is in progress.

These revisions conform to the Westinghouse Owners Group (WOG) Basic revision Emergency

Response

Guidelines (ERG) in both technical content and general format.

A concerted effort on the entire EOP package cannot be made at this time.

The WOG Revi sion 1

ERG and WOG Writer's Guide is currently being written and may be received by June 1983.

Revision 1 is expected to generally conform to the Basic revision although extensive changes may occur in certain area s.

Virtually all the EOPs will be revised to some degree.

The WOG Writer's Guide will be used to write a plant specific writer' guide.

Deviations frcm WOG supplied material will be documented.

The Turkey Point Writer's Guide will become part of the Procedures Generation Package (PGP).

After ccmpletion of the PGP the EOP revision process will continue, using. the Turkey Point Writer's Guide and WOG Revision 1

ERG.

2 ~

Submittals 8 Implementation a)

Submittal Date for the Generic Technical Guidelines The generic ERG have been submitted by the WOG to the NRC.

The Commission has approved these tecnnical guidelines.

b)

Submittal Date for the Procedures Generation Package The PGP developed for Turkey Point will include the fol l owi ng:

(

i)

A plant specific writer's guide, developed from the WOG generic writer's guide (when received).

( ii)

A description of the EOP validation program.

This progr am's approach has not yet been determined.

However, it will definitely include plant and control room walk-throughs.

Some simulator work may be necessary.

(iii)

A description of the EOP training program.

Training program specifics, have not been determined.

The training program (and validation program) scope wil 1 be determined after receipt of the Revision 1

ERG from the WOG.

0 II

Office of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut Page 5

The PGP will undergo an in-house review and revision process before submittal to the NRC.

The PGP will be submitted to the.

NRC by March 1, 1984.

C.

Date for Implementation of the EOPs The fo 1 1 owi ng requi renents must be met befo re the Turkey Point EOPs can be implemented:

(

i)

Upgrade EOPs to WOG Revision 1 guidelines.

( ii)

Document all changes from existing EOPs to upgraded EOPs.

(iii)

Document all changes fran WOG Revision 1 guidelines to plant specific EOPs.

( iv)

Review completed EOPs.

(

v)

Validate ccmpleted EOPs.

( vi)

Train all licensees in the use.of EOPs.

This effort can be ccmpleted in approximately one year's time

~ after submittal of the Procedures Generation Package.

Tne date given below is based upon NRC acceptance of the PGP as submitted,(PGP review takes place concurrent with EOP revision, validation, etc.)

The planned date for implementation of the EOPs at Turkey Point Units 3

& 4 is December 31, 1984.

EMERGENCY RESPONSE. FACILITIES ERFs)

Supplement 1 requires that we provide the operational dates for the ERFs.

A.

TURKEY POINT UNITS 3

& 4 2.

Technical Support Center (TSC) - The TSC is complete and operational except for the availability of backup electrical power.

The backup electric power supply will be available prior to startup of Unit 3's Fall 1983 Refueling Outage.

Operational Support Center (OSC) - The OSC is currently operational.

41 Il

~ >

~,

STA'TE OF FLORIDA

)

)

ss.

COUNTY OF'PALM BEACH )

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

That he is Vice President Licensee herein; of Florida Power & Light Company, the 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.

Rober't E'hrig Subscribed and sworn to before me this i~~ l>5.day of I98&.

g t

J

~",jNOT/BY.-,

BLIC, in and for the County

'~ oftPalrn'Beach, State. of.Florida.

State of Ronda at Large October 30,.1983 M

OA

0 0

'1~

I f

P